For orders placed in 2026, most EU toy-safety requirements still come from Directive 2009/48/EC — not from the new Regulation (EU) 2025/2509 in full. Regulation (EU) 2025/2509 was published in the Official Journal on 12 December 2025 and entered into force on 1 January 2026, but its main application date is 1 August 2030. Only Articles 28 to 44 and Articles 49 to 55 apply from 1 January 2026.
That single split decides your paperwork for the 2026 buying season. Toys that comply with the Toy Safety Directive can still be placed on the EU market before 1 August 2030, and EC type-examination certificates issued under the directive remain valid until 1 February 2031. The practical task is not 'comply with the new regulation now' — it is knowing which obligations already bite, which ones wait until 2030, and what to put in writing with your factory this year.
Key takeaways for 2026 EU toy orders
- Regulation (EU) 2025/2509 entered into force on 1 January 2026 — the twentieth day after its 12 December 2025 OJ publication — but that is not the date most product requirements start applying.
- The main application date is 1 August 2030. Between now and then, Directive 2009/48/EC remains relevant for most toy-safety requirements, and the directive is repealed from 1 August 2030.
- Articles 28 to 44 and Articles 49 to 55 apply from 1 January 2026, even though the bulk of the regulation waits until 2030. Buyers should ask suppliers which of these early articles touch their product documentation and online listings.
- EC type-examination certificates issued under the old directive stay valid until 1 February 2031 — so a 2026 order is not automatically invalidated by the new regulation.
- The Digital Product Passport is part of the 2025/2509 regime and is not the same obligation as GPSR. Its technical specifications were still being developed through delegated acts, so do not treat it as a confirmed 2026 deadline.
What changed on 1 January 2026 — and what did not
1 January 2026 is the entry-into-force date of Regulation (EU) 2025/2509, not the date the whole regulation starts to apply. Under the standard EU twentieth-day rule, a regulation published in the Official Journal on 12 December 2025 enters into force on 1 January 2026. Entry into force means the legal instrument exists and is binding as law; it does not mean every article is enforceable against every toy.
Two article groups are the exception. Articles 28 to 44 and Articles 49 to 55 apply from 1 January 2026, while the majority of the regulation's requirements apply from 1 August 2030. The practical consequence for a buyer is that a 2026 purchase order sits inside a transitional regime: the regulation is in force, but for most product-safety requirements the old directive framework still governs what can be placed on the market.
Be careful with secondary sources here. Testing-lab bulletins and law-firm summaries often carry the year in the headline, and that year is not a legislative application date. Where the official text does not confirm a date for a specific obligation, the honest position is that the timeline is not confirmed from official text — not that the requirement is mandatory from a given day.
How the EU's dual timeline works for toys
The mechanism is a phased replacement of a directive by a regulation. Directive 2009/48/EC, the Toy Safety Directive, is repealed from 1 August 2030. From that date, Regulation (EU) 2025/2509 becomes the operative framework and, because it is a regulation rather than a directive, it applies directly across the EEA without national transposition.
Three dates carry most of the weight for planning. 1 January 2026: entry into force, plus early application of Articles 28–44 and 49–55. 1 August 2030: main application date and repeal of the directive. 1 February 2031: the outer validity of EC type-examination certificates issued under the directive. A fourth date matters to anyone holding old test reports — the revised EN 71-1 and EN 71-8 standards published in early 2026 are reported to replace the current versions in July 2027, which affects the standard you cite in a purchase specification even before the regulation's main application date.
The regulation's scope covers toys intended for children under 14, and the changes it introduces — chemical restrictions, connected-toy duties, a Digital Product Passport, updated warnings — are the reason buyers are being asked to plan years ahead. None of that changes the fact that 2026 orders are largely governed by the existing directive for product requirements.
Regulation (EU) 2025/2509 dates: what each one actually triggers
| 12 December 2025 | Publication in the Official Journal. Not an application date — it starts the twentieth-day clock. |
|---|---|
| 1 January 2026 | Entry into force of Regulation (EU) 2025/2509. Articles 28–44 and Articles 49–55 also apply from this date. |
| 1 August 2028 | Member State penalty frameworks reported as due by this date. |
| 1 August 2030 | Main application date of the regulation; Directive 2009/48/EC is repealed from this date. |
| 1 February 2031 | EC type-examination certificates issued under the Toy Safety Directive remain valid until this date. |
| Not confirmed from official text | The application dates of individual obligations not listed in Articles 28–44 and 49–55, and the Digital Product Passport technical specifications, which were being developed through delegated acts. |
Which regime applies to an order placed in 2026?
For most product-safety requirements, an order placed in 2026 is still assessed against Directive 2009/48/EC, because the new regulation's main application date is 1 August 2030 and toys complying with the directive can be placed on the EU market before then. The regulation is in force, but it is not the operative standard for the full product scope yet.
The exception is the early-applicable articles. Articles 28 to 44 and 49 to 55 already apply from 1 January 2026. The source material for this article does not enumerate what each of those articles covers, so the correct action is to read the official text and map those article numbers against your own documentation and listing obligations rather than assume a list. If a supplier or agent tells you 'everything applies from January 2026', that statement is not supported by the regulation's own application dates.
One more boundary to hold: the Digital Product Passport sits inside the 2025/2509 regime. GPSR is a separate regime with its own obligations, and the Toy Safety Directive is a third. Do not let anyone collapse them into a single deadline.
What to put in writing with your supplier this quarter
Ask three questions and keep the answers on file. First: which EC type-examination certificates does this product rely on, who issued them, and what is their scope and validity? Certificates issued under the directive remain valid until 1 February 2031, so an early expiry or a scope that does not match the actual product is a real risk — not a technicality.
Second: is the factory already tracking the chemical provisions that arrive with the 2030 application date? PFAS, bisphenols and N-nitrosamine limits are the items most likely to force a reformulation, and reformulation lead times are measured in seasons, not weeks. You do not need a 2026 certificate for them if the main application date is 2030 — but you do need to know whether your supplier has started, because a supplier that has not begun by mid-2026 is a supplier you may not be able to reorder from in 2029.
Third: how will documentation and any QR-accessible product data be handled, and who maintains it? The Digital Product Passport's technical specifications were still being developed through delegated acts, so the honest answer from a supplier may be 'not yet defined'. Accept that answer, but put a review date in the contract. And confirm who the EU-based responsible economic operator is for online sales — that is a documentation question you can settle now, whatever the 2030 timeline does.
Cost and lead-time risk you should budget for
Compliance costs for the new regime are frequently described in the 30–100% range for affected products, driven mainly by chemical substitution, additional testing and documentation infrastructure. Treat that as a planning band, not a quote: it is a potential impact reported by compliance sources, not a guaranteed figure, and it lands unevenly depending on material mix and whether the product is a connected toy.
The asymmetric risk is timing, not price. Lab capacity tightens as a deadline approaches, and 2030 is close enough that a 2027 or 2028 reformulation decision has less slack than it looks. Buyers who wait for the first enforcement signals will be competing for the same test slots as everyone else.
For connected, radio-enabled or AI-using toys, add privacy, cybersecurity and AI Act obligations to the contract review — those are product-specific and cannot be assumed to be covered by a general toy test report.
FAQ: EU toy compliance for 2026 orders
Does Regulation (EU) 2025/2509 apply to my 2026 toy order?
Only partly. The regulation entered into force on 1 January 2026 and Articles 28–44 and 49–55 apply from that date, but its main application date is 1 August 2030. For most product-safety requirements, a 2026 order is still governed by Directive 2009/48/EC, and toys complying with the directive can be placed on the EU market before 1 August 2030.
Are EC type-examination certificates issued under the old directive still valid?
Yes, until 1 February 2031. Certificates issued under the Toy Safety Directive remain valid until that date, so a 2026 purchase is not invalidated by the new regulation. Confirm the certificate's scope matches the actual product and check its own expiry date, which may fall earlier.
Do I need a Digital Product Passport for toys shipped in 2026?
No confirmed 2026 requirement. The Digital Product Passport is part of the 2025/2509 regime, distinct from GPSR, and its technical specifications were being developed through delegated acts. Treat any claim of a 2026 DPP deadline as unconfirmed unless it cites the official text.
When do the new chemical limits for PFAS, bisphenols and N-nitrosamines start to bind?
They are tied to the regulation's main application date of 1 August 2030, unless a specific early-applicable article covers them. That gives suppliers a reformulation window, but the lead time is long — ask now whether your factory has begun material substitution, because a supplier that has not started by 2027 may not be able to supply you in 2029.
Which standard should our purchase order cite for testing?
Cite the EN 71 version your test report actually references. Revised EN 71-1 and EN 71-8 standards published in early 2026 are reported to replace the current versions in July 2027, so a specification written today may need updating within a year or two. ASTM F963 and Toy requirements are a separate US route and do not satisfy EU obligations.
What should I ask a new supplier before placing a 2026 EU order?
Ask which EC type-examination certificates the product relies on and their scope and validity; whether the factory has started tracking the 2030 chemical provisions; how product documentation and any QR-accessible data will be maintained and by whom; and who the EU-based responsible economic operator is for online sales. Get the answers in writing and diarise a review before the next buying season.
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Planning a 2026 EU toy order?
If you are specifying toys for the EU market and need the documentation questions above answered before you commit to a purchase order, send us your product list and destination market. We will tell you plainly what is confirmed by the official text, what is still transitional, and what your supplier needs to put in writing.