Toys
EU Declaration of Conformity for Electronic Toys: requirements and checklist
By Ing. Jaroslav Křepelka, Owner, DoC solutions s.r.o. · Updated 22 September 2026
Electronic toys combine the Toy Safety Directive, with its mechanical, chemical and electrical safety requirements, with EMC, RoHS and, for anything with a radio, the Radio Equipment Directive, including its data-protection requirement for toys. From 1 August 2030 the Toy Safety Regulation (EU) 2025/2509 replaces the directive and the declaration of conformity with a digital product passport.
This page covers battery-powered and radio-controlled toys, interactive and app-connected toys for children under 14.
Checklist: what your electronic toys declaration must contain
- Toy name, model and batch or item number as marked on the toy or packaging
- Name and postal address of the manufacturer (and of the authorised representative, if appointed)
- The statement that the declaration is issued under the sole responsibility of the manufacturer
- Toy Safety Directive 2009/48/EC
- EMC Directive 2014/30/EU, or the Radio Equipment Directive 2014/53/EU for toys with a radio
- RoHS Directive 2011/65/EU
- The harmonised standards applied, and the notified body and EC type-examination certificate if one was used
- Place and date of issue, name and function of the signatory, and the signature
Which EU legislation applies
| Legislation | Applies? | In the DoC? | Notes |
|---|---|---|---|
| Toy Safety Directive2009/48/EC | Applies | In the DoC: Yes | Physical and mechanical, flammability, chemical, electrical, hygiene and radioactivity requirements. Toys must not be powered by more than 24 V DC or the equivalent AC. EC type-examination by a notified body is required where harmonised standards have not been applied in full. |
| Toy Safety Regulation(EU) 2025/2509 | Depends on model | In the DoC: No | Applies from 1 August 2030 and repeals the directive. The manufacturer then creates a digital product passport instead of an EU declaration of conformity. Toys placed on the market in conformity with the directive before that date may continue to be made available. |
| EMC Directive2014/30/EU | Applies | In the DoC: Yes | For toys with electronics; replaced by RED for radio toys. |
| Radio Equipment Directive2014/53/EU | Depends on model | In the DoC: Yes | Radio-controlled and app-connected toys. Under Delegated Regulation (EU) 2022/30, applicable since 1 August 2025, radio toys that can process personal data must meet the data-protection requirement even without internet access; internet-connected toys must also meet network protection. |
| RoHS Directive2011/65/EU | Applies | In the DoC: Yes | Electrical and electronic toys are within RoHS scope. |
| Batteries Regulation(EU) 2023/1542 | Applies | In the DoC: No | Obligations for the batteries supplied with or built into the toy, including end-user removability of portable batteries from 18 February 2027. |
| WEEE Directive2012/19/EU | Applies | In the DoC: No | Producer registration in every EU country where you sell and the crossed-out wheeled bin symbol. |
Typical harmonised standards
A harmonised standard gives presumption of conformity only in the version cited in the Official Journal of the EU. Always check the current list for each directive before you issue or update a declaration (European Commission: harmonised standards); the versions below are the ones commonly used at the time of writing, and the right selection depends on your product.
Toy safety
- EN 71-1:2014 + A1:2018Mechanical and physical properties (cited with a restriction)
- EN 71-2:2020Flammability
- EN 71-3:2019 + A2:2024Migration of certain elements
- EN IEC 62115:2020 + A11:2020Electric toys — safety
EMC
- EN 55014-1:2017 + A11:2020EMC emission for household appliances and similar apparatus, including toys
- EN 55014-2:1997 + A1:2001 + A2:2008EMC immunity (edition cited in the Official Journal)
Radio toys (RED)
Versions shown are cited under RED in Implementing Decision (EU) 2022/2191 as amended.
- ETSI EN 300 328 V2.2.2 or EN 300 220-2 V3.1.12.4 GHz links, or sub-GHz short-range devices (27/40/433/868 MHz remote controls)
- ETSI EN 301 489-1 with the relevant part (-3 or -17)EMC for radio equipment
- EN 18031-2:2024Radio equipment processing personal data, including toys (cited with restrictions)
Already have a declaration for your electronic toys?
A certification expert checks it against everything on this page and tells you exactly what to fix. Written report in 48 hours, €99 per product (excl. VAT).
Common mistakes in electronic toys declarations
EN 62115 missing for an electric toy
Electrical safety of toys is assessed against EN IEC 62115, not the household appliance standards. Declarations that list only EN 71 leave the electrical requirements without evidence.
Data protection ignored for radio toys
Since 1 August 2025 radio toys that can process personal data, such as voice, images or names, must meet RED Article 3(3)(e), with or without an internet connection.
Age grading and warnings wrong or untranslated
Warnings such as "Not suitable for children under 36 months" must be accurate, legible and in the language of the country of sale.
Chemical testing not matched to materials
EN 71-3 migration testing has to cover the accessible materials of the toy as sold, including coatings and small parts.
No plan for the Toy Safety Regulation
Toys placed on the market from 1 August 2030 need a digital product passport under Regulation (EU) 2025/2509 instead of a declaration of conformity.
What you need besides the declaration
- Safety assessment and technical documentation
- The directive requires a safety assessment of chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazards, plus test reports, a description of the design and materials, and the conformity assessment evidence. Keep it for 10 years.
- Warnings and marking
- CE marking, type and batch number, manufacturer and importer names and addresses, age warnings and battery warnings, in the local language.
- Instructions
- Use, assembly and battery instructions in the language of each EU country of sale.
- Importer
- An EU importer or authorised representative whose name and address appear on the toy or packaging.
No EU presence yet? We can act as your EU authorised representative or responsible person.
Frequently asked questions
Which standards apply to an electronic toy?
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EN 71-1, EN 71-2 and EN 71-3 for general toy safety and EN IEC 62115 for electrical safety, plus EMC standards and, for radio toys, the RED radio standards.
When does the new Toy Safety Regulation apply?
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Regulation (EU) 2025/2509 applies from 1 August 2030 and replaces the Toy Safety Directive. It introduces a digital product passport in place of the EU declaration of conformity.
Do radio-controlled toys need to meet RED cybersecurity requirements?
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Radio toys that can process personal data must meet the data-protection requirement of Delegated Regulation (EU) 2022/30 since 1 August 2025, even without internet access.
What does MyCECheck check on a toy declaration?
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The Toy Safety Directive and other directives, the EN 71 parts and EN IEC 62115 with versions, the radio and data-protection coverage, and the identification of the toy and the importer. Written report within 48 hours.
Already have a declaration for your electronic toys?
A certification expert checks it against everything on this page and tells you exactly what to fix. Written report in 48 hours, €99 per product (excl. VAT).