On August 1, 2030, the new EU Toy Safety Regulation will come into full force, replacing the previous Directive 2009/48/EC. With the regulation, the strict safety rules will apply directly and uniformly in all EU member states in the future. For manufacturers, importers, and distributors, this means a considerable need for adaptation in terms of products and digital processes.
The three central pillars of the new regulation
1. Radical tightening of chemical safety
The EU is introducing a generic ban on entire classes of substances. Substances classified as CMR, endocrine disruptors, or respiratory sensitisers will be banned across the board in future. There are also specific bans on PFAS and an extended list of bisphenols. Another new feature is the obligation for manufacturers to take cumulative effects (the so-called mix effect) of different chemicals into account in their safety assessments.
2. Introduction of the Digital Product Passport (DPP)
The classic paper-based declaration of conformity will be replaced by the DPP. In future, every toy must have a data carrier (e.g., QR code) that is directly linked to a central EU register. Without this digital passport, importing goods across the EU’s external borders will be virtually impossible, as customs systems and registers are automatically synchronized.
3. Extended liability in the supply chain
Due diligence obligations are being clarified:
- Importers must check the existence of the DPP in advance.
- Online marketplaces will be more liable for non-compliant offers (“illegal content”).
- Fulfillment service providers are explicitly required to maintain compliance during storage and shipping.
Timetable and transition periods
Although full implementation will not take place until August 2030, administrative aspects (e.g., notifications) have already been in effect since January 1, 2026. In view of long development cycles and complex supply chains, proactive portfolio conversion is advisable with immediate effect.
Call to action: Set the course now!
Economic operators should immediately begin taking stock of their chemical profiles and planning their digital DPP infrastructure. Contracts with suppliers must be adapted to ensure the necessary data transparency for the product passport.
reuschlaw provides support for the legally compliant implementation of the new requirements:
- Strategic consulting on chemical compliance and safety assessment.
- Legal support for the implementation of the digital product passport.
- Adaptation of supplier contracts and liability regimes along the supply chain.
Would you like to have a specific gap analysis carried out for your current product range? Contact us for an initial consultation.
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