What EU and US toy rules ask of you, and what changed this year
The EU Toy Safety Regulation, PPWR packaging duties, CPSIA certificates and the new CPSC electronic filing rule — what applies now, what is coming, and who carries the legal duty.
Compliance is the part of a toy order that most often surprises a first-time importer, because the legal duty does not sit with the factory. It sits with the importer or the economic operator placing the goods on the market. Here is what is in force right now on both sides, and what is about to change.
European Union
Today. Toys placed on the EU market are covered by the Toy Safety Directive 2009/48/EC, with the EN 71 series as the harmonised standards behind it and CE marking as the visible result. That route still works.
What changed. The new Toy Safety Regulation (EU) 2025/2509 was published in the Official Journal on 12 December 2025 and entered into force on 1 January 2026. It replaces the Directive, but it applies in full only from 1 August 2030 — a 54-month transition. Until that date, toys complying with the existing Directive may still be placed on the market.
The three changes worth planning for now, even though they land later:
- Chemical restrictions are widened and reorganised, so a formulation that passes today may need re-testing.
- A Digital Product Passport replaces the paper trail, which means product data has to be structured and kept, not just filed once.
- Digital and connected toys get their own assessment route, which matters if a toy will pair with an app.
Packaging, from 12 August 2026. Packaging is a separate regime. Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), applies from 12 August 2026 and requires packaging to be recyclable, minimally wasteful and clearly labelled, with a conformity assessment behind it. Alongside it, extended producer responsibility means an EPR registration number in each EU country where the goods are sold. If you sell through a marketplace, that marketplace will usually ask you for the EPR number before it lets the listing go live.
United States
Children's products fall under CPSIA. In practice that means:
- Testing at a CPSC-accepted third-party laboratory for each applicable rule — typically lead, phthalates and ASTM F963 for toys.
- A Children's Product Certificate (CPC) issued by the manufacturer or the importer, based on those test results. A CPC is not issued by the lab; it is issued by the responsible party.
- A tracking label on the product and its packaging.
What changed. From 8 July 2026, importers of most regulated consumer products have to file certificates of compliance electronically with the CPSC — the eFiling requirement. If you are the importer, this is a step you now own at entry, not paperwork you can file afterwards.
Who is responsible for what
This is the part worth being blunt about. We are the manufacturer. We can give you test reports, material declarations and the technical file you need to build your own compliance file, and we can produce to the standard your market requires. The legal declaration, the CPC in the US and the CE document in the EU, is made by the importer or the brand placing the goods on the market. That is the structure of both regimes, not a choice either of us makes.
What to tell us at enquiry stage
- The destination market, country by country if you sell in more than one.
- The age grading you intend to sell under.
- Whether the item goes in the mouth or the bath, because that changes which chemical and phthalate rules apply.
- Whether you already have a test report we can work to, or need a fresh one.
Tell us that up front and the compliance documents can be planned alongside the order rather than chasing it afterwards. Start an enquiry.
Where to check the current position
Both regulators publish the rules directly, and they are the only sources worth relying on for a compliance decision:
- European Commission, toy safety: single-market-economy.ec.europa.eu/sectors/toys
- US Consumer Product Safety Commission, Children's Product Certificate: cpsc.gov
This article is a planning summary, not legal advice. Requirements change and the duty sits with the importer, so confirm the current position for your market and your product before you commit to an order.