Ensuring the safety of toys sold in the EU increasingly depends on robust chemical oversight. With the entry into force of the new EU Toy Safety Regulation (TSR) on 1 January, the European Chemicals Agency (ECHA) has assumed expanded responsibilities that will significantly shape how chemical risks in toys are assessed and managed.
The Toy Safety Regulation aims to strengthen protections for children by introducing stricter standards for chemical safety, enhanced product transparency, and increased digital accountability for toys sold both online and in physical stores across the EU.
What’s Changed: ECHA’s New Responsibilities
Under the Toy Safety Regulation, ECHA will work closely with the European Commission to:
- Conduct chemical safety assessments of substances used in toys at the request of the Commission, supported by expert opinions from the Committee for Risk Assessment (RAC)
- Evaluate derogation requests from companies seeking permission to use substances otherwise prohibited under the Regulation
- Provide assessments for derogations through both RAC and the Committee for Socio-Economic Analysis (SEAC)
Through these activities, ECHA will contribute directly to determining whether specific chemical uses in toys can be considered acceptable under the new regulatory regime.
Why This Matters
These changes represent a meaningful shift in how chemical risks in toys are assessed and governed in the EU.
For manufacturers, importers, and supply-chain actors, the Regulation introduces:
- Increased scrutiny of chemical composition
- Higher expectations for scientific justification where derogations are sought
- A clearer role for expert committee opinions in regulatory outcomes
For regulators and policymakers, ECHA’s involvement ensures that decisions are underpinned by rigorous, transparent scientific evaluation, supporting consistent protection of children’s health across the EU.
Practical Considerations for Industry
Organisations involved in the manufacture or placing on the market of toys should consider:
- Whether substances used in products fall within newly restricted categories
- The potential need to prepare robust derogation dossiers, including hazard, exposure, and socio-economic justifications
- How internal data, testing strategies, and supply-chain communication support regulatory defensibility
- Early engagement with regulatory expertise to anticipate assessment expectations under RAC and SEAC review
Proactive planning will be particularly important where legacy substances or complex formulations are involved.
Deenamic Insight
Experience across EU regulatory frameworks shows that early, well-structured engagement with evolving requirements significantly reduces downstream risk. As ECHA’s role under the Toy Safety Regulation develops, organisations that align scientific, regulatory, and strategic considerations from the outset will be best positioned to maintain compliance and continuity of supply.
According to the European Chemicals Agency, “ECHA’s new responsibilities require us to perform rigorous scientific assessments and provide clear advice on the safe use of chemicals in toys. Through this work, we will contribute to the protection of children’s health across the EU.”
— Peter van der Zandt, Director for Risk Management, ECHA
(Helsinki, 7 January 2026)
The Toy Safety Regulation marks an important step in strengthening chemical safety governance for children’s products in the EU. With ECHA now playing a central role in scientific assessment and derogation evaluation, clarity, preparedness, and sound regulatory strategy will be key for organisations navigating this evolving landscape.
If you would like to discuss how these developments may affect your products or regulatory strategy, get in touch to start a conversation.
You can contact us for a preliminary consultation at info@deenamicltd.com or use the form below.
