Educational toys, STEM kits and electronic toys

• Directive 2009/48/EC — Toy Safety
• Directive 2014/53/EU where connected
• Regulation (EU) 2016/679 — GDPR for connected toys
• Regulation (EU) 2023/1542 — Batteries
• Regulation (EU) 2024/2847 — CRA

Who has to appoint one

Manufacturers and sellers outside the Union placing educational and electronic toys on the EU market. Connected toys with microphones or cameras process children's data, which brings the strictest data protection expectations in the Union.

Thresholds and exemptions

None. Button cell batteries in electronic toys have specific accessibility requirements after ingestion incidents.

What must appear on the label

CE marking, manufacturer and EU representative details, age marking, batch identification, the Annex V warnings, battery markings and, for connected toys, the data protection information for parents.

Marketplace fields

Connected toys have been banned in some member states where they functioned as covert listening devices, and marketplaces remove toys whose companion apps lack privacy documentation.

Documentation you must hold

Safety assessment, technical documentation, EN 71 test reports, radio documentation for connected models, battery documentation, and on the data side the Article 30 record, the Article 27 designation, parental consent mechanics and a data protection impact assessment.

Standards and testing

EN 71-1 mechanical including button cell accessibility, EN 71-3 migration, EN 62115 for electric toys, radio testing for connected models, and cybersecurity assessment under EN 18031 where the toy connects.

Language requirements

Warnings, instructions and parental information in the language of each member state of sale.

When it applies

Before placing on the market. CRA obligations for connected toys from 2026 and 2027.

How long records are kept

Ten years for the toy documentation. Children's data minimised and deleted promptly.

What happens if you do not comply

Withdrawal and Safety Gate alerts for the product, and data protection fines for the app. Connected toys that record children without adequate safeguards have been prohibited outright in some member states.

Who enforces it

Market surveillance authorities, data protection authorities and radio regulators.

Where the boundary lies

Button cells are the most acute physical hazard: ingestion causes severe internal burns within hours, and the accessibility requirements are strictly enforced. Voice-controlled toys are simultaneously radio equipment, toys and data processing operations involving children.

Questions we are asked

Are connected toys allowed?

Yes if they meet the toy, radio and data protection requirements. Toys that transmit audio without adequate security or parental control have been banned as covert listening devices.

What are the button cell rules?

Battery compartments must require a tool to open or resist opening, and the warnings are mandatory, following a series of ingestion injuries.