Selling toys in the EU market: FAQ on CE marking on toys

What is CE marking?

CE marking refers to the letters ‘CE’, from the French "conformité Européenne" meaning "European conformity”, that appears on products traded within the extended Single Market of the European Economic Area (EEA).

It indicates that these products have undergone evaluation to adhere to rigorous safety, health, and environmental protection standards. CE marking on toy products signifies that the manufacturer affirms toy compliance with the relevant requirements detailed in community harmonization legislation.

What kind of toy products need a CE marking?

All toys sold in the EU must carry a CE marking.

As defined in the Toy Safety Directive 2009/48/EC, “toys” means products designed or intended, whether or not exclusively, for use in play by children under 14 years of age.

However, there are various exemptions, including:

Playground equipment intended for public use;
Automatic playing machines, whether coin operated or not, intended for public use;
Toy vehicles equipped with combustion engines;
Toy steam engines;
Slings and catapults; and
Products listed in Annex I of the Toy Safety Directive 2009/48/EC

What are the essential safety requirements that toys must meet?

According to the Toy Safety Directive 2009/48/EC, toys must meet safety requirements that cover various risks including physical and mechanical, flammability, chemical, electrical, hygiene, and radioactivity.

They must also consider general risks to children’s health and safety and those of others such as parents or caregivers.

What should manufacturers do to obtain CE marking for toys?

Manufacturers must follow these steps to obtain the CE marking:

Safety Assessment: Analyse potential hazards from chemical, physical, mechanical, electrical, flammability, hygiene, and radioactivity.
Conformity Assessment: Choose between self-verification (using harmonised standards) or third-party verification through a notified body (applying for the EC-type examination to a notified body)
Technical Documentation: Draw up documentation ensuring the toy meets the essential safety requirements.
Declaration of Conformity: Issue an EC Declaration of Conformity, declaring that the toy meets all applicable EU requirements.
Affix CE Mark: Place the CE marking on the toy, affixed label, or its packaging.
Display Contact Information: Affix the manufacturer’s name and address, along with a traceability element such as a batch or serial number.
Instruction and Safety Information: Accompany instructions and safety information and bear the required warnings along with the toy products.

If using self-verification for conformity assessment, what if harmonized standards do not cover all safety aspects?

If harmonized standards do not cover all safety aspects of a toy, the manufacturer must opt for third-party verification through a notified body. The manufacturer submits a model of the toy to a notified body for an EC-type examination. If the toy meets the requirements, the notified body will issue an EC-type examination certificate to the applicant.

How to find a Notified Body?

The NANDO database in the EU’s SMCS system contains the names and details of notified bodies performing conformity assessments for the Toy Safety Directive 2009/48/EC.

Here is the Notified Body under the Eurofins Toys & Hardlines network of laboratories.

What should be included in the technical documentation?

The technical documentation should encompass all relevant details such as design and manufacturing processes, safety assessments, and compliance measures. It should be comprehensive enough to demonstrate the toy's adherence to essential safety requirements and must be maintained for at least ten years after the toy is placed on the market.

Read our article “Ensuring the accuracy of your toy technical documentation” for more.

What should importers and distributors do to ensure compliance?

For importers:

Only place toys compliant with safety requirements on the EU market.

An importer has to:

Make sure the manufacturer has completed the necessary conformity assessment procedure to prove the toy meets essential safety standards.
Confirm that the manufacturer has prepared technical documentation demonstrating compliance with essential safety requirements.
Keep a copy of the EC Declaration of Conformity which verifies the toy is adhered to required safety standards. The manufacturer takes responsibility for ensuring the toy product meets with compliance.
Verify that the CE marking is affixed either directly on the toy, on an affixed label or the packaging.
Ensure that the manufacturer affixes their name and address, along with a traceability element such as a batch or serial number.
Confirm that the toy is accompanied by instructions and safety information and bears the required warnings.
Affix importer name and address.

For distributors:

Act with due care when making toys available on the EU market.

A distributor has to verify that:

The CE marking is affixed either directly on the toy, on an affixed label or the packaging.
The manufacturer has affixed name and address, along with a traceability element such as a batch or serial number on the toy or its packaging.
The importer has affixed name and address.
The toy is accompanied by instructions and safety information and bears the required warnings.

Are there any additional legal obligations for non-EU manufacturers?

Yes, as part of the EU regulation on market surveillance and product compliance, non-EU manufacturers must appoint an EU-based "economic operator" responsible for ensuring the product's compliance with EU requirements. The economic operator's name and contact details must be included on the toy or its packaging.

An economic operator could be a manufacturer, authorised representative, importer or distributor.

How long must manufacturers keep the EC Declaration of Conformity?

Manufacturers must retain the EC Declaration of Conformity for a minimum of ten years after the toy has been placed on the EU market. This document signifies the manufacturer’s responsibility for the toy's compliance with the essential safety requirements.

How can the Eurofins Toys & Hardlines network of laboratories help?

Our Eurofins lab operates as a Notified Body (2817) for CE marking of a wide range of toy products, helping toy brands and manufacturers conduct tested and completed documents related to the conformity assessment procedures set out in the European Toys Safety Directive 2009/48/EC.

For more information, visit our CE Marking Certification page or contact us directly.

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