Safety First What the New EU Toy Safety Regulation Means for UK and Irish Businesses
What You Really Need to Know
Introduction
On 13 October 2025, the Council of the EU approved its position on a new Toy Safety Regulation that will replace Directive 2009/48/EC. The Regulation tightens chemical controls, introduces a mandatory Digital Product Passport (DPP) and strengthens enforcement to keep unsafe toys out of the EU market. Final entry into force still requires European Parliament endorsement. Consilium
Once published in the Official Journal, the Regulation will enter into force after 20 days. Most obligations will fully apply after a transition period of about 4.5 years (54 months), giving businesses time to adapt systems and documentation. European Parliament
A Shift from Directive to Regulation
Unlike a Directive (transposed nationally), a Regulation applies directly and uniformly across all Member States, eliminating national variations and supporting consistent enforcement. Consilium
The Key Changes Chemicals and Digital Passports
1) Stricter chemical controls. Beyond existing bans on CMRs, the text targets endocrine disruptors, PFAS (intended use ban), the most dangerous bisphenols, substances harmful to the respiratory system and skin, and allergenic fragrances (prohibited in toys for children under 36 months and toys meant to be placed in the mouth). Expect more agile updates via delegated acts as science evolves. European Parliament
2) Digital Product Passport (DPP). Each toy will carry a scannable, digital record (e.g., QR code) giving authorities and consumers quick access to compliance data (materials/chemicals, warnings, standards, manufacturer/AR details). The DPP becomes the primary compliance artefact and contains the DoC information, improving traceability and border checks. European Parliament+1
3) Economic operators & online marketplaces. Duties for manufacturers, importers, distributors and fulfilment service providers are clarified. Marketplaces must enable display of CE, warnings, and a link/QR to the DPP before purchase to help regulators and consumers verify compliance. European Parliament
Navigating the UK & Ireland Landscape
- Ireland / EU: When the Regulation applies, toys placed on the Irish/EU market will require CE marking and a DPP. Consilium
- Great Britain: The EU Regulation will not apply in GB; GB uses UKCA rules under OPSS (note the UK’s ongoing recognition of CE in many cases, but UKCA remains the GB framework). GOV.UK
Northern Ireland: EU product rules continue to apply. Use CE; if a UK conformity assessment body is used, apply UKNI alongside CE. GOV.UK+1
What HSEQ & Quality Teams Should Do Now
- Regulatory roadmap: Map the 54-month transition and identify which obligations/IT changes (e.g., DPP data model, QR code deployment) you’ll phase in first. European Parliament
- Chemical compliance: Re-screen bills of materials for new bans/restrictions (PFAS, bisphenols, allergens), update supplier declarations and testing plans. European Parliament
- DPP readiness: Decide where your DPP will be hosted, how you’ll maintain data integrity, and how consumers/authorities will access it on-pack. European Parliament+1
- Online sales controls: Ensure CE, warnings and DPP link are visible pre-purchase on your listings and marketplace storefronts.
Navigating the complexities of the new EU Toy Safety Regulation requires expertise in regulatory compliance and quality management. AcornStar provides comprehensive HSEQ Consultancy Services and training courses to help businesses in the UK and Ireland meet their obligations. Contact us today to ensure your products are safe, compliant, and ready for the market.
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