Compliance Checklist
CE marking for toys on Amazon.de: Toy Safety Directive 2009/48/EC, EN 71 tests, warnings and common mistakes.
Overview
Toys are among the most strictly regulated product categories in the EU. The Toy Safety Directive 2009/48/EC makes CE marking mandatory for every toy on Amazon.de. Tests according to EN 71 (mechanical/physical, flammability, chemical properties) are extensive and expensive – but without them, no toy may be sold in the EU. Amazon monitors this category particularly strictly.
Does this apply to my product?
The Toy Safety Directive applies to all products designed for children under 14 to play with. This includes: classic toys, dolls, board games, puzzles, outdoor toys, bath toys, educational toys, craft sets, remote-controlled vehicles and electronic toys. NOTE: Products not intended as toys but that could be used by children as toys (e.g. animal-shaped keychains) may also fall under the directive.
Step-by-Step Guide
Toy requirements vary significantly by age group. Toys for children under 36 months have the strictest requirements (choking hazard, swallowable parts).
Estimated time: 1 Tag
Target age group defined and documentedRequired
Define the age group: under 36 months, 3-6 years, 6-14 years. The age indication determines which tests are required and which warnings must be on the packaging.
Applicable EN 71 parts identifiedRequired
EN 71 consists of 14 parts. At least EN 71-1 (mechanical/physical), EN 71-2 (flammability) and EN 71-3 (migration of certain elements) are required for almost every toy. Depending on type additionally: EN 71-7 (finger paints), EN 71-8 (swings/slides), EN 71-12 (N-nitrosamines).
The EN 71 test series is the core of toy CE marking. Without passed tests, no CE mark.
Estimated time: 3-8 Wochen
EN 71-1: Mechanical and physical properties testedRequired
Tests: swallowable small parts (Small Parts Test), tensile strength, drop test, compression tests, edge sharpness, tip test. Particularly strict for toys for children under 36 months.
EN 71-2: Flammability testedRequired
Tests the burning behavior of toy materials. Particularly relevant for textile toys, costumes, wigs, tents. The material must not burn like a flame.
EN 71-3: Migration of chemical elements testedRequired
Tests whether hazardous elements (lead, cadmium, chromium, barium etc.) are released from the toy. Separated by material type: Category I (dry), II (liquid), III (scraped). Limits in Annex II of the Toy Safety Directive.
Further applicable EN 71 tests performed
Depending on toy type: EN 71-7 (finger paints), EN 71-8 (activity toys for domestic use), EN 71-12 (N-nitrosamines in elastomers), EN 71-13 (olfactory games, gustatory games, cosmetic kits).
The complete technical documentation is particularly extensive for toys and must be kept for 10 years.
Estimated time: 3-5 Tage
Technical documentation completeRequired
Must contain: product description with photos, material specifications, manufacturing process, list of applied standards, all test reports, risk assessment, declaration of conformity, sample of packaging and warnings.
EU Declaration of Conformity issuedRequired
The DoC for toys must explicitly reference Directive 2009/48/EC and list all applied EN 71 standards with version numbers.
Toys have the most extensive labeling obligations of all product categories. Missing warnings are one of the most common reasons for listing suspensions on Amazon.de.
Estimated time: 2-4 Tage
CE mark correctly applied (min. 5mm, on product or packaging)Required
The CE mark must be visibly and permanently affixed to the toy or packaging. For very small toys, placement on the packaging or a label is permitted.
Age warning correct and in German languageRequired
Standard warning: 'WARNING! Not suitable for children under 36 months. Choking hazard – small parts.' The warning symbol (black triangle with exclamation mark) is mandatory. The warning must be visible BEFORE purchase – also in the Amazon listing.
Manufacturer information on packaging (name, address, email)Required
Name or trade name, postal address and email of the manufacturer must be on the toy or packaging. For imports, additionally the importer's data. Since GPSR (Dec. 2024), email address is also mandatory.
Batch/model number on productRequired
Each toy must bear a type, batch, serial or model number enabling identification and traceability.
Amazon monitors the toy category particularly strictly. Ensure all compliance information is correctly stored in the listing and Seller Central.
Estimated time: 1-2 Tage
Compliance documents uploaded to Seller CentralRequired
Upload DoC, EN 71 test reports and photos of labeling to Amazon Seller Central. Amazon can request these at any time – for toys this happens more frequently than for other categories.
Listing updated with warnings and GPSR fieldsRequired
Mention age warnings in bullet points, GPSR mandatory fields (responsible person, manufacturer) filled in, safety instructions integrated in A+ Content.
Common Mistakes to Avoid
Declaring the product as 'decoration' instead of 'toy' to avoid the Toy Safety Directive
Consequence: Classification is based on USE, not declaration. If a product is obviously used by children as a toy, the Toy Safety Directive applies regardless. High fines and Amazon account suspension.
Prevention: Classify honestly. If children could play with it, it's probably a toy. When in doubt, consult TUeV or a Notified Body.
Only testing EN 71-1 and forgetting the chemical tests (EN 71-3)
Consequence: Incomplete CE marking. Chemical tests are critical especially for imported toys – heavy metals and prohibited plasticizers are regularly found. Recall and RAPEX notification.
Prevention: ALWAYS have at least EN 71-1, EN 71-2 and EN 71-3 tested. For textile toys additionally REACH/azo dyes. Costs are manageable compared to recall risk.
Age warning missing or only in English
Consequence: Immediate listing suspension on Amazon.de. The age warning must be in the language of the target country (German) on the packaging. Amazon additionally requires it in the listing.
Prevention: Apply age warning in German on packaging: 'WARNUNG! Nicht fuer Kinder unter 36 Monaten.' plus specific reason (e.g. 'Erstickungsgefahr – Kleinteile'). Also mention in Amazon listing.
Accepting test reports from Chinese supplier without verification
Consequence: Falsified or insufficient test reports are widespread for toys from China. Market surveillance (in DE: BAuA, state authorities) conducts regular spot checks.
Prevention: Have critical tests (at least EN 71-3 chemistry) repeated in an EU-accredited laboratory. Cost: 500-1,500 EUR – a fraction of the recall risk.
Frequently Asked Questions
For EN 71-1 (mechanical), one test per basic design is usually sufficient. For EN 71-3 (chemical migration), EACH color must be tested separately as different color pigments can have different heavy metal concentrations. For EN 71-2 (flammability), it depends on the material.
In addition to the Toy Safety Directive: (1) Battery Directive 2006/66/EC – battery compartment must be child-safe (screw instead of clip for button cells). (2) For button cells: special warnings about swallowing hazard. (3) BattG in Germany: registration with Stiftung GRS Batterien. (4) WEEE registration with Stiftung EAR required.
Most common reason: missing or incomplete compliance documents. Steps: (1) Check in Seller Central which documents are specifically requested. (2) Upload DoC and EN 71 test reports. (3) Ensure warnings are in the listing. (4) Fill in GPSR mandatory fields. (5) Submit appeal with all documents. Processing time: 3-14 days.
For a single plush toy: approx. 1,000-3,000 EUR. Breakdown: EN 71-1 mechanical (300-500 EUR), EN 71-2 flammability (200-400 EUR), EN 71-3 chemistry (500-1,500 EUR depending on number of materials/colors), documentation (300-500 EUR). For multiple variants, cost per unit can decrease significantly.
The new Toy Safety Regulation (EU) 2024/XXXX was adopted in 2024 but has a transition period until approximately 2027. Until then, Directive 2009/48/EC continues to apply. The new regulation particularly tightens chemical requirements (endocrine disruptors) and introduces a digital product passport. Start preparing now.