“Is obtaining CE certification all that is needed for a toy?” Based on NBTS's extensive hands-on compliance experience, the answer is: not necessarily.

Toys intended for different age groups, made from different materials, or featuring different functions and power modes can require very different tests. Ordinary plastic toys, plush toys, electric remote-control toys, and chemistry sets cannot simply share one compliance solution. Applying a one-size-fits-all approach can easily result in listing removal or goods being detained.

01 What Are the Core Requirements for Toys Entering Europe?

During the transition between the old and new rules, sellers must still comply with the current Toy Safety Directive 2009/48/EC and its supporting legislation. At the same time, they should prepare for the new requirements, especially the introduction of the Digital Product Passport and tighter controls on chemical substances.

Before a toy is placed on the EU market, the following work must be completed:

• Conduct a safety assessment covering mechanical, physical, chemical, electrical, flammability, hygiene, and other risks

• Test the product in accordance with the applicable EU harmonized standards

• Prepare and sign an EU Declaration of Conformity (DoC)

• Correctly affix the CE marking to the product or its packaging

• Provide the details of the manufacturer, importer, or EU Responsible Person

• Provide warnings and instructions for use in the local language

The European Commission clearly states that only toys meeting the safety requirements and bearing the CE marking may be placed on the EU market.

One point requires special clarification:

CE compliance is not simply a matter of buying a “CE certificate” from a testing organization.

CE is fundamentally the manufacturer's self-declaration that the product meets applicable EU legal requirements. Laboratory test reports are key technical evidence supporting the CE declaration, but a report alone cannot replace the complete compliance process.

02 What Tests Are Usually Required for Ordinary Toys?

For most toys, the EN 71 series is the starting point, but not every product must be tested against every part of EN 71. The laboratory determines the specific tests based on the toy's materials, construction, age grading, manner of use, and foreseeable risks.

1. EN 71-1: Mechanical and Physical Properties

This is the most common basic toy test and mainly assesses:

• Small parts and choking hazards

• Sharp points, sharp edges, and protruding parts

• Tension, torque, drop, and impact

• Cords, projectiles, and moving parts

• Thickness of packaging film

• Sound pressure levels of sound-emitting toys

• Stability of ride-on or load-bearing toys

•  Risks associated with magnets, springs, folding mechanisms, and similar features

2. EN 71-2: Flammability

• This test mainly examines the flammability and flame-spread rate of toy materials. Common products within its scope include:

• Plush toys

• Children's fancy-dress costumes

• Toys worn on the head

• Toys that children can enter, such as tents and tunnels

• Toys containing textiles, pile, or long-haired materials

Key point: Children's fancy-dress costumes cannot be tested solely as ordinary children's apparel; they must undergo the toy flammability test under EN 71-2.

3. EN 71-3: Migration of Certain Elements

This test controls the risk of heavy-metal migration from accessible toy materials under conditions simulating a child biting or licking the product. It covers paints, plastics, metal parts, coatings, modeling clay, inks, and other materials.

The controlled elements include:

Aluminum, antimony, arsenic, barium, boron, cadmium, chromium(III), chromium(VI), cobalt, copper, lead, manganese, mercury, nickel, selenium, strontium, tin, organic tin, and zinc

Key point: EN 71-3 measures the migration of elements, not their total concentration in the material. For testing, all accessible materials and differently colored parts must be separated. If an accessible component is omitted, the report will not provide complete coverage and may be rejected outright during Amazon's review.

Other Specialized EN 71 Tests

Certain special toy categories require additional, category-specific standards beyond EN 71-1, EN 71-2, and EN 71-3:

• EN 71-4: Experimental sets for chemistry and related activities - Covers chemistry sets and science experiment toys, controlling the toxicity, corrosivity, and reaction risks of experimental substances.

• EN 71-5: Chemical toys other than experimental sets - Covers non-experimental chemical kits, such as crystal-growing and craft crystallization toys.

• EN 71-7: Finger paints - Covers children's finger paints and controls colorants, preservatives, binders, extenders, humectants, surfactants, nitrosamines, and other parameters.

• EN 71-8: Activity toys for domestic use - Covers indoor and outdoor activity toys such as home swings, slides, and climbing frames.

• EN 71-12: N-Nitrosamines and N-nitrosatable substances - Covers elastomer toys such as balloons and teethers and controls the release risk of carcinogenic nitrosamines.

• EN 71-13: Olfactory board games, cosmetic kits, and gustative games - Covers children's makeup kits and smell/taste board games, controlling allergens, microorganisms, and ingredient limits.

• EN 71-14: Trampolines for domestic use - Covers the construction, strength, and protective safety of children's home trampolines.

03 What Additional Tests Are Required for Electric, Remote-Controlled, and Smart Toys?

Toys with batteries, motors, lights, sounds, charging, or wireless communication functions generally require more than EN 71 testing.

Electric Toy Safety Testing

For toys with batteries, motors, lights, sounds, charging, or wireless communication functions, the EN 71 series alone is insufficient for EU compliance. Testing against the dedicated safety standard for electric toys must also be added.

The current EU compliance standard is EN IEC 62115:2020+A11:2020. It has been formally included among the EU harmonized standards and is a core review basis for Amazon Europe listings and customs clearance of electric toys. It focuses on electrical safety, temperature-rise protection, optical radiation, charging protection, and other key risks:

Battery Compartment and Button-Cell Protection: Strictly controls accessibility risks involving button cells. Battery compartments on high-risk toys must require a special tool or two independent actions to open, preventing children from removing or swallowing batteries. Structural security is also tested, and screws must not loosen or detach under a 20 N force.

Temperature Rise and Abnormal-Operation Testing: Simulates normal operation and abnormal conditions such as overload and stalling to determine whether the enclosure, motor, or wiring exceeds temperature limits, helping prevent burns and fire. The test criteria distinguish between self-resetting and non-self-resetting thermal control devices.

Electric Strength and Insulation Protection: Evaluates the voltage-withstand performance of insulating materials to prevent leakage current and electric shock, with requirements adapted to electric toys of different voltage and current ratings.

Charging and Short-Circuit Risk Control: Adds dedicated charging tests for USB-charged toys and toys with built-in rechargeable batteries, covering overcharging, short circuits, reverse charging, and other abnormal conditions to prevent charging fires and battery swelling.

Wiring and Critical-Component Safety: Examines internal wire routing, securing strength, switches, and motor durability and safety to prevent accidents caused by loose wiring, short circuits, or component failure.

Optical-Radiation Hazard Control: Focuses on toys using LEDs and other light sources, adding optical-radiation test procedures to prevent harm to children's vision from intense light or ultraviolet radiation.

Heat and Fire Resistance: Non-metallic and insulating materials around electrical components must pass ball-pressure, glow-wire, and needle-flame tests to ensure they resist ignition and deformation under high temperatures and abnormal conditions.

Category-Specific Requirements: Covers special categories such as suspended sound-and-light toys, electric aquatic toys, electric ride-on toys, and electric toys connected to external equipment, with additional category-specific safety clauses.

Common Pitfall for Sellers: Most listing removals and customs detentions involving electric toys result from completing only basic EN 71 testing while omitting the dedicated EN IEC 62115 electric-toy tests. During the transition between the old and new standards, platform scrutiny of this requirement continues to tighten, so the complete set of applicable tests is essential.

Final compliance note: The regulatory and standards information in this article is current as of August 2026 and applies to the transition between the old and new EU toy rules. Based on the seller's actual product, functional parameters, and target Amazon marketplace, NBTS can provide one-to-one guidance on the applicable legislation and test items, helping avoid duplicate testing, inconsistent documentation, requests for additional listing materials, and customs detention.