Requirements check
Toy
The forChildren attribute is inherent to this category, so it adds nothing. Electric/electronic toys must operate at 24 V or below in the EU/UK (EN 62115); a mains adapter is a separate LVD product — the LVD entries under 'mains' refer to that power supply. Battery-operated toys are EEE, which is why the battery attribute also pulls in EMC/RoHS/WEEE; toys with only simple motors may be outside FCC Part 15 — verify. US: ASTM F963 is mandatory (16 CFR 1250), plus third-party testing at a CPSC-accepted lab, a Children's Product Certificate and permanent tracking labels under CPSIA. Connected toys are squarely within UK PSTI scope, and the EU CRA will apply from December 2027. Toys that contain button cells must meet EN 62115 / ASTM F963 battery-compartment requirements. Chemical limits: EU Toy Safety Directive Annex II plus REACH; a new EU Toy Safety Regulation replacing Directive 2009/48/EC is progressing through the legislative process — verify its adoption status.
European Union4 instruments
The EU's baseline safety law for consumer products, applicable since 13 December 2024. It replaces the General Product Safety Directive and adds duties around traceability, online selling, recalls and having a responsible economic operator in the EU.
Key obligations
- 01Only place safe products on the market. Safety is assessed against the product's characteristics, packaging, instructions, the consumers who will use it, its appearance (food-imitating products) and, where relevant, cybersecurity features.source
- 02A product may only be placed on the EU market if there is a responsible economic operator established in the EU — an EU manufacturer, importer, authorised representative or fulfilment service provider (Article 16).source
- 03Carry out an internal risk analysis and draw up technical documentation; keep product identification and traceability information available (manufacturers, importers and distributors each have tiered duties).source
- 04Report accidents caused by your products and notify dangerous products to the authorities through the Safety Business Gateway.source
The EU's enforcement framework for product rules. Its Article 4 is the practical blocker for online sellers: since 16 July 2021, most CE-marked goods can only be placed on the EU market if an economic operator established in the EU is responsible for compliance tasks — and that operator's contact details must accompany the product.
Key obligations
- 01A product covered by the Article 4 list may only be placed on the EU market if there is an economic operator established in the Union responsible for the Article 4 tasks (applies since 16 July 2021).source
- 02That operator can be: the manufacturer established in the EU; an importer (where the manufacturer is not established in the EU); an authorised representative with a written mandate; or an EU-established fulfilment service provider handling the products (Article 4(2)).source
- 03The operator's tasks (Article 4(3)): verify that the EU Declaration of Conformity and technical documentation exist and keep the DoC available; provide information and documentation to authorities on request; inform authorities when a product presents a risk; cooperate on corrective action.source
- 04The name, registered trade name or trade mark and contact details (including postal address) of the Article 4 operator must be indicated on the product or on its packaging, the parcel or an accompanying document (Article 4(4)).source
The EU's chemicals regulation. For physical-product (article) sellers the practical duties are: communicating Candidate List substances of very high concern (SVHCs) above 0.1% down the supply chain and to consumers, notifying ECHA in some cases, and respecting the Annex XVII restrictions. Full chemical registration applies to substance manufacturers/importers, not typical article sellers.
Key obligations
- 01Article 33(1): if an article contains a Candidate List SVHC above 0.1% weight by weight, provide recipients (businesses in the supply chain) with sufficient information for safe use — at minimum the name of that substance. This applies per article within a complex product.source
- 02Article 33(2): on request from a consumer, provide the same safe-use information (at minimum the substance name) within 45 days, free of charge.source
- 03Article 7(2): EU producers/importers of articles must notify ECHA when a Candidate List substance is present above 0.1% w/w AND its total quantity in those articles exceeds 1 tonne per producer/importer per year — no later than 6 months after the substance is added to the Candidate List. Notification is not required where exposure of humans and the environment can be excluded.source
- 04Notify articles containing Candidate List SVHCs above 0.1% w/w to ECHA's SCIP database (a duty under the Waste Framework Directive, submitted via ECHA).sourceUnverified — check source
The CE framework for toys — products designed or intended for use in play by children under 14. It sets mechanical, flammability, chemical, electrical and hygiene requirements. A new Toy Safety Regulation (EU) 2025/2509 has been adopted and will replace this directive from 1 August 2030.
Key obligations
- 01Before placing a toy on the market, carry out a safety assessment including an analysis of the chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazards and of potential exposure to them (Article 18).source
- 02Ensure the toy meets the essential safety requirements of Annex II (including the chemical requirements, e.g. CMR substance rules and element migration limits), draw up technical documentation and keep it for 10 years (Article 4).source
- 03Perform the applicable conformity assessment (Article 19), draw up the EC Declaration of Conformity and affix the CE marking (Article 17).source
- 04Affix the required warnings exactly as worded in Annex V (e.g. minimum-age warnings, choking-hazard warnings for small parts) where applicable, visibly and legibly; a warning must not conflict with the toy's intended use (Article 11).source
Documents you will need
Deduplicated across everything above
- Technical documentationBased on an internal risk analysis; must describe the product and its safety-relevant characteristics. No EU Declaration of Conformity is required under the GPSR itself.source
- Traceability informationProduct identification (type/batch/serial) plus manufacturer and EU responsible operator contact details must accompany the product.source
- Written mandate (when using an authorised representative)The authorised representative must hold a written mandate covering the Article 4 tasks.source
- EU Declaration of Conformity + technical documentation availabilityThe EU operator must be able to verify these exist and produce them for authorities on request.source
- Supplier declarations / full material disclosuresEvidence that Candidate List SVHCs are below 0.1% w/w per article, or the basis of your Article 33 communications.source
- Article 33 safe-use communicationsRecords of the information passed to recipients and provided to consumers within the 45-day deadline.source
- EC Declaration of ConformityKept for 10 years after the toy is placed on the market.source
- Technical documentation including the safety assessmentHazard analysis per Article 18, design and test information; kept 10 years.source
- Instructions and warningsAnnex V warnings as worded, in the language(s) required by the Member State of sale.source
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