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Expandly Blog

EU Adopts New Toy Safety Regulation: What Brands Must Do Now

Regulation (EU) 2025/2509 replaces toy safety rules that have governed EU market access since 2009. GPSR obligations that affect toys are already in force.

In This Article

01 What the new TSR 2025/2509 changes
02 GPSR: the compliance layer already in force
03 EN71 testing: the non-negotiable pre-condition
04 Digital product passports: what to plan for
05 EPR and France's toys registration requirement

Key Takeaways

► GPSR is in force now. Every toy ASIN needs a Responsible Person.
► EN71 testing must happen before Declaration of Conformity is issued
► Amazon enforces GPSR per-ASIN. Non-compliant listings get removed.
► Digital product passports for toys required from 2030

The EU adopted a new toy safety regulation in December 2025, replacing the framework that had governed EU market access for toys since 2009. For US brands selling toys or children's products in Europe, the broader regulation applies from August 2030, but the General Product Safety Regulation (GPSR) that underpins much of modern product compliance has been in force since December 2024. Both need to be understood before products enter EU distribution.

Dec 2024 Date GPSR came into force across the EU, requiring all non-EU brands to appoint a named Responsible Person for products sold on the EU market. Source: European Commission, 2024.

Regulation (EU) 2025/2509, which entered into force on January 1, 2026, is a complete replacement for Toy Directive 2009/48/EC. The major changes affect three areas. First, chemical safety requirements are significantly tighter, now covering CMR (Carcinogenic, Mutagenic or Reprotoxic) substances and endocrine disruptors that were not explicitly banned under the previous directive. Second, manufacturers must produce digital product passports for all toys placed on the EU market. Third, and most significant for ecommerce operators, online marketplace providers are explicitly named as having compliance obligations for the first time. Platforms must ensure toys sold through their services meet requirements and must cooperate with authorities to remove non-compliant products.

For US brands, the more immediate issue is GPSR compliance, which has applied across all product categories since December 13, 2024. GPSR requires non-EU sellers to appoint a named Responsible Person in the EU. For toys specifically, that person must hold EN71 test certification, an active Declaration of Conformity, and current technical documentation. Amazon enforces GPSR compliance per-ASIN in Seller Central's Manage Your Compliance dashboard. Listings without a compliant Responsible Person declared are removed.

  • GPSR (in force since December 2024): requires a named EU Responsible Person, Declaration of Conformity, risk assessment, and compliant product labeling for every toy ASIN.
  • EN71 testing must be completed before a Declaration of Conformity can be issued. This is a non-negotiable pre-condition for EU toy market access.
  • Regulation (EU) 2025/2509: digital product passports required for toys from 2030. Brands building product documentation infrastructure now should plan for this requirement.
  • France has EPR obligations for toys requiring separate registration. Lead time is approximately 4 weeks.

Expandly handles Responsible Person, label compliance, and CE marking for toys brands as part of EU onboarding, so documentation is in order before the first product listing goes live.

Expandly helps US ecommerce brands expand into Europe — compliance, marketplaces and fulfilment, all handled. We’ve supported 2,000+ brands make the move.

  • EPR compliance managed from day one — packaging, WEEE, batteries and beyond
  • Product label review and Responsible Person service for EU and UK market entry

The bigger picture

EU toy safety compliance what toys brands need before launch

The new EU toy safety regulation raises the bar on chemical safety, documentation, and marketplace accountability across the board. For US toys brands entering Europe, the compliance sequence begins long before products reach a warehouse. EN71 testing, label review, and Responsible Person approval must all be completed before a single listing goes live on Amazon.de or Amazon.fr. Expandly's compliance-first onboarding manages the full documentation chain for toys brands, starting with label review and EN71 verification before moving to Responsible Person registration. Brands that follow this sequence avoid the account restrictions and listing removals that come from skipping steps.

  • EN71 testing required before Declaration of Conformity can be issued for any toy sold in the EU
  • Responsible Person approval takes 2 to 3 weeks once full documentation is submitted via the Expandly portal
  • France EPR toys registration: approximately 4 weeks lead time. Required separately from VAT and RP setup.

EU Children's Products Market

The EU is one of the world's largest markets for children's toys and products. For US brands with successful domestic toy lines, European expansion brings direct access to high-spending consumer markets across the UK, Germany, France, and the Netherlands.

27

EU member states where Regulation (EU) 2025/2509 will apply from 2030

GPSR and Responsible Person

Every non-EU brand selling toys in the EU must have a named Responsible Person. For toys, this requires EN71 test certification before the Declaration of Conformity can be issued. No RP approval is possible without completing the label review first.

2–3 weeks

Responsible Person approval timeline once full documentation is submitted (Expandly knowledgebase)

Compliance-First Onboarding

Product compliance and VAT setup run in parallel from day one. From there, VAT registration, marketplace setup and EU-local fulfilment follow in the right order.

2,000+

brands expanded with Expandly

If this sounds like your world,
let's talk.

Expandly helps US ecommerce brands expand into Europe — compliance, marketplaces and fulfilment, all handled.

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