The new toy directive EU/2025/2509
From Toy Safety Directive 2009/48/EC to Toy Safety Regulation EU/2025/2509
Europe’s rules on toys are getting a shake-up. The 2009 Toy Directive is giving way to a new EU regulation. In this blog, we explain what the new toy directive means in practice for online sales, product pages and your compliance process.
For entrepreneurs, the new toy directive means that product compliance is becoming less “something of the manufacturer” and more and more a part of your own sales process. Especially if you work with marketplaces, dropshipping, private label or suppliers outside the EU.
Why new legislation?
Toys are a product category in which safety problems are relatively common. At the same time, the market has changed significantly in recent years. Consumers are more often buying directly online from providers outside the EU, the number of platform providers has grown, and dropshipping has made the chain more complicated.
This creates two challenges. First, it becomes more difficult for regulators to quickly see who is responsible and whether a product is truly compliant. Second, web shops and marketplaces are playing a bigger role in what eventually reaches consumers. The new toy directive aims to enable faster monitoring, better enforcement and earlier removal of unsafe products from the chain.
Difference between old and new legislation
From directive to regulation
The old rules were a directive. Member states had to translate them into national legislation, which meant interpretations and enforcement could differ. The new rules are a regulation and therefore apply directly in all EU countries. That gives more uniformity and fewer gray areas, but also less room for “this is how we always do it here.”
In practice, this means that the new Toy Directive leaves less room for interpretation and puts more emphasis on demonstrability. This is relevant for entrepreneurs, as platforms and regulators will more often apply the same requirements regardless of where you sell within the EU.
Digital Product Passport becomes the new standard
The biggest change in the new Toy Safety Directive is the introduction of the Digital Product Passport. In practice, this is usually accessed via a QR code or similar digital data carrier on the product, packaging or associated documentation.
The goal is for important product information to be digitally accessible to consumers, regulators and customs. Think identification, traceability and relevant safety information. This will make it easier to check more quickly whether a product is correct and to act more quickly if a risk is discovered.
Important to understand: the Digital Product Passport is not the same as your complete technical dossier. Your technical file remains the substantiation by which you demonstrate that your product complies. The passport is the digital access to core information and product identification so that inspections can be faster and more consistent.
Online sales are more explicitly included
The new toy directive puts more emphasis on online sales and information that must be available before purchase. Think CE information, safety warnings and access to the Digital Product Passport.
For business owners, this means that compliance is not just about what’s on the product or packaging, but also about what’s on your product page. If you offer the same products on multiple channels, that information must also be consistent throughout.
Stricter chemical requirements
The new Toy Safety Directive tightens chemical requirements and expands attention to substance groups that may pose additional risks to children. These include PFAS, endocrine disruptors, skin sensitizers and certain bisphenols.
Fragrances will also be approached more strictly. Allergenic fragrances will be banned in toys for children under 3 and in toys intended to be placed in the mouth.
Greater emphasis on demonstrability and traceability
The common thread in the new toy directive is demonstrability. You have to be able to show faster that a product is safe, and a product has to be more traceable in the chain. That requires tighter product identification, version control and documentation that you can deliver immediately upon request.
For web shops with many variants, bundles or private label assortment management, this is a major concern. Small differences in material, age indication or warning can suddenly make all the difference in what information you need to show and what substantiation you need.
Wanneer gaat de nieuwe speelgoedrichtlijn in?
The new rules took effect Jan. 1, 2026. Most obligations will apply from Aug. 1, 2030. That means there is a transition period, but for business owners, it makes sense to start earlier. If you rely on supplier data, test cycles, labeling and listing processes, it almost always takes more time than you think.
Think of this as a time to get your basics in order: who provides what documentation, how do you manage variants, and how do you make sure product information on your site and on marketplaces is correct and up to date.
FAQ for entrepreneurs
I sell toys through my own webshop. What will change for me?
The new toy directive makes it more important that your product information online is complete and correct. Your product pages need to show the correct warnings and mandatory information, and you need to better manage the data behind your assortment. When questions come from a regulator, payment provider or platform, you want to be able to show immediately that your product is compliant.
I sell through marketplaces like Amazon or bol. Will this become stricter?
Yes. Marketplaces already pay close attention to documentation and product safety, and the new toy directive reinforces that trend. Expect more questions, stricter checks and less tolerance for incomplete listings. If your account depends on platform compliance, it’s smart to get your documentation and product data in order sooner than later.
I do dropshipping. Who is responsible for compliance?
It depends on your role in the chain, but in practice dropshipping is often a risk form because responsibilities quickly become unclear. If you sell to consumers in the EU, you usually get questions about product safety and proof anyway. Dropshipping only works well if you know exactly who the manufacturer and responsible party is, and if you can actually request and keep the proper documentation.
I am purchasing from a supplier outside the EU. What is my biggest risk?
The biggest risk is that your supplier may say “CE,” but can’t provide substantiation that will stand up to scrutiny or platform review. You want advance assurance of test results, documentation and traceability. Without that, you run the risk of roadblocks, recalls or claims, and in practice, long-term listing issues.
Will I soon have to have my own DPP for each product variant?
Variants and bundles are often underestimated. If a variant has different materials, different age indications or different warnings, you need to be able to distinguish that in your data and documentation. The digital passport is all about identification and correct information per product. So make sure your variant management is set up accordingly.
Does this include used, refurbished or outlet toys?
If you offer toys on the market as “new,” the rules apply most clearly. In second-hand, it depends on your role and how you offer it. In online sales, it is wise to be very keen on completeness of warnings, packaging and traceability in outlet and returns, as that is often the weak spot in practice.
What should I arrange now if I want to do this “later”?
The bottleneck is usually not in making a QR code, but in product data, documentation and processes. If you start now to properly organize supplier agreements, variant management and your documentation structure, the step to the digital passport will soon be much smaller.
Conclusion
The new EU toy regulation makes compliance more digital, more stringent and more enforceable. The Digital Product Passport becomes a central link in how product information is verified, especially for online sales. For entrepreneurs, this means that compliance is no longer something that “lies somewhere with the supplier,” but part of your own operation, from procurement to product page.
Those who start now with structure in product data, documentation and traceability will avoid hassles later with marketplaces, regulators and recalls.
Want to know what these new rules mean for your assortment and sales channels, and how to set this up smartly without your team drowning in documentation?
Instrux helps you with scope check, supplier briefing, risk analysis, documentation setup and making your processes DPP ready. Schedule a no-obligation intake and find out where you can gain the most towards 2030.