RP16

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Regulation (EU) 2023/988 · Article 16

Toys sit under two regimes at once, and sellers usually satisfy only one.

A toy sold into the Union must meet the Toy Safety Directive and carry CE marking, and it must also have an economic operator established in the Union. Getting the CE part right does not discharge the second obligation.

Enforcement file leading to a product recall — GPSR toys responsible person
Enforcement file leading to a product recall.

Where the two regimes meet

CE marking speaks to whether the product conforms; the responsible person speaks to whether someone in the Union can be reached about it. An authority checking a toy will look for both, and finding one does not excuse the other.

Many sellers assume a CE certificate from the factory covers everything. It does not, and the gap shows up on the marketplace field first.

Why toys are checked more often

Toys are among the most frequently notified product categories in the Union's rapid alert system, so the practical chance of a check is considerably higher than for most goods.

Small parts, magnets, button cells and chemical content drive most of the alerts, which is also where documentation gaps get exposed.

Signing the written mandate for a responsible person — GPSR toys responsible person
Signing the written mandate for a responsible person.

Age marking and warnings

Age grading and the accompanying warnings must be present, legible and in the languages of the markets you sell into. This is the detail that most often turns a routine check into a finding.

It is also the cheapest thing on this page to fix before a production run.

What lands in your inbox

The signed mandate, the label block ready to paste, the certificate and a link that shows your status to anybody who asks for it.

Marketplaces and customs officers do not read attachments. They check a name against a register, which is exactly what we give them.

The check happens without you

By the time an authority or a platform looks at your product, you are not in the room. Whatever you left on the label has to speak for itself.

A resolvable code speaks; a scanned document does not.

Questions we are asked

My factory gave me a CE certificate. Is that enough?

No. CE marking addresses conformity of the product. The responsible person requirement is separate and asks who in the Union can be contacted and hold the file.

Do you take responsibility for the safety of my toy?

No, and no provider honestly can. Safety and conformity remain with the manufacturer. Our obligations are those of Article 16: hold the documentation, cooperate with authorities, inform them of risks.

Are toys treated more strictly than other products?

The legal test is the same, but toys are checked far more often in practice, so weaknesses that stay hidden elsewhere tend to be found here.

With toys the question is not whether a check will come, but whether the file is ready when it does.

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