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e-mail address : enquiry@tid.gov.hk
Ref. : EIC 230/2/12
15 December 2025
Dear Sirs,
Further to Commercial Information Circular No. 870/2019 of 3 December 2019, the European Parliament and the Council of the EU adopted Regulation (EU) 2025/2509 to introduce updated requirements for the safety of toys and to repeal the Directive on the Safety of Toys (Directive 2009/48/EC). Regulation (EU) 2025/2509 was published on 12 December 2025 and can be accessed through the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202502509.
2.In gist, the Regulation introduces stricter control on the use of certain chemical substances in toys, such as endocrine disruptors, skin sensitisers and per- and polyfluoroalkyl substances (PFAS). It also requires manufacturers to carry out a comprehensive safety assessment covering chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazard evaluations before placing a product on the EU market.
3.Moreover, manufacturers will be required to create a digital product passport (DPP) for toys being placed on the EU market to provide information on the toy’s compliance with the Regulation and other relevant data to consumers, market surveillance authorities and customs authorities of the EU. Technical requirements of the DPP shall be in compliance with the subsidiary legislations to be adopted under the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) in due course.
4.The Regulation will enter into force on 1 January 2026 and apply from 1 August 2030. Certain articles of the Regulation concerning the administrative operation of relevant regulatory bodies (Articles 28 to 44 and Articles 49 to 55) will apply from 1 January 2026. The European Commission will provide guidelines on how to set up and operate DPP for toys in accordance with this Regulation to micro, small and medium-sized enterprises by 1 August 2029. Directive 2009/48/EC will be repealed on 1 August 2030.
5.For enquiries concerning the content of this circular, please contact the undersigned at 2398 5684.
Yours faithfully,
(Miss Jenny MOK)
for Director-General of Trade and Industry
* The EU comprises 27 member countries, namely, Austria, Belgium, Bulgaria, Croatia, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.
| Note 1: | While every effort is made to ensure the accuracy of the above information, the Department cannot guarantee this to be so and will not be held liable for any reliance placed on the same. |
| Note 2: | "Regulatory Alert - EU" of the Hong Kong Trade Development Council provides up-to-date information on the latest developments in EU trade policy and trade regulations. It is available at: https://research.hktdc.com/en/regulatory-alerts/eu. |