Understanding the EU TSR 2025/2509: Reshapes Chemical Compliance

Toy Supply Chain Compliance Thresholds Fully Upgraded

The European Union officially published the new EU Toy Safety Regulation (EU) 2025/2509 (Toy Safety Regulation, TSR) on 12 December 2025.
This new regulation will fully replace the existing Toy Safety Directive 2009/48/EC, marking a major regulatory shift in the EU’s approach to toy safety and chemical substance management.

As the new framework is adopted in the form of a Regulation, rather than a Directive, it will be directly applicable in all EU Member States without the need for national transposition. As a result, it will impose highly consistent and immediately binding legal requirements across the entire toy industry and its supply chain.

According to the official EU announcement, the implementation timeline of the new Toy Safety Regulation is as follows:

12 December 2025:
The EU Toy Safety Regulation (EU) 2025/2509 is formally published.

From 2026 onward:
The Regulation enters into force, with certain provisions becoming applicable (start of the transition period).

1 August 2030:
The Regulation becomes fully and mandatorily applicable, and the existing Toy Safety Directive 2009/48/EC is formally and completely replaced.

During the transition period from 2026 to 2030, the new Regulation and the existing Directive will apply in parallel in accordance with specific provisions. Companies will need to progressively adjust product design, material selection, and compliance strategies to ensure a smooth transition ahead of full implementation.

Chemical Risk Management

The new Regulation significantly strengthens the management of the following chemical risks:

CMR substances (carcinogenic, mutagenic, and reprotoxic)
Endocrine Disruptors (EDCs)
Additives and reactive substances with potential health concerns
High level of integration and cross-application with the REACH Regulation

Details are outlined below:

1. CMR Substances (Carcinogenic, Mutagenic, Reprotoxic)

Under the TSR, toys are, in principle, prohibited from containing the following substances classified as CMR Category 1A / 1B / 2:

Carcinogenic
Mutagenic
Reprotoxic

2. Endocrine Disruptors (EDCs)

The revised TSR explicitly includes endocrine disruptors as key substances subject to control:

Affect the hormonal system
May interfere with children’s growth, development, and reproductive functions
Associated with long-term chronic health risks

These controls are closely aligned with the REACH Regulation. Substances identified as EDCs in the future are expected to become increasingly difficult to continue using in toy products.

3. Phthalates

The TSR maintains and consolidates existing EU chemical regulatory requirements by restricting specific phthalates, including but not limited to:

DEHP
DBP
BBP
DINP
DIDP
DNOP

4. Heavy Metals and Element Migration Limits

Strict migration limits are established for the following metals and elements:

Lead (Pb)
Cadmium (Cd)
Mercury (Hg)
Hexavalent chromium (Cr VI)
Arsenic (As)
Nickel (Ni), among others

5. Sensitising Substances and Specific Fragrances

The TSR further tightens restrictions on substances that may cause skin sensitisation or respiratory irritation, including:

Certain fragrance ingredients
Chemical substances identified by the EU as substances of high concern for sensitisation

6. High Level of Integration with the REACH Regulation

The revised TSR no longer operates in isolation but is deeply integrated with the REACH Regulation, including:

Substances of Very High Concern (SVHCs)
Restricted substances listed in Annex XVII
Newly identified or upcoming regulated chemical substances

Impact on Non-Toy Raw Materials and Industrial Products

Similar to the previous Toy Safety Directive, the scope of the TSR remains limited to finished toy products intended for use by children under the age of 14. Therefore:

Industrial raw materials, lubricants, and processing additives are not direct subjects of the TSR.
However, if such products are used in toy manufacturing or may come into contact with children, suppliers may still be required to provide chemical compliance declarations or risk assessment documentation.
Under the new regulatory framework, toy manufacturers are expected to apply more stringent material screening of suppliers, making the completeness and transparency of chemical information across the supply chain a key prerequisite for continued cooperation.

The core direction of the revised EU Toy Safety Regulation (EU) 2025/2509 is not focused on banning individual substances alone, but on establishing a more forward-looking and robust chemical risk protection framework, with particular emphasis on:

Long-term health risks
Low-dose exposure
Supply chain transparency

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