EU Responsible Person & Authorized Representative for Toys
Ensure your toys meet EU safety and labeling rules with EARP’s expert Authorized Representative services for the European market.
Sell toys safely in the EU
Toys are among the most tightly regulated consumer products in the EU due to their use by children and the potential for serious safety risks. These risks include choking hazards, toxic substances, sharp edges, and misuse injuries if not properly designed, labeled, or documented.
Most toys sold in the EU must carry CE marking under the Toy Safety Directive 2009/48/EC and complete a toy safety assessment, keep technical documentation, affix CE marking and provide an EU Declaration of Conformity accordingly. However, the General Product Safety Regulation (EU) 2023/988 (GPSR) also applies, adding requirements for labeling, traceability, post-market surveillance, and a designated EU Responsible Person (RP).
It requires structured safety documentation presented in a technical file with clear age suitability labeling, and defined responsibilities for reporting and regulatory inquiries. All must be considered to maintaining access to the European market and avoiding customs blocks or online delistings.
What is required?
Under the Toy Safety Directive, you must create and maintain a technical file that explains the design, hazards and mitigations, supported by relevant tests/standards. Core harmonised standards for conformity (commonly EN 71-1 mechanical/physical, EN 71-3 migration of elements, and EN IEC 62115 for electric toys) must be applied before affixing the CE Mark. Then, you must draw up the EU DoC, and apply correct age grading and warnings.
What authorities expect
Reviewers look for a coherent safety story supported by a documented risk analysis. For toys this usually means: secure assemblies that don’t create small parts, correct age grading and warnings that match hazards, migration results to EN 71-3, and for electric toys, thermal/abnormal use evidence and robust battery/charging notes. If a serious risk or accident occurs, notify without undue delay via the Safety Business Gateway.
What products are covered?
The Toy Safety Directive defines a toy as any product designed or intended (even if not exclusively) for play by children under 14 years old. Examples of toys that may fall under this directive and GPSR requirements include:
Stuffed animals, dolls, and plush toys
Creative kits and role-play sets
Puzzles, games, and logic toys
Miniature vehicles and play figures
Outdoor and ride-on toys for children
Bath toys and stacking or nesting sets
All toys sold in the EU must be safe under normal and foreseeable conditions of use, with compliant labeling for age suitability, warnings, and safe instructions.
Relevant legislation
Disclaimer: This list is not exhaustive and may not apply to all products; manufacturers must identify all applicable EU requirements.
Do you need an EU Authorized Representative?
Yes. If you are a non-EU manufacturer and none of your partners formally accepts the role of Responsible Person, you must appoint an Authorized Representative in the EU. This obligation is set out in Article 10 of the GPSR and is particularly strict for toys due to their safety-critical nature.
Appointing an AR is essential for managing regulatory expectations, meeting labeling and traceability requirements, and maintaining uninterrupted sales channels. Without an AR, your toys may be blocked at customs, delisted from online marketplaces, or trigger enforcement action by EU market surveillance authorities, all of which can damage your brand and sales.
We can act as your Authorized Representative and your EU-based Responsible Person. Find out who we are.
Helpful ArticleWhy choose EARP as your EU Representative
EARP understands the unique safety, documentation, and compliance challenges facing toy manufacturers selling in the EU. Our services include:
- Acts as your legal EU contact point for authorities and consumer safety inquiries
- Verifying technical documentation, declarations of conformity, and age suitability labeling are complete and accessible
- Ensuring AR contact details are properly listed on packaging or instruction leaflets for toys
- Reviewing consumer complaints or safety events submitted through our platform
- Managing mandatory safety notifications to authorities if the manufacturer fails to act
- Providing templates and guidance materials to support minimum GPSR compliance documentation upon request
Read more about EARP’s Representation services.
We provide these services independently from your importer or distributor, ensuring flexible compliance support while you maintain control over your distribution strategy.
FAQs – Toys
Yes. CE marking under the Toy Safety Directive is essential for demonstrating conformity, but GPSR obligations — such as labeling, traceability, and Responsible Person designation also apply to toys sold in the EU.
Online sales are fully covered by the GPSR. If your distributor or fulfillment provider does not formally assume the RP role, you are required to appoint an AR.
Technical documentation, declarations of conformity, age suitability statements, clear labeling, and safe use instructions as required under GPSR Article 9(2).
Toys are highly prioritized by EU market surveillance authorities. Products lacking proper documentation or labeling risk being blocked at customs, removed from platforms, or triggering fines.
The manufacturer is responsible, but the AR must verify that labeling, traceability, and documentation meet GPSR and Toy Safety Directive requirements.
