Independent Toy Safety Directive
Representation
EU Authorized Representative for Products under the EU Toy Safety Directive (2009/48/EC)
The Toy Safety Directive 2009/48/EC(TSD) establishes safety requirements for toys sold in the European Union. The directive aims to ensure that toys placed on the market do not present risks to children’s health or safety during normal or reasonably foreseeable use.
Non-EU manufacturers placing toys on the EU market must appoint an EU-based Authorized Representative to support documentation access and cooperation with EU Market Surveillance Authorities. EARP acts as your Authorized Representative under the Toys Directive, ensuring that your formal EU representation obligations are fulfilled.
Scope of the EU Toy Safety Directive
The TSD applies to products designed or intended for use in play by children under the age of 14.
This includes traditional toys as well as a wide range of modern or novelty products marketed to children, regardless of whether they are sold online or through traditional distribution channels.
The TSD sets strict safety requirements to protect children from hazards and focuses on:
mechanical and physical safety
chemical properties and material composition
flammability and electrical safety (where applicable)
appropriate warnings and age grading
Manufacturers must perform a safety assessment identifying potential hazards associated with the toy and demonstrating that the product meets the directive’s safety requirements.
Frequent Compliance Issues and Related Safety Risks
Toys are among the most frequently recalled products in the EU due to safety hazards affecting children.
Small Parts Choking Hazard
Small detachable parts may pose choking risks for young children if they become separated during use.
Chemical Exposure
Certain toy materials may contain restricted chemicals such as phthalates, heavy metals, or other hazardous substances.
Sharp Edges or Points
Poorly designed toy components may cause cuts or injuries during normal use.
Projectile Hazards
Toy weapons or projectile-launching toys may cause eye or facial injuries if improperly designed.
Inadequate Age Warnings
Incorrect or missing age warnings may result in toys being used by children younger than intended.
The Role of the Authorized Representative under the TSD
Under the TSD, the Authorized Representative acts on behalf of the manufacturer for defined administrative and regulatory tasks. These tasks ensure that EU authorities can identify a responsible EU contact and access the required compliance documentation when needed.
The Authorized Representative must be able to provide technical documentation and the EU Declaration of Conformity upon request. The AR further must cooperate with EU Market Surveillance Authorities, and support investigations or corrective actions in case of suspected non-compliance.
Appointing a dedicated Authorized Representative ensures that these obligations are met without transferring regulatory responsibility to importers, distributors, or retailers.
EARP’s Role as Authorized Representative
Your Official EU AR for Compliance under the TSD
EARP acts as an independent EU Authorized Representative for manufacturers placing toys on the European market under the TSD.
We ensure that your company fulfills the administrative and communication duties required under the TSD. As your EU AR, we will:
Being identified on product labeling or packaging as your EU contact
Holding and providing Declarations of Conformity and technical documentation upon request
Forwarding authority requests and supporting responses to compliance inquiries
Maintaining documentation access for the legally required period
Cooperating with EU authorities in case of toy safety investigations or enforcement actions
Independent and compliance-focused
EARP operates as an independent Authorized Representative and does not participate in the import, distribution, or commercial sale of products. This independent structure prevents conflicts of interest and ensures that regulatory communication remains focused on compliance representation.
We have 25+ years of experience with European Authorized Representative services, focused exclusively on fulfilling the administrative and regulatory functions required under EU product safety law.
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