What is the Toy Safety Directive and what products does it cover?

The Toy Safety Directive 2009/48/EC is EU legislation governing the safety of toys sold in the European market. It covers products designed or intended for use in play by children under 14 years old. This includes traditional toys, electronic toys, educational toys, sports equipment for children, activity toys, and products with play value like novelty items.

What testing is required for toys under EN 71?

EN 71 is the European harmonized standard series for toy safety. Key parts include: EN 71-1 (mechanical and physical properties), EN 71-2 (flammability), EN 71-3 (migration of certain elements/heavy metals), EN 71-4 through 71-11 covering chemistry sets, activity toys, age warnings, finger paints, organic compounds, and more. Most toys require at least EN 71-1, 71-2, and 71-3 testing.

How do I determine the correct age grading for my toy?

Age grading must be based on the toy's design, features, and foreseeable use. Consider motor skills, cognitive development, and safety risks for each age group. EN 71-1 provides guidance on age-related hazards. Age grading affects which safety requirements apply—toys for under-3s have stricter small parts requirements. Document your age grading rationale in your technical file.

When is the small parts warning required?

The small parts warning 'Not suitable for children under 36 months' (with choking hazard symbol) is required when a toy intended for children 3-14 contains small parts that would be dangerous for under-3s but is safe for the intended age group. It's mandatory when the toy contains parts that fit in the small parts cylinder (EN 71-1 test). The warning must appear on packaging and be visible before purchase.

What chemical requirements apply to toys?

Toys have strict chemical restrictions under EN 71-3 (migration limits for 19 elements), EN 71-9 (organic compounds), REACH restrictions, and specific bans on substances like phthalates in plasticized materials (DEHP, DBP, BBP prohibited; DINP, DIDP, DNOP restricted in mouthable toys). CMR substances are prohibited unless specifically exempted. Chemical testing is essential for toys with painted surfaces, plastics, or textiles.

Do I need a Notified Body for toy CE marking?

Most toys can be self-certified by the manufacturer using Module A (internal production control). However, third-party testing by a Notified Body is required for: toys using harmonized standards that specify Type Examination (Module B), toys where you haven't applied harmonized standards and used own solutions, and when market surveillance authorities request verification. A Notified Body can also provide credible third-party test reports.

What documentation is required for the toy technical file?

The technical file must include: detailed product description, design drawings and manufacturing information, list of applied harmonized standards, test reports from accredited laboratories, risk assessment covering all relevant hazards, safety assessment for chemicals, age grading justification, instructions and warnings in required languages, Declaration of Conformity, and production quality control procedures.

What warnings and instructions are required for toys?

Required elements include: age grading and any age-specific warnings, 'Warning' heading preceding warning text, specific hazard warnings (small parts, water toys, functional toys, etc.), instructions for safe use in the destination country language, and manufacturer/importer contact information. Warnings must be visible before purchase—on packaging for boxed toys. Warning formats are specified in EN 71-1.

How do marketplaces like Amazon enforce toy compliance?

Amazon actively enforces toy compliance and frequently requests: EN 71 test reports covering parts 1, 2, and 3 at minimum; EU Declaration of Conformity; product images showing CE mark and age grading; and evidence of warnings on packaging. Listings missing compliance documents or proper warnings face suppression. GPSR requirements add manufacturer and EU Responsible Person information requirements.

What is the difference between toy and childcare article requirements?

Childcare articles (car seats, highchairs, baby carriers, etc.) are NOT toys and don't fall under the Toy Safety Directive. They have separate EN standards and different compliance pathways. However, if a childcare article has play features, those features must meet toy safety requirements. Products clearly serving both functions may need to comply with both regulatory frameworks.

EU Directive

High Enforcement

25 min read

Toy Safety Directive Guide

The EU Toy Safety Directive sets some of the strictest safety requirements in the world for products intended for children. This comprehensive guide covers EN 71 testing, age grading, chemical requirements, warnings, and CE marking—everything you need to sell toys legally in the European market.

High Enforcement Category

Toys are among the most heavily regulated and enforced product categories in the EU. Market surveillance authorities conduct frequent testing campaigns, and non-compliant toys face immediate recalls. Amazon and other marketplaces require EN 71 test reports before listing toys. Ensure full compliance before selling.

What is the Toy Safety Directive?

The Toy Safety Directive 2009/48/EC is EU legislation ensuring toys sold in Europe are safe for children. It applies to products designed or intended, whether exclusively or not, for use in play by children under 14 years of age. The directive covers physical and mechanical safety, flammability, chemical safety, electrical safety, hygiene, and radioactivity.

The directive requires toys to not jeopardize health or safety when used as intended or in a foreseeable way, bearing in mind the behavior of children. Importantly, risks from toy use must be assessed considering children's abilities—the younger the intended user, the stricter the requirements.

If applicable

Requirements for scented toys and olfactory games

Fragrance allergen limitsScent capsule requirementsLabeling requirementsAge appropriate scents

EN 71-14

Trampolines for Domestic Use

Toys have strict chemical restrictions to protect children from exposure to toxic substances. Requirements come from EN 71-3 (heavy metals), EN 71-9 (organic compounds), REACH restrictions, and the Toy Safety Directive itself. Testing is essential for painted surfaces, plastics, textiles, and any mouthable components.

Substance	Limit	Common Source	Regulation
Lead (Pb)	2.0 mg/kg (Cat I), 0.5 mg/kg (Cat II), 23 mg/kg (Cat III)	Paint, solder, PVC stabilizers	EN 71-3
Cadmium (Cd)	1.3 mg/kg (Cat I), 0.3 mg/kg (Cat II), 17 mg/kg (Cat III)	Pigments, plating, batteries	EN 71-3
DEHP, DBP, BBP	Prohibited (0.1% combined)	Plasticized PVC	REACH Annex XVII Entry 51
DINP, DIDP, DNOP	0.1% combined in mouthable toys	Plasticized PVC in mouthable parts	REACH Annex XVII Entry 52
N-Nitrosamines	0.05 mg/kg migration	Rubber, elastomers	EN 71-12
Chromium VI (Cr6+)	0.02 mg/kg (Cat I/II), 0.2 mg/kg (Cat III)	Leather, textiles, coatings	EN 71-3
CMR Substances	Generally prohibited (specific exemptions)	Various	Toy Safety Directive Annex II
Fragrance Allergens	55 prohibited, 11 require labeling	Scented toys, slimes	Toy Safety Directive

Required Warnings and Labels

Warnings must be visible before purchase—typically on packaging. They must be preceded by the word "Warning" or a warning symbol. Age grading is always required and must be appropriate for the toy's actual hazards.

Not suitable for children under 36 months

When required: Toys with small parts for 3-14 age group

Symbol: Age 0-3 prohibition symbol

Format: Visible on packaging before purchase

Warning: Only for use in water shallow enough for child to stand

When required: Aquatic toys (inflatables, pool toys)

Symbol: Required

Format: Indelible marking on toy + packaging

Warning: Use under adult supervision

When required: Functional toys, projectile toys, activity toys

Symbol: Not required but recommended

Format: Instructions and packaging

Warning: Not suitable for children under [X] years

When required: Toys with specific age-related hazards

Symbol: Age restriction symbol

Format: Visible before purchase

Maximum user weight: [X] kg

When required: Ride-on toys, activity toys

Symbol: Not required

Format: Product and instructions

Warning: Contains small magnets/ball

When required: Toys with swallowable magnets

Symbol: Required for high-flux magnets

Format: Packaging and instructions

7-Step Toy Compliance Process

Define Product Scope

Confirm your product is a toy (intended for play by children under 14) and identify the intended age group.

Verify product meets toy definition
Determine intended age range
Document age grading rationale
Identify all applicable hazards for age group

Conduct Risk Assessment

Assess all foreseeable risks considering intended use and reasonably foreseeable misuse by children.

List all potential hazards
Consider developmental abilities of target age
Assess misuse scenarios
Document risk mitigation measures

Design for Safety

Ensure toy design eliminates or minimizes risks through inherent safety measures.

Eliminate small parts where possible
Use safe materials and construction
Design age-appropriate features
Include necessary warnings/instructions

Arrange EN 71 Testing

Have your toy tested by an accredited laboratory against applicable EN 71 parts.

EN 71-1 mechanical and physical testing
EN 71-2 flammability testing
EN 71-3 heavy metals migration
Additional tests based on toy type

Compile Technical File

Create comprehensive technical documentation demonstrating compliance.

Product description and design drawings
Risk assessment documentation
Test reports from accredited lab
Manufacturing and QC procedures

Create Declaration of Conformity

Draft the EU Declaration of Conformity referencing the Toy Safety Directive.

Reference Directive 2009/48/EC
List applied harmonized standards
Include manufacturer identification
Sign by authorized person

Apply CE Marking and Warnings

Affix CE mark, age grading, and all required warnings before placing on market.

CE mark on product or packaging
Age grading clearly displayed
Required warnings visible before purchase
Instructions in local language

Technical File Requirements

The technical file must demonstrate compliance with all applicable requirements. Keep documentation for 10 years after the last toy is placed on the market.

Technical Documentation

Product description and design drawings
Bill of materials with material specifications
Risk assessment covering all hazards
Safety assessment for chemicals
Age grading justification
EN 71 test reports (parts 1, 2, 3 minimum)
Additional tests for product type
Manufacturing quality control procedures

Declaration of Conformity

Manufacturer name and address
Product identification (name, model, batch)
Reference to Directive 2009/48/EC
List of applied EN 71 standards
Any other applied standards
Statement of sole responsibility
Signature of authorized person
Place and date of issue

Frequently Asked Questions

Related Guides

CE Marking Complete Guide

Understand the full CE marking process for toys and other products.

Amazon EU Compliance Guide

How to upload toy compliance documents and meet Amazon requirements.

Selling toys in the EU market?

Use SellSafe to analyze your toys against EN 71 requirements and get a clear compliance roadmap including testing, documentation, and warning requirements.

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