2026-11-04

CE marking of toys: declaration, technical file, warnings and labels

CE marking on a toy is the manufacturer’s declaration that the toy meets the EU Toy Safety Directive, backed by an EU declaration of conformity, technical documentation, test reports and correct warnings and labels. The marking itself is short, but it stands for that chain of documents; here is what sits behind it and what to check as importer, distributor or private-label buyer.

What the CE marking means on a toy

Under the Toy Safety Directive 2009/48/EC, the CE marking shows that the manufacturer has assessed the toy and declares that it meets the essential safety requirements. It is not a quality mark and it is not issued by an authority. The manufacturer affixes it, and the manufacturer is responsible for it.

The Directive covers products designed or intended for play by children under 14. If a product is a toy, it needs the CE marking before it is placed on the EU market. If it is not a toy, it must not carry a toy CE marking for appearances. That line matters for products such as kids’ backpacks, purses and decorations, which we come back to below.

The chain behind the mark

  • Safety assessment. The manufacturer analyses the chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazards the toy may present, and how children are likely to use it.
  • Conformity assessment. For most toys this is internal production control, using harmonised standards such as the EN 71 series. Where standards are not applied in full, an EU-type examination by a notified body is needed.
  • Technical documentation. The file that proves it: description, design and manufacture, the safety assessment, test reports, addresses of manufacturing sites.
  • EU declaration of conformity. A signed statement that the toy meets the requirements, with the standards applied.
  • CE marking and labels. Applied to the toy, a label or the packaging.

The manufacturer keeps the technical documentation and the declaration for ten years after the toy is placed on the market. The importer keeps a copy of the declaration for the same period and must be able to make the technical documentation available to authorities on request.

What a declaration of conformity should contain

A useful declaration is specific. Check that it includes:

  • a unique identification of the toy: model, item number, batch or type, and ideally a photo;
  • the name and address of the manufacturer;
  • a statement that the declaration is issued under the sole responsibility of the manufacturer;
  • the legislation it refers to, at least the Toy Safety Directive, and other rules where relevant;
  • the harmonised standards applied, with editions, for example parts of EN 71;
  • where a notified body was involved, its name, number and certificate reference;
  • place, date, name and function of the signatory, and the signature.

Declarations covering “all our toys” or listing standards that have nothing to do with the product are a reason to ask again. The declaration should be available in, or translated into, the language required by the country where the toy is sold.

The importer’s checklist

Before a toy goes on the market, an importer checks that the manufacturer did its part. Our working list per item:

CheckWhere
Declaration of conformity matches the itemDocument
EN 71 reports cover the parts that apply and the right productDocument
CE marking is visible, legible and indelibleToy, label or packaging
Type, batch or serial number allows identificationToy or packaging
Manufacturer’s name and postal addressToy or packaging
Importer’s name and postal addressToy or packaging
Age grade and warnings in the language of the country of salePackaging, instructions
Instructions and safety information in that languageLeaflet or packaging
REACH declarations where the material requires themDocument

If the CE marking on a small toy cannot be seen through the packaging, it must also be on the packaging. For very small toys and toys sold loose, information can go on a label or accompanying document; check that it actually reaches the end customer.

Warnings and labels

Warnings must be clearly visible and legible, and placed so that the buyer sees them before purchase where they decide whether to buy. That is why age warnings belong on the outside of the box, not in the leaflet. Warnings begin with the word “Warning” or its translation. Specific warnings apply to certain toy types, such as toys not intended for children under 3, activity toys, aquatic toys and toys contained in food. We cover them in our guide to age grading and warnings.

If you sell in several countries, plan multilingual boxes or stickers from the start. Stickers placed after import are acceptable when they are durable and complete, but they cost time.

Private label: who is the manufacturer?

If you put your own name or trade mark on a toy, you are treated as the manufacturer for that toy, with the manufacturer’s obligations: the declaration in your name, access to the technical documentation and responsibility for the CE marking. This is the point many brands miss when they start with private label. We help you build the file from the factory’s documents, and we check labels and warnings for each country. Our private label page shows how we work.

Products on the borderline

Not every product for children is a toy. A school backpack, a coin purse or a beach bag is usually a consumer product under the General Product Safety Regulation (EU) 2023/988, not a toy. A plush backpack or a plush purse designed so that children play with it can be a toy. We check these case by case and label them accordingly. We never present a toy as a non-toy to avoid the rules, and we do not suggest removing a warning or an age grade.

Looking ahead

A new EU Toy Safety Regulation was adopted in 2025 and will replace the Directive after a transition period. It brings, among other things, a digital product passport and stricter chemical rules. We follow the transition to the new Toy Safety Regulation and will update documents and labels as it applies. For now, the checklist above remains the basis for each order.

Toys are supplied with the manufacturer’s EN 71 test reports on request, and we check the documents before shipment. See our toy safety page for the full approach.

Frequently asked questions

Who is allowed to put the CE marking on a toy?

The manufacturer, or its authorised representative, after the conformity assessment. If you sell a toy under your own brand, you take on the manufacturer’s role and are responsible for the CE marking on that toy.

Does the importer need its own declaration of conformity?

No. The importer keeps a copy of the manufacturer’s declaration and must be able to provide the technical documentation to authorities on request. The importer also adds its own name and address to the toy or packaging.

Can the CE marking be only on the toy’s packaging?

Yes, it may be affixed to the toy, a label or the packaging. If it is on the toy but not visible through the packaging, it must also appear on the packaging.

Do kids’ backpacks need CE marking?

Usually not, because a backpack is not a toy and the Toy Safety Directive does not apply. General product safety rules apply instead. Plush backpacks designed for play can be borderline and we check them case by case.

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What happens next

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  3. 3
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