EU Toy Regulation 2026 — PFAS/Bisphenol Controls + Digital Product Passport
At the end of 2025, the EU's latest Toy Safety Regulation (TSR) was officially adopted and is expected to take effect in the second half of 2026, fully replacing the current Toy Safety Directive 2009/48/EC. The new regulation introduces major changes in scope of application, chemical substance controls, and digital compliance, with far-reaching implications for Chinese toy exporters.
Scope Expansion: Children's Age Cap Raised from 12 to 14
The new regulation raises the age cap for "toys" from 12 to 14 years. This means products for 12-14 year-olds that were previously managed as "general consumer goods" — such as certain educational board games, science experiment kits, and remote-controlled models — will be brought under toy regulatory oversight and must meet stricter safety and chemical requirements.
Comprehensive PFAS Restrictions
The new regulation explicitly prohibits the intentional addition of PFAS (per- and polyfluoroalkyl substances) in toys. PFAS are widely used in stain-resistant, water-repellent, and oil-repellent coatings, commonly found in fabric toys, children's clothing accessories, paints, and other products. Exporters must audit their supply chains to ensure raw materials and additives contain no intentionally added PFAS.
Strengthened Bisphenol Controls
The new regulation extends bisphenol restrictions from bisphenol A (BPA) to multiple bisphenol compounds (such as BPS, BPF, etc.) and lowers migration limits. This affects plastic toys, teethers, and children's tableware. Companies need to monitor the technical feasibility and compliance of alternative materials.
Six Key Compliance Points
- Age Expansion: Products for ages 13-14 may be brought under regulation
- Chemical Safety: PFAS ban + expanded bisphenol restrictions
- Digital Product Passport (DPP): Toys will be required to have a DPP
- Battery Structural Safety: Battery-containing toys must meet both mechanical and electrical safety standards
- Label Changes: New DPP carrier identification (e.g., Data Matrix code)
- Online Sales Compliance: Product information pages must display compliance documentation
Key Comparison: Old vs. New Regulation
| Comparison Dimension | Directive 2009/48/EC | New Regulation TSR |
|---|---|---|
| Children's Age Cap | 12 years | 14 years |
| PFAS Control | No specific provisions | Explicit ban on intentional addition |
| Bisphenol Restrictions | BPA only | Covers multiple bisphenols, stricter limits |
| Digital Passport | Not required | DPP mandatory |
| Online Sales | Not specified | Requires display of compliance information |
Implementation and Transition Arrangements
The new regulation is expected to take effect 20 days after publication in the EU Official Journal in the second half of 2026, with a 36-54 month transition period (depending on provisions). Companies are advised to begin compliance preparations early, particularly regarding the R&D and verification cycle for PFAS and bisphenol alternatives.
FAQ
Q: My product is labeled 13+, will it now be classified as a toy?
A: Possibly. After the new regulation takes effect, products targeting children under 14 may be considered toys. It is recommended to re-evaluate product positioning and applicable age criteria.
Q: Are there any exemptions to the PFAS ban?
A: The current text does not provide PFAS exemptions; all intentionally added PFAS in toys are prohibited. Non-intentionally added trace residues must be controlled to the lowest technically feasible level.
Q: How do I implement a Digital Product Passport?
A: Compliance documents (declaration of conformity, test reports, safety information, etc.) must be digitized and linked to a unique identifier. GreenArk can assist companies in building DPP compliance solutions, including testing, document digitization, and labeling guidance.
Q: What about existing inventory during the transition period?
A: Inventory placed on the market before the end of the transition period can generally continue to be sold ("legacy stock" rule), but this depends on the final regulation text. It is recommended to clear old-version products as early as possible.
GreenArk (Shenzhen) Certification Co., Ltd. closely tracks EU toy regulation developments, providing toy exporters with regulation interpretation, chemical testing agency services, and digital product passport solution design to help companies transition smoothly.
GreenArk (Shenzhen) Certification Co., Ltd.
www.greenark-sz.com | sui@greenark-sz.com
