This article is provided by BRC Associate Member, UL Solutions.

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As manufacturers around the world anticipate the publication of new European Union (EU) toy safety regulations — expected to significantly reshape requirements for toys placed on the EU market — regulatory work continues. While the definitive text is still pending, the European Committee for Standardization (CEN) is actively developing standards in alignment with Directive 2009/48/EC and the European Commission (EC) mandate. Several standards have been published in 2025, and many more are scheduled for publication by the end of the year.

Standards published in 2025

·      EN 71-2:2020+A1:2025:

On June 11, the CEN published EN 71-2:2020+A1:2025 Safety of toys - Part 2: Flammability. This standard supersedes the previous EN 71-2:2020 and still needs to be harmonized.

Main changes:

— Inclusion of new definitions for olfactory board game, cosmetic kit and gustative game

— Modification to the general requirements linked with highly flammable liquids and flammable liquids contained in chemical toys, olfactory board games, cosmetic kits and gustative games, aligning with EN 71-5 and EN 71-13

Clarifications in the testing procedure for masks

— Refinements to the preparation of samples submitted for flammability testing when it comes to toy disguise costumes, toys intended to be worn, and toys to be assembled by a child (i.e., how to cut and prepare the test specimen when there is insufficient material to take two samples in a vertical orientation)

— Increase in the range of allowable water hardness to wash toys when no washing instructions are provided, or if a toy disguise costume is marketed as non-washable

  • EN 71-4:2020+A1:2025

Main changes:

— Deletes entry for potassium permanganate due to its harmonized classification as a reproductive toxicant category 2 substance under Regulation (EC) No 1272/2008 on classification, labeling and packaging of substances and mixtures (CLP Regulation, consolidated version to February 2025)

— Sets the maximum concentration limit of < 3% potassium permanganate mixture with sodium sulfate in chemistry sets to meet the requirements of Directive 2009/48/EC (consolidated version to December 2022) as regards carcinogenic, mutagenic or reprotoxic (CMR) substances, and revises appropriate pictograms and signal word Clause 5.2.4.1 ‘Chemistry sets’

— Permits closures for child-resistant containers to comply with one of three methods: 1) EN ISO 8317:2015, 2) Closure test A or Closure test B

In addition, a full set of European Norm (EN) standards have been published in February 2025 to cover the requirements of Appendix C (applicable to toys intended for use by children under 36 months, or in other toys intended to be placed in the mouth), and while we are still waiting for the harmonization of these standards, some of them can already be used to verify compliance and will be playing a key role when the new EU Toy Safety Regulation is published.

Restrictions will probably apply to most toys:

Substance​

Standards to be replaced in protocol​

When to implement replacements
and upgrade​s

Phenol (content and migration)​

EN 71-18:2024​

When the standard will be harmonized with the directive, following the decision of the European Commission (decision date not known)

Bisphenol A​

EN 71-19:2024​

1,2-benzisothiazol-3(2H)-one​

EN 71-17:2025​

Tris(2-carboxyethyl)phosphine (TCEP), Tris(chloropropyl) phosphate (TCPP), Tris[2-chloro-1-(chloromethyl)ethyl] phosphate (TDCP)​

EN 71-16:2025​

Reference method that can be used from 26/02/2025

When harmonized, it will be mandatory to use these test methods.​

Methylchloroisothiazolinone (MCI) and Methylisothiazolinone (MI), both individually and
in a ratio of 3:1​

EN 71-17:2025​

Formamide (content)​

EN 71-15:2025​

The upcoming standards are expected to address:

  • Microbiological safety

    EN 71-20 - Standard for microbiological safety of toys containing accessible aqueous media

The proposed standard sets maximum allowable limits for total aerobic microbial count (TAMC), the total number of aerobic mesophilic microorganism colonies formed on culture media under aerobic conditions, and bile-tolerant Gram-negative bacteria. It supports the assessment of certain toys containing accessible aqueous media not only for cleanliness, but also for the effectiveness of preservatives.

In addition, revisions to EN 71-7 (safety of toys - Finger paint) are currently under review, focusing on updating the list of preservatives and adding booster substances. EN 71-5 (safety of toys - Experimental sets for chemistry and related activities) is also being updated to include provisions for slime kits.

  • Mechanical and physical properties

The proposed draft revision of EN 71-1 introduces several updates. These include new requirements for toys resembling food, targeting hazards related to the ingestion of small parts. It also includes a newly defined test method for evaluating the mechanical safety of expanding materials, following an in-depth technical assessment. Another key update is the reorganization of the requirements and test methods applicable to ride-on toys. The revised standard introduces new categories and sets additional requirements and test methods to help enhance safety. This reorganization reflects a more tailored approach to safety, recognizing the diverse designs and functions of modern ride-on toys.

Regarding activity toys, the draft revision of EN 71-8 will now cover inflatable activity toys. Updates include new requirements for means of suspension, ladders and similar access features, entrapment of head and fingers, and minimum clearance between adjacent swing devices and adjacent structures. The test method for the diameter of ropes has also changed. The updated version of EN 71-14 will contain some updates of warnings, markings and instruction requirements and a slight revision of pinching and crushing requirements.

At UL Solutions, we provide end-to-end support for quality and supply chain management in the toys and children’s products industry. We help retailers bring compliant products to market and stay ahead of evolving regulatory requirements. Contact katie.ellen.moore@ul.com to learn more.

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