[Home](/)/[Resources](/resources)/CE marking for toys EUDirective guide # CE Marking for Toys: Directive 2009/48/EC The Toys Safety Directive is one of the most detailed CE frameworks in the EU. Physical, chemical, flammability, and electrical safety requirements combine into a single compliance program — and chemical restrictions update independently of the directive text, meaning a product that was compliant last year may not be compliant today. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fce-marking-for-toys) At a glance Safety requirement areas 5 Key EN 71 standards 7 FAQs 4 ## What counts as a toy under the directive? The Toys Safety Directive 2009/48/EC applies to products designed or intended — exclusively or not — for use in play by children under 14 years of age. The definition is broad and intentional. A product does not need to be explicitly labelled as a toy to fall in scope; if a child is reasonably expected to play with it, the directive applies. Annex I of the directive lists specific product exclusions: festive decorations, scale models for adult collectors, sports equipment for children over 36 months (with exceptions), and puzzle pieces exceeding 500. When a product falls outside the directive, the GPSR still applies — there is no compliance gap between the two frameworks. Electronic toys that include Wi-Fi, Bluetooth, or other intentional radio functions also need RED compliance alongside the Toys Directive. The CE mark on the Declaration of Conformity must reference both frameworks. This is a frequent gap in toy technical files submitted by hardware-first teams. ## Essential safety requirements Art. 10 ### Physical and mechanical safety Toys must not present injury risk from sharp edges, protrusions, or small accessible parts. The EN 71-1 small parts cylinder test defines what constitutes a small part — critical for products intended for children under 36 months. Art. 11 ### Flammability Toys must not constitute a dangerous flammable element in the child's environment. Materials must meet reaction-to-fire limits under EN 71-2. Certain toy types — projectile toys with tips designed to ignite — are prohibited outright. Art. 13 ### Chemical properties Toys must not contain hazardous substances above set migration limits. EN 71-3 covers heavy metal migration (lead, cadmium, chromium VI). REACH SVHC restrictions, phthalate limits, and CMR substance prohibitions apply and are updated independently of the directive. Art. 14 ### Electrical properties Electrically powered toys must meet electrical safety requirements. The maximum operating voltage is 24 V DC; external power supply voltage is limited to 24 V. Mains-connected toys need LVD compliance via EN 62115 (electric toys safety). Art. 15 ### Hygiene Toys intended for contact with the mouth, placed near the face, or used by children under 36 months must be designed so they can be cleaned without structural damage. This particularly affects soft toys and bath toys. ## Key harmonised standards (EN 71 series) Applying current harmonised standards from the EN 71 series gives presumption of conformity for the corresponding essential requirements. Most toy products need EN 71-1 and EN 71-2 at minimum. EN 71-3 applies when accessible coatings, paints, or materials could leach heavy metals. Always verify current OJ citation status before finalising your test plan. EN 71-1 Mechanical and physical properties — small parts, sharp points, edges, and pull strength EN 71-2 Flammability — reaction to fire, burning rate, and self-extinguishing requirements EN 71-3 Migration of certain elements — 19 heavy metals including lead, cadmium, and chromium VI EN 71-4 Experimental sets for chemistry and related activities EN 71-5 Chemical toys (sets) other than experimental sets EN 71-8 Activity toys for domestic use — swings, slides, climbing frames, and trampolines EN 62115 Electric toys — safety standard (cited under LVD via Toys Directive Art. 14) ## Frequently asked questions ### Does every toy need third-party testing for CE marking? Not always. For most toys, manufacturers can self-certify under Module A using harmonised standards from the EN 71 series. Notified Body involvement is required when the toy is electrical and falls outside harmonised standard coverage, or when harmonised standards do not fully address the essential requirements for that toy type. Many soft toys self-certify; electronic learning toys with novel features may need a Notified Body. ### What are the age warning labelling requirements for small parts? Toys not suitable for children under 36 months due to small parts must carry a standardised warning — either the text 'Not suitable for children under 36 months' or the recognised age warning pictogram. This warning must appear on the toy itself, on the packaging, and in the instructions for use. The small parts cylinder test from EN 71-1 defines the geometric threshold. ### How often are chemical limits updated in EN 71-3? EN 71-3 and REACH SVHC restrictions are updated relatively frequently. Phthalate limits, CMR substance prohibitions, and the SVHC candidate list have all been tightened in successive amendments. Verify the current OJ citation for EN 71-3 and review the REACH SVHC candidate list at least annually for products in active production. ### Does a connected electronic toy need RED compliance as well as the Toys Directive? Yes. A toy with Wi-Fi, Bluetooth, or any other intentional radio transmitter falls under RED 2014/53/EU in addition to the Toys Directive. The two directives run in parallel — the CE mark on the toy's DoC must reference both. Your lab's test plan and technical file must address both directive frameworks. **Disclaimer:** Educational resource only. Not legal advice. Chemical restrictions under EN 71-3 and REACH are updated frequently — always verify current standards and substance limits before placing toys on the EU market. 🇪🇺 CE Marking roadmap for toys Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take toys through 🇪🇺 CE Marking compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/01-ce-marking-for-electronics-engineers)[Prefer to read? 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