Compliance Checklist

CE Marking
Toys
France 🇫🇷

Comprehensive compliance checklist for CE marking of toys under Directive 2009/48/EC for the French market. Covers EN 71 standards series, DGCCRF requirements, Loi AGEC, and Citeo registration.

Overview

Toys are among the most heavily regulated product categories in the EU. The Toy Safety Directive 2009/48/EC requires extensive safety testing per the EN 71 standards series and an EU Declaration of Conformity before placing on the market. In France, the DGCCRF (Direction generale de la concurrence, de la consommation et de la repression des fraudes) monitors the market particularly strictly and regularly conducts focused inspections on toys. Additionally, the French Loi AGEC (Anti-Gaspillage pour une Economie Circulaire) requires extended labeling obligations such as the Triman and Info-Tri.

Does this apply to my product?

This checklist applies to all economic operators placing toys (defined as products designed or intended for use in play by children under 14 years) on the French market. Covers plush toys, dolls, board games, electronic toys, outdoor play equipment, craft kits, baby toys, and bath toys. Applies to manufacturers, importers, distributors, and online sellers including marketplace vendors.

Step-by-Step Guide

Progress0/16 (0%)

Determine Toy Classification and Applicable Standards

First verify whether your product falls under the definition of the Toy Safety Directive 2009/48/EC and identify all applicable harmonized standards from the EN 71 series and, if applicable, EN 62115 for electric toys.

Estimated time: 1-3 Tage

Determine age group and toy categoryRequired

Define the intended and reasonably foreseeable age group. The age rating significantly determines applicable test requirements (e.g., stricter small parts test for under 36 months). Use the CEN guide CEN/TR 13387 for age grading.

Identify applicable EN 71 sub-standardsRequired

Determine which parts of the EN 71 series are relevant: EN 71-1 (mechanical/physical), EN 71-2 (flammability), EN 71-3 (migration of certain elements), EN 71-7 (finger paints), EN 71-8 (swings/slides), EN 71-12 (N-nitrosamines), EN 71-13 (board games with odor). For electronic toys, additionally EN 62115 and potentially RED 2014/53/EU.

Check French additional requirements (Decret requirements)Required

France has specific national regulations beyond the EU directive: Decret n 2010-166 on toys and Decret n 2016-1811 on chemical substances in toys. Check whether additional French limits for certain chemicals apply.

Conduct Safety Testing at Accredited Laboratory

Have your toy tested at an accredited testing laboratory according to the identified EN 71 standards. For toys, conformity assessment procedure Module A (internal production control) is generally sufficient, but technical test reports from an accredited laboratory are de facto indispensable.

Estimated time: 3-8 Wochen

Commission accredited testing laboratoryRequired

Commission an ISO 17025 accredited laboratory (e.g., TUeV, SGS, Bureau Veritas, Intertek) for the required EN 71 tests. Ensure the laboratory is accredited for toy testing and send representative product samples.

EN 71-1 test report (mechanical and physical safety)EN 71-2 test report (flammability)EN 71-3 test report (migration of elements)

Ensure chemical conformity (REACH, POPs, phthalates)Required

Ensure compliance with chemical limits of the Toy Safety Directive Annex II Part III: CMR substances, phthalate restrictions (DEHP, DBP, BBP, DINP, DIDP, DNOP), lead, cadmium, and nickel limits, PAH limits, and REACH Annex XVII restrictions.

Chemical analysis report (phthalates, heavy metals, PAH)

Commission EU type-examination (Module B+C) if required

If no harmonized standards cover the full safety aspect, an EU type-examination by a notified body is required. Check whether your toy falls within the scope of Module B+C.

Create EU Declaration of Conformity and Technical Documentation

Create the complete technical documentation and EU Declaration of Conformity per Annex IV of the Toy Safety Directive. These must be kept for at least 10 years after the last placing on the market.

Estimated time: 1-2 Wochen

Create EU Declaration of Conformity (DoC)Required

Create the DoC with: product description and unique identification, manufacturer name and address, reference to Toy Safety Directive 2009/48/EC, applied harmonized standards, notified body number if applicable, signature and date. The DoC must be available in French or translated.

EU Declaration of Conformity (French version)

Compile technical documentationRequired

Compile: product description and photos, design drawings, material list with supplier data, test reports, conformity assessment, safety evaluation with hazard analysis per Annex II, production controls and manufacturing control plan.

Adapt Labeling and Packaging for the French Market

France has particularly strict labeling requirements for toys. Besides CE marking and EU-mandated warnings, the Loi AGEC (Law No. 2020-105) requires additional environmental and disposal markings.

Estimated time: 3-7 Tage

Apply CE marking and mandatory informationRequired

Apply: CE marking (min. 5mm), age warning ('Ne convient pas aux enfants de moins de 36 mois' with pictogram), manufacturer name and address, importer name and address (if applicable), batch/serial number, EAN/GTIN. All information in French language.

Apply Triman logo and Info-Tri sorting instructions (Loi AGEC)Required

Since January 1, 2022, the Triman logo together with the Info-Tri (sorting instructions) must be applied on all packaging sold in France. The Info-Tri must inform consumers about correct disposal of each packaging component. Since 2023, stricter design requirements apply.

Info-Tri graphic per Citeo specifications

Create specific toy warnings in FrenchRequired

Create all product-specific warnings in French: choking hazard ('Attention! Risque d'etouffement - Petits elements'), strangulation risk for cords, water hazards for water toys, speed warnings for vehicles. Use the exact wording from Annex V of the Toy Safety Directive in the French version.

Complete Citeo Registration and EPR Obligations for France

France has one of the most comprehensive Extended Producer Responsibility (EPR) systems in Europe. For toys, at least two EPR categories are relevant: packaging (Citeo) and potentially toys as a separate category (since 2022 under Loi AGEC).

Estimated time: 1-3 Wochen

All companies placing packaged products on the French market must register with Citeo (formerly Eco-Emballages) and pay an eco-contribution based on packaging weight and material. Registration is via citeo.com.

Citeo registration confirmation and UIN (Unique Identification Number)

Check EPR registration for toys with Eco-Mobilier or EcosystemRequired

Since 2022, certain toys may fall under the EPR category 'Jeux et jouets'. Check on the ADEME website whether your toy falls under this category and register with the responsible PRO (Producer Responsibility Organization).

Register in the ADEME SYDEREP portal and obtain a UIN for each EPR category. The UIN must be provided to online marketplaces (Amazon.fr, Cdiscount, Fnac) as they are obligated to verify EPR compliance.

SYDEREP registration with UIN

Ensure GPSR Requirements and Marketplace Compliance

In addition to CE marking, since December 2024, the requirements of GPSR (EU) 2023/988 must be met, particularly designating an EU responsible person and enhanced online information obligations.

Estimated time: 1-3 Tage

Designate EU responsible person and enter in listingsRequired

Designate an EU-based responsible person per GPSR Art. 4 and enter their contact details (name, address, email) in all product listings on Amazon.fr, Cdiscount, and other French marketplaces.

Design product images and listing content GPSR-compliantRequired

Ensure product images show CE marking and warnings. Listings must contain clear age recommendations, safety warnings, and complete contact details of manufacturer/importer/EU responsible person.

Common Mistakes to Avoid

Age rating incorrectly chosen to avoid stricter test requirements

Consequence: The DGCCRF recognizes this practice and can remove the product from the market. Fines up to EUR 1,500 per item (individual) or EUR 7,500 (legal entity) in France. Criminal consequences possible if a child is injured.

Prevention: Use the CEN/TR 13387 guide for realistic age classification and have an age suitability assessment performed by an accredited laboratory if in doubt.

Warnings not in French or incorrect wording

Consequence: Immediate objection during DGCCRF inspection. Product can be seized and removed from sale. Repeated violations lead to increased sanctions.

Prevention: Use exclusively the official French wording from the French version of the Toy Safety Directive. Have all texts reviewed by a native French speaker.

Triman logo and Info-Tri on packaging forgotten

Consequence: Violation of Loi AGEC. Fines up to EUR 100,000 possible. Marketplaces like Amazon.fr and Cdiscount can block offers without EPR proof.

Prevention: Integrate Triman and Info-Tri already in the packaging design phase. Use the free design templates from Citeo and check the current ADEME specifications.

Chemical limits not met (phthalates, lead, PAH)

Consequence: RAPEX/Safety Gate notification, EU-wide recall, criminal charges if children's health is endangered. The DGCCRF conducts annual focus campaigns on chemicals in toys.

Prevention: Have every production batch tested by an accredited laboratory for all relevant chemicals. Request REACH and toy compliance certificates from your suppliers and conduct regular random sample testing.

EPR registration with Citeo or ADEME/SYDEREP missing

Consequence: Sales ban on French marketplaces. Amazon.fr requires the UIN when creating listings since 2022. Fines up to EUR 200,000 for EPR violations.

Prevention: Register early with all relevant PROs (Citeo for packaging, responsible PRO for toys) and proactively provide the UIN to all sales channels.

Frequently Asked Questions

Q1Can I sell toys in France without EN 71 test reports?

Technically, the Toy Safety Directive allows Module A (internal production control), so external test reports are not strictly mandatory. In practice, however, accredited test reports are indispensable: the DGCCRF requests evidence during inspections, marketplaces require them, and without test reports, liability in case of damage is nearly impossible to mitigate.

Q2What is the Triman and when must it appear on toy packaging?

The Triman is a French recycling symbol that must be applied together with the Info-Tri (sorting instructions) on all packaging sold to end consumers in France. Mandatory since January 2022, with specific design requirements since 2023. It replaces the Green Dot, which may no longer be used in France since 2021.

Q3How often does the DGCCRF conduct toy inspections?

The DGCCRF conducts inspections year-round, with focus campaigns before Christmas (October-December). Thousands of toys are tested annually. In recent years, regularly over 15% of tested products were objected to, mainly due to chemical limit exceedances and missing/incorrect labeling.

Q4Do I need separate EPR registration for toys and packaging in France?

Yes, in France, packaging EPR (with Citeo) and product EPR (for the 'Jeux et jouets' category) are separate obligations. You need a separate registration and UIN in the ADEME SYDEREP portal for each category. Contributions are calculated separately.

Q5What additional requirements apply to electronic toys in France?

Electronic toys must additionally be tested per EN 62115 (safety of electric toys). For radio functions (Bluetooth, WiFi), RED 2014/53/EU also applies. Batteries are subject to the Battery Regulation (EU) 2023/1542, in France via Corepile or Screlec as PRO. Additionally, WEEE registration obligations via ecosystem apply.

Q6Can I as a non-EU seller sell toys directly on Amazon.fr?

Yes, but you need: an EU responsible person (GPSR), complete CE documentation, EPR registrations (Citeo + toy PRO) with UINs, French warnings, and Triman/Info-Tri on the packaging. Amazon.fr checks these details and can block offers without complete compliance proof.

CE MarkingToysFrance 🇫🇷