80% of toys from online marketplaces fail EU safety standards.
This finding from Toy Industries of Europe is a warning bell for every business in the toy supply chain. It’s one of the reasons that European Union lawmakers have introduced the most significant overhaul of product safety regulations in two decades.
The General Product Safety Regulation (GPSR), which took effect in December 2024, is increasing accountability in the toy industry. As toys are frequently recalled on safety grounds, GPSR aims to address safety issues by introducing more rigorous requirements throughout the supply chain.
For companies that manufacture, import, distribute or sell toys in the EU, GPSR requirements touch every aspect of operations – from design and production to marketing and customer support.
What is GPSR?
GPSR is a set of mandatory rules for consumer products sold or made available on the EU market.
Introduced in 2024, it marks the first major update to European safety laws in twenty years, incorporating new considerations such as the impact of AI and cybersecurity on product quality and safety.
For general information on GPSR, check out our blog post on new EU product safety rules.
How does GPSR affect toy manufacturers?
Toys sold in Europe are already subject to specific safety requirements under the EU Toy Safety Directive. This regulation was recently updated to ban carcinogenic compounds, endocrine disruptors, respiratory irritants and PFAS chemicals in toys.
GPSR carries additional obligations for toy manufacturers, importers and distributors to ensure high levels of product safety. These include:
Conducting a comprehensive risk analysis
To meet GPSR requirements, companies must analyse hazards associated with their products to mitigate potential risks. For toy manufacturers, this could include:
- Physical risks (small parts, sharp edges)
- Chemical risks (toxic substances)
- Electrical risks (for electronic toys)
- Flammability risks
- Hygiene risks
- Cybersecurity risks (for connected toys with digital features)
- AI-related risks (for toys with smart or interactive features)
Risk assessments should cover the entire lifecycle of the toy, from design to disposal.
Creating detailed technical documentation
GPSR requires economic operators to maintain thorough technical documentation for each product and keep it accessible to authorities for ten years after market placement.
For toy manufacturers, this documentation typically includes:
- Product specifications
- Safety assessment results
- Test reports
- Material safety data sheets
- Manufacturing controls
- Cybersecurity protocols and data protection measures (for connected toys)
Enhancing product marking for traceability
GPSR mandates that products sold in the EU include clear and permanent markings that enable product traceability. For toy manufacturers, these markings could include:
- Product type and model number
- Batch or serial number
- Barcode or QR code for digital tracking
- CE marking (where applicable under the Toy Safety Directive)
All toys must also be accompanied by clear assembly and use instructions, age suitability warnings, and specific hazard warnings, e.g. risk of choking. For electronic or connected toys, manufacturers need to include information about battery handling and data protection where applicable.
Listing contact information
Manufacturers must include their full contact details on the toy or its packaging, including the company name, registered trade name or trademark, postal address and electronic contact information (email/website).
If the manufacturer is not established in the EU, the name and contact details of their responsible EU representative, such as Hooley Brown, must also be included.
Maintaining an internal register of complaints and recalls
To meet GPSR regulation, toy manufacturers must also implement systems to record all safety-related complaints.
Key requirements include documenting any product recalls or corrective actions, tracking affected products still in the market, and analysing safety incidents to prevent recurrence.
Are there separate GPSR requirements for toy distributors?
Distributors have their own set of obligations under GPSR that align with manufacturer requirements. These include:
Verification responsibilities
Distributors must verify that:
- Toys are carrying the required markings and labelling outlined in the manufacturer requirements
- Safety information is included in appropriate languages
- Products show no visible signs of non-compliance
- The manufacturer and importer (if applicable) have met their obligations
Failure to meet these responsibilities can result in significant penalties. Additionally, distributors may be held liable for damages caused by non-compliant products they've placed on the market.
Due diligence requirements
Under GPSR, toy distributors must ensure proper storage and transport conditions, randomly checking product safety. They also need to maintain records of suppliers and customers for traceability and cooperate with authorities in case of safety issues.
If a distributor becomes aware of a safety issue, they need to:
- Immediately inform the manufacturer or importer
- Help implement corrective measures
- Notify relevant authorities if necessary
Does GPSR affect online toy retailers?
Online marketplaces and retailers selling toys in the EU must now take more responsibility for product safety. This includes verifying GPSR compliance before listing products and having systems in place to quickly remove unsafe toys from sale.
What are the main GPSR compliance challenges for EU toy companies?
While the introduction of GPSR aims to enhance consumer safety and build trust in the EU toy market, it creates several operational hurdles that companies must navigate.
From documentation to representation requirements, manufacturers, importers, distributors and retailers need to develop strategies for maintaining market compliance.
Two key challenges stand out for businesses selling toys in Europe:
Finding an EU Authorised Representative
Companies selling into the EU that are not based in the EU must appoint an authorised representative. Finding a suitable partner who understands both GPSR and toy-specific regulations can be challenging.
Coordinating with the Toy Safety Directive
Companies must navigate the interplay between GPSR and the recently updated Toy Safety Directive, ensuring compliance with both regulatory frameworks.
GPSR toy compliance: Hooley Brown can help
Hooley Brown specialises in helping consumer goods companies (including toy manufacturers and distributors) navigate complex regulatory requirements across international markets.
We can act as your authorised EU representative, fulfilling all legal obligations and serving as your point of contact with EU authorities.
Our European compliance specialists can help you create and maintain the technical documentation required under GPSR, including product specifications, risk assessments and safety testing documentation.
We are also experts in product labelling and packaging, offering clear guidance on correctly marking your toys with all required traceability and safety information.
Don't risk non-compliance penalties. Contact Hooley Brown for your GPSR assessment.
