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EUProduct guide

# CE Marking for Children's Electronics

Children's electronic products are subject to some of the most demanding CE requirements in consumer electronics. The first compliance question is always: is this a toy? The answer changes everything — including the chemical limits, the safety standards, and whether a Notified Body is required.

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## Toy vs EEE: the critical first question

### Toy Safety Directive 2009/48/EC

Products designed or intended — even if not exclusively — for use in play by children under 14. Includes electronic toys, interactive learning devices, and child-facing smart toys.

Specific chemical safety limits (stricter than RoHS), mechanical and physical safety, electrical safety, and age-appropriate warnings. Notified Body may be required for certain toy categories.

### General EEE directives (EMC, LVD, RED, RoHS)

Children's electronic products not classified as toys — kids' tablets, educational tablets, child-targeted smartwatches.

Standard CE marking under applicable directives. GPSR also applies as these are consumer products. Enhanced risk assessment recommended for child users.

### GPSR 2023/988 (General Product Safety Regulation)

All consumer products intended for or likely used by children.

GPSR specifically calls out child safety as a factor in safety assessment. Products targeted at children face heightened scrutiny under market surveillance.

## Toy Directive vs RoHS chemical limits (examples)

SubstanceToy Directive limitRoHS limit

Lead (Pb)13.5 mg/kg in scraped-off material0.1% by weight of homogeneous material

Cadmium (Cd)1.9 mg/kg in scraped-off material0.01% by weight

Mercury (Hg)94 mg/kg in scraped-off material0.1% by weight

Chromium VI0.053 mg/kg in scraped-off material0.1% by weight

## Safety assessment checklist for children's products

01

Determine whether the product is a 'toy' under the Toy Safety Directive definition

02

Apply enhanced chemical migration limits if the product is a toy (not just RoHS limits)

03

Include choking hazard and small parts warnings for products with components that could detach

04

Age-grade the product based on physical, cognitive, and developmental appropriateness

05

Assess foreseeable misuse by children more broadly than for adult-facing products

06

Verify that cords, cables, and charging accessories meet strangulation risk requirements

07

Include specific safety warnings on packaging and in instructions in all required EU languages

08

Conduct electrical safety testing at a higher standard where children are the primary users

## Frequently asked questions

### My product is a children's tablet, not a toy. Does the Toy Safety Directive apply?

If the tablet is marketed or designed primarily for children's education or entertainment but not primarily as a toy for play, the Toy Safety Directive may not apply — but this depends on how the product is marketed and presented. If it features toy-like characteristics or is presented as play equipment, authorities may determine it is within Toy Directive scope. When in doubt, assess both pathways.

### Are the chemical limits in the Toy Safety Directive stricter than RoHS?

Yes, significantly. The Toy Safety Directive uses migration limits (amount that can be released from a material) rather than content limits (total amount present). These are expressed in mg/kg of scraped material and are typically far more restrictive than RoHS content thresholds. A product that meets RoHS may still fail Toy Directive chemical requirements.

### Do children's products need enhanced EMC testing?

CE marking EMC requirements are the same regardless of end user. However, the risk assessment for children's products should specifically consider how children are likely to use and misuse the device, including proximity to the body and head, which affects RF exposure assessment.

**Disclaimer:** Educational resource only. Not legal or engineering advice. Toy classification involves detailed legal analysis. Always verify with a qualified legal or compliance professional and accredited test laboratory.

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