Open call for evidence

Toys safety regulations: call for evidence

Published 6 July 2026

1. The UK Toys Regulations 

1) The Toys (Safety Regulations) 2011 (‘UK Toys Regulations’) implemented the requirements of the EU Toy Safety Directive 2009/48/EC (‘EU Toys Directive’) in the UK. The EU Withdrawal Act 2018 preserved these Regulations and enabled them to be amended to continue to function effectively after the UK left the EU. 

2) We are reviewing the UK Toys Regulations to ensure they support economic growth and innovation whilst ensuring toys are safe for children. We are also committed to reducing possible trade friction and simplifying cross-border transactions for suppliers, where it is in the interest of UK businesses and consumers. 

3) The EU has also reviewed its toy safety legislation and introduced Regulation (EU) 2025/2509 on the safety of toys (‘the EU Toys Regulation’) which replaces the EU Toys Directive and includes new specific safety requirements to ensure children and consumers are protected from modern day risks. The EU Toys Regulation entered into force across the EU on 1 January 2026, with a transition period up to 1 August 2030 (meaning the new rules will not apply until that date).  

4) Under current UK legislation, businesses who comply with specific requirements of the EU Toys Directive and apply the CE marking can continue to place these products on the market in Great Britain (GB). The policy of CE recognition across 21 regulations, including toys, is estimated to save businesses around £640.5 million over 10 years, largely by avoiding duplicative conformity assessment costs of CE and UKCA.   

5) Under the Windsor Framework, certain EU product regulations apply in Northern Ireland (NI), including the EU Toys Regulation, to facilitate NI’s dual access to the UK internal market and EU Single Market. The continued recognition of CE marking for toys in GB could complement the Windsor Framework arrangements by helping to smooth the flow of trade within the UK internal market. It would simplify processes for NI supply chains, supporting reduced compliance costs for business. 

6) There is an opportunity to tailor product safety and conformity assessment frameworks to our domestic priorities. We need to ensure that the UK’s toys legislation supports this crucial sector, with regulation that is pragmatic, proportionate, and globally competitive. The UK Government aims to make sure that whatever approach is taken allows the UK to respond flexibly to global market developments and promote growth, while ensuring child safety. 

2. Changes to toys legislation in the European Union 

7) According to the EU, the key objective of its new Toy Safety Regulation is to achieve a higher level of child protection and reduce the number of non-compliant and unsafe toys on the EU market. Whilst some requirements remain the same, the EU Toys Regulation introduces some key changes which include, but are not limited to, the following: 

• Updated approach on chemicals: The existing ban on carcinogenic and mutagenic substances and substances toxic for reproduction is extended to chemicals that are particularly harmful to children, such as endocrine disruptors, substances that harm the respiratory system, and chemicals that are toxic for the skin and other organs. The new rules also ban the intentional use of per-and polyfluorinated alkyl substances (PFAS) and the most dangerous types of bisphenols. Allergenic fragrances will be prohibited in toys for children under 36 months and in toys designed to be placed in the mouth. The Regulation also extends the Directive’s existing limit values for certain substances in toys intended for children under 36 months or toys that are intended to be put in the mouth to all toys. 

• Digital Product Passport (DPP): toys will have to display a DPP which is similar to the current Declaration of Conformity but requires additional information such as the CE marking, the customs commodity code and how consumers can contact the manufacturer in case of a complaint. The manufacturer should upload the information to the EU digital registry (which at the time of writing is undergoing development). The information should be publicly available through a data carrier (QR code or similar) and must be affixed to the toy or its label. 

• Internet-connected toys and Artificial Intelligence (AI): Manufacturers placing toys on the EU market may need to meet other EU regulations in addition to the Toy Safety Regulation, such as the EU AI Act or Cyber Resilience Act where relevant. Under the EU AI Act, certain AI systems are prohibited (e.g. in an AI-enabled toy that encourages children to engage in risky behaviours). In other cases, an AI-enabled toy will need to meet certain ‘high-risk’ rules where the AI performs a safety feature, and the toy is required to undergo third party conformity assessment. The EU Cyber Resilience Act also introduces certain technical, reporting and conformity requirements for internet connected toys. The Toy Safety Regulation itself has very limited AI or cyber requirements, namely that manufacturers of toys in scope of either act must account for particular vulnerabilities of children in their safety assessment.  

• Online marketplaces obligations: Online marketplaces will be required to display a link to the Digital Product Passport (for example, through a QR code). Online marketplaces will also have to show safety warnings and the CE marking that indicates that a product meets the EU’s safety, health and environmental protection rules.  

8) The UK Government is giving due consideration to the EU’s reforms of toys legislation. Many of our own objectives for product safety reform also feature in the EU’s new Toy Safety Regulation, such as considerations around new and modern technologies, a move to paperless documentation and obligations on all actors in the supply chain. We will be considering feedback to this Call for Evidence alongside feedback to linked broader UK consultations, including the UK’s new product safety framework consultation (which examines requirements for online marketplaces)^{[footnote 1]}, and proposed reforms to UK product regulation market surveillance and enforcement^{[footnote 2]}. 

9) From a trade perspective, continuing to recognise EU product requirements would reduce friction for UK manufacturers selling into the EU and for those seeking to import products into GB. Taking a similar approach across the UK to the EU Toy Safety Regulation would also mean the rules for placing a product on the market in GB are aligned with those which apply to products in Northern Ireland. 

10) The UK Government recognises that updating UK rules in a similar way to the EU Toy Safety Regulation may have unintended impacts, and so we wish to build on our understanding of those through this Call for Evidence. 

3. Consulting under the Product Regulation and Metrology Act 2025 and the Call for Evidence 

11) Any changes to the UK’s Toys legislation would be made using powers under the Product Regulation and Metrology Act 2025 (PRAM). As such, and in line with our statutory duty to consult, under the PRAM Act we are consulting on the approach for GB via this Call for Evidence. 

12) This Call for Evidence will build an evidence base on potential changes to toys legislation and help us understand: 

1. The potential benefits and costs to businesses and consumers if similar changes to the EU regulation were implemented UK wide. 

2. The potential benefits and costs of continuing recognition of EU toys requirements, including CE marking. 

13) In particular, we are keen to hear views on the following themes and how each of these would impact your business (including on whether they would have any unintended impacts, wider benefits, raise costs or lead to any savings – and any quantitative evidence for this): 

• Stricter requirements for chemical substances  
• The use of digital product passports for toys 
• The regulation of toys which are internet connected, and toys which use AI 

14) We are looking to hear from all interested parties, including, but not limited to: 

• Trade Associations 
• Manufacturers & Authorised Representatives 
• Distributors 
• Consumers  
• Importers 
• Conformity assessment bodies 
• Consumer and child safety organisations  
• Market surveillance and enforcement authorities 

15) How to respond: Please send all responses to toys.enquiries@businessandtrade.gov.uk by 11:59pm on 06 October 2026 when the Call for Evidence will close.

4. Questions

Question 1: What factors should be considered if the UK were to continue its recognition of new EU product requirements for toys, including the CE marking?

• What practicalities or wider issues might continued recognition of EU product requirements for toys involve? 

• What practicalities (including additional costs or cost savings, or administrative activities) might this involve for the economic operators and traders? 

• Overall, would you be in favour of continued recognition of the EU’s toys requirements? 

• What would you see as the benefits of this approach? 
• What would be the result if we were not to continue recognising EU product requirements in the new EU Toy Safety Regulation 2025/2509 for goods placed on the market in GB? 

Question 2: What factors should be considered if the UK Government were to implement the same approach to the EU Toy Safety Regulation 2025/2509 across the whole of the UK?

• What practicalities or wider issues might these new toy safety measures involve if adopted across the UK? 
• What practicalities might this involve for economic operators and traders? 
• What additional costs or cost savings, or additional administrative activities, would be incurred from these changes? 
• Overall, would you be in favour of legislation to introduce similar measures? 
• What would you see as the benefits of introducing the same approach? 
• Would there be an impact on your business operations or any unintended consequences if a similar approach was not introduced across the UK? 
• How might introducing the same approach in the UK impact on your organisation’s innovation and growth prospects? 

Question 3: Are there are any opportunities to make administrative savings for business?

Administrative costs to business in the UK primarily refers to the expenses incurred in demonstrating compliance with government regulations. This includes business time and money spent on paperwork and reporting. 

• What opportunities are there to achieve lower administrative burdens or administrative savings?  
• Are there any other ways that regulation of toys in the UK could be improved to reduce the burden of regulation on businesses?

5. Footnotes

1. Product regulation: the UK’s new product safety framework ↩

2. Product regulation: market surveillance and enforcement framework ↩