CE marking for toys done! With easyCE expert support.

Make toy safety part of your product development. easyCE assesses the applicable requirements, reviews safety evidence and prepares the technical documentation needed for a well-supported CE declaration.

0:00 / 0:00

Willy Lebherz

Founder and Managing Director of easyCE GmbH

Toy safety assessment and CE marking requirements

Tell us about your product

Request free initial advice on the requirements for your product and the next steps for its conformity assessment.

What can we help you with?

How can we reach you and provide answers?

Or simply give us a call: +49 7248 4524700

DoC ready to sign!

We prepare your declaration of conformity, ready for the responsible signatory.

Risk assessment completed!

We assess the relevant product risks and document the findings.

Applicable standards identified!

We identify the relevant harmonised standards and check their scope, current references and any restrictions for your product.

Technical documentation created!

We prepare clear technical records and practical instructions for your product.

Ready for CE marking!

Once conformity has been demonstrated, the manufacturer signs the declaration and affixes the required marking.

Your role. Your CE responsibilities.

Manufacturers

The Toy Safety Directive 2009/48/EC applies to products designed or intended, whether exclusively or not, for use in play by children under 14. It addresses foreseeable use, children's behaviour and the specific hazards presented by the toy.

Regulation (EU) 2025/2509 entered into force on 1 January 2026, but its main product requirements apply from 1 August 2030. The directive remains the basis for current toy conformity assessments during the transition. Future requirements, including the digital product passport, must not be presented as already mandatory.

easyCE reviews the toy's intended use, materials and design, identifies relevant standards and assessment routes, and compiles the agreed evidence. Harmonised standards can support conformity, but their use is voluntary and their scope must match the product.

+49 7248 4524700

Frequently asked questions

What is changing in EU toy safety law?

Regulation (EU) 2025/2509 will replace the Toy Safety Directive 2009/48/EC. It entered into force on 1 January 2026, while its main requirements apply from 1 August 2030.

Until that changeover, current assessments must follow the applicable directive requirements. Manufacturers should plan for the new regulation, including its digital product passport, without confusing future duties with obligations already in force.

What does the Toy Safety Directive regulate?

The directive sets safety requirements for toys and duties for manufacturers, importers and distributors. It addresses general safety and specific hazards.

  • Physical and mechanical hazards.
  • Flammability.
  • Chemical hazards.
  • Electrical hazards.
  • Hygiene.
  • Radioactivity.

The assessment must consider intended and reasonably foreseeable use, taking account of children's behaviour and the abilities of the intended users.

Which products are toys?

The directive covers products designed or intended, whether exclusively or not, for play by children under 14. Marketing, presentation, design and foreseeable use all matter when deciding whether a product is a toy.

The scope excludes specified products, including public playground equipment, automatic playing machines for public use, toy vehicles with combustion engines, toy steam engines, slings and catapults. Annex I also lists products not considered toys, such as certain collectors' items and sports equipment. A label alone cannot turn an otherwise in-scope toy into a non-toy.

Which other requirements and standards apply?

The EN 71 series addresses different toy safety topics, while electrical toy safety is addressed by relevant electrical toy standards. Only the applicable parts, editions and published harmonised references support the intended assessment.

Harmonised standards are voluntary. Other legislation, such as RED for a radio function or RoHS for electrical equipment, may also apply. The product must be assessed against all relevant obligations, not a standard number selected in isolation.

Why is a complete safety assessment important?

A CE mark is not a substitute for evidence that the toy is safe. The assessment links the design, materials, foreseeable exposure, tests and warnings to the applicable requirements.

This gives the manufacturer a defensible basis for its declaration and helps identify issues before production or market surveillance brings them to light.

What must manufacturers, importers and distributors do?

Manufacturers are responsible for design, manufacture, safety assessment, technical documentation and the conformity declaration. Importers must check that the manufacturer has fulfilled the relevant duties before placing toys from outside the EU on the market. Distributors must exercise due care and check the required marking and information.

All roles include duties concerning traceability, storage and transport where relevant, non-conforming products and cooperation with authorities. An operator marketing a toy under its own name or modifying it in a way that may affect conformity can assume manufacturer obligations.

Which documents must be retained?

Manufacturers must keep the technical documentation and EC declaration of conformity for ten years after the toy is placed on the market. These records support the assessment and must be made available to the authorities as required.

The technical file is not simply a public marketing document. It must contain the design and manufacturing information, safety assessment, relevant test reports and other records specified in Article 21 and Annex IV.

What is the toy declaration of conformity?

Under Directive 2009/48/EC, the document is called an EC declaration of conformity. The manufacturer issues it under its sole responsibility once conformity has been demonstrated.

It identifies the toy, manufacturer, applicable legislation and relevant standards or specifications, with notified-body details where applicable and the place, date and authorised signature. The future regulation's terminology and digital requirements should not be applied prematurely.

Which conformity assessment routes are available?

The directive provides internal production control, Module A, or EC-type examination followed by conformity to type, Modules B and C. The appropriate route depends on the use and coverage of harmonised standards.

When can internal production control be used?

The manufacturer can use Module A where it has applied harmonised standards whose references are published in the EU Official Journal and those standards cover all relevant safety requirements for the toy.

The manufacturer must still carry out the safety assessment, maintain production conformity and hold the necessary technical evidence. Internal assessment does not mean that testing or documentation can be omitted.

When is EC-type examination required?

EC-type examination by a notified body is required in the cases set out in Article 19, including:

  • No harmonised standards cover all relevant safety requirements.
  • The relevant harmonised standards have not been applied, or have been applied only in part.
  • A relevant harmonised standard has been published with a restriction affecting the toy.
  • The manufacturer considers that the toy's nature, design, construction or purpose requires third-party verification.

The approved type is then followed by the required production-conformity procedure.

What does a notified body assess?

A notified body designated for the relevant scope examines the technical design and supporting evidence through the prescribed EC-type examination procedure. It performs or arranges the necessary examinations and tests.

The manufacturer remains responsible for the toy and for ensuring that production continues to conform. A notified-body certificate does not transfer that responsibility.

How do safety assessment and conformity assessment differ?

The safety assessment identifies the hazards a toy may present and evaluates potential exposure to them. Conformity assessment demonstrates that the toy meets the applicable legal requirements through the required procedure.

Both must be completed before the toy is placed on the market. The safety assessment informs the design, testing, technical documentation and warnings.

What happens once conformity has been demonstrated?

The manufacturer finalises the technical documentation, issues the EC declaration of conformity and applies the CE marking before placing the toy on the market. Required identification, instructions and warnings must also be provided.

Series production must remain consistent with the assessed design. Relevant design, material or standards changes require review.

Where must CE marking appear?

The CE marking must be visible, legible and indelible on the toy, an attached label or its packaging. If it is not visible from outside the packaging, it must at least appear on the packaging.

For small toys or toys made up of small parts, a label or accompanying leaflet may be used as specified in Article 17. A limited counter-display provision also exists. The directive does not require the mark on the toy, packaging and instructions in every case.

CE marking proportions

What information must accompany a toy?

The required information includes appropriate instructions and safety information, relevant warnings, product identification and the responsible operators' contact details, using the locations and language rules specified in the directive.

The technical documentation is retained by the responsible operator; it is not the same as the information supplied to the user. Instructions and warnings must reflect the toy's actual design and foreseeable use.

How should warnings be presented?

Warnings must be clear, accurate and appropriate to the hazards and intended users. Age warnings cannot contradict the toy's intended use or be used to avoid design requirements.

Warnings that determine the decision to buy must be clearly visible before purchase, including online. Annex V sets additional wording and presentation rules for specified toy categories.

Trusted by leading businesses. Chosen for results.

Mercedes-Benz logo TEKA logo Drexler Automotive logo Böhmler logo Bürkert logo CPM Extricom Extrusion logo Hengst Filtration logo IMS Gear logo KABE Labortechnik logo MicroStep logo MSE Filterpressen logo Deutsche Post DHL logo POLYRACK logo REINTJES logo

Consistently rated excellent by our customers

Your CE project. Expertly handled.

Scroll horizontally to compare the options.

Approach to CE marking

How the service works

Scope of support

Project contact

Product-specific assessment by experienced engineers

Engineering expertise combined with digital workflows

A complete project or selected tasks

A dedicated expert for your project

Other service providers

Approach depends on the provider and agreed scope

Processes vary between providers

Services depend on the provider and contract

Contact arrangements vary

CE software

Guided workflows based on the software functions

Your team enters information and assesses the results

Scope depends on the available modules

Technical support depends on the subscription

Practical engineering expertise

Successful projects. Results that speak for themselves.

CE marking for a tunnel boring machine used in Australian copper mining

CE marking for a tunnel boring machine used in Australian copper mining

easyCE carries out the conformity assessment for a tunnel boring machine, including risk assessment across its lifecycle and preparation of a declaration of conformity ready to sign. The assessment focused on the new multi-arm cutting-head concept. The work also considered the applicable Australian safety and technical requirements, in close cooperation with the manufacturer and its Australian customer.

Legislation and standards considered: Machinery Directive 2006/42/EC, EMC Directive 2014/30/EU, Low Voltage Directive 2014/35/EU, Pressure Equipment Directive 2014/68/EU, ATEX Directive 2014/34/EU

CE marking and declaration of conformity for control cabinets

CE marking for control cabinets

easyCE supports the conformity assessment for control cabinets, including risk assessment and preparation of a declaration of conformity ready to sign. The assessment considered the Machinery, EMC and Low Voltage Directives, alongside DIN EN 60204-1:2019-06 and DIN EN IEC 61439-1:2021-10. The work also included a checklist to help select suppliers and components that meet the project's specific requirements.

Legislation and standards considered: Low Voltage Directive 2014/35/EU, EMC Directive 2014/30/EU

CE marking for a mobile satellite communications system

CE marking for a mobile satellite communications system

easyCE supports the conformity assessment of a mobile satellite communications system, including risk assessment, EMC review and preparation of a declaration of conformity ready to sign. The system routes TCP/IP data redundantly through two or more satellite antennas. It is designed for rapid deployment where a mobile communications link is needed over long distances.

Legislation and standards considered: Radio Equipment Directive 2014/53/EU, Low Voltage Directive 2014/35/EU, EMC Directive 2014/30/EU

2D laser cutting system with an automatic pallet changer

CE marking and declaration of conformity for a 2D laser cutting system

easyCE supports the full conformity assessment for a 2D laser cutting system with an automatic pallet changer. The work included coordinating the safety concept and two-beam light barrier, determining the performance level, analysing the product and carrying out a risk assessment in accordance with EN ISO 12100. Particular attention was needed for the cutting head's support structure and the movements of the pallet changer and cutting head. Laser protection screens, safety devices and a complete enclosure shield operators from the Class 4 laser cutting process inside the cabin, with Class 1 laser conditions outside the machine.

Legislation and standards considered: 2006/42/EC, 2014/30/EU, DIN EN 60825-1.

Toy safety assessment for wood-plastic composites

Toy safety assessment for wood-plastic composites

easyCE assessed wood-plastic composite materials intended for consumer products and toys. The work addressed chemical migration and restricted substances, with reference to DIN EN 71-3 and EN 71-9, and documented the assessment. Material assessment alone does not establish that every product made from it is compliant or requires CE marking.

Project references: 2009/48/EC

Explore more reference projects and success stories

Your project in three steps

Step 1

Discuss your product

Tell us about your product and request free initial advice. We identify the likely conformity requirements and the next steps for your project.

Step 2

Receive your proposal

We explain the required assessments and documentation, then prepare a proposal for the scope you need. You can commission a complete project or individual tasks.

Step 3

Your expert gets started

Your dedicated CE expert carries out the agreed engineering and documentation tasks and keeps you informed throughout the project. Follow-up questions can be discussed with the same expert.

Discuss your CE project

+49 7248 4524700

Product safety expertise

Willy Lebherz, Founder and Managing Director of easyCE
Willy Lebherz, Founder and Managing Director of easyCE

Willy Lebherz, Founder and Managing Director of easyCE

  • Expert in product safety and conformity since 1995
  • Recipient of the "Medal of the Order of Merit of the Federal Republic of Germany", awarded in 1983 by the then Federal President Carl Carstens
  • Meister qualification in measurement and control technology
  • Captain (ret.), Project Officer for Technical Logistics in the Army Material Office and Chief of the Telecommunications Repair Company

easyCE is an engineering consultancy specialising in product safety and conformity assessment. We help manufacturers, operators and suppliers assess products, reduce risks and prepare the documentation needed for market access. Our engineers identify applicable requirements, develop safety measures, prepare technical documentation and coordinate testing. You can commission the complete agreed process or selected tasks. Founded in southern Germany, easyCE works with clients internationally.

Technical expertise. Clear documentation. A defined route to conformity.