The European standardisation organisation CEN develops the EN 71 parts. Under the Toy Safety Directive 2009/48/EC, a toy may only be sold in the EU with a CE marking, and the manufacturer shows compliance in one of two ways: self-verification against harmonised standards such as EN 71, or an EC-type examination by a notified body. Source: the European Commission’s page on toy safety.
What EN 71 Covers
EN 71 is split into parts. The Commission’s overview of harmonised standards for toys lists Part 1 on mechanical and physical properties, Part 2 on flammability and Part 3 on the migration of certain elements, next to parts for chemistry sets, finger paints, activity toys for home use and N-nitrosamines.
For merchandise, the first three parts are usually the relevant ones. A plush mascot, for example, is assessed for its mechanical and physical properties, for how its materials burn and for which elements can migrate from them. Which parts and which edition apply to a specific product is a question for an accredited test laboratory, and the Commission’s list marks some editions with restrictions.
When Merchandise Counts as a Toy
A toy is any product designed or intended, whether or not exclusively, for use in play by children under 14. The words “whether or not exclusively” matter for merchandise: a product with another function, such as a keyring or a fridge magnet, can still be a toy if it has play value.
The Commission’s Guidance Document No 20 on decorative products and products for collectors gives the criteria. Soft filling, a three-dimensional shape, suitability for cuddling and easy handling point towards a toy; fragile materials, a flat shape, low play value and a weight or size that makes handling hard point away from it.
Its examples are close to a club range. A panda bear attached to a key ring is a toy, a flat key ring is not; a three-dimensional fridge magnet with play value is a toy, a flat one is not; a plush souvenir figure is a toy. By the same criteria a plush mascot is a toy whoever buys it, while a flat enamel pin sits closer to the flat key ring; the guidance does not name pins, so that last point is our reading.
The 14+ Collector Label
The directive excludes products for collectors, provided the product or its packaging carries a visible and legible indication that it is intended for collectors aged 14 and over. The guidance gives detailed and faithful scale models and their kits, folk dolls and decorative dolls, historical replicas of toys and reproductions of real firearms as examples.
A label does not decide the question on its own. The guidance says the reasonably foreseeable use prevails over the use the manufacturer declares, and that marking a product “This is not a toy” goes against the directive when its criteria point to a toy. A plush mascot resembles none of the collector examples and meets the soft-toy criteria, so a 14+ sticker is unlikely to change its classification.
The New Toy Safety Regulation
Regulation (EU) 2025/2509 on the safety of toys was adopted on 26 November 2025, entered into force on 1 January 2026 and applies from 1 August 2030, replacing the 2009 directive. It bans further hazardous chemicals from toys, including PFAS and bisphenols, and every toy placed on the EU market will need a digital product passport, readable through a QR code or another data carrier (Commission news of 23 December 2025).
Until 1 August 2030, the directive and the EN 71 parts listed under it remain the reference. Our article on the digital product passport for merchandise shows how the toy passport fits next to the passports planned for textiles.
Take a club that plans a plush version of its mascot and a flat enamel pin with the same design for its club shop. The plush mascot meets the toy criteria, so it needs a CE marking and one of the two conformity routes before it goes on sale. The pin, by our reading of the guidance, is a general consumer product and falls under the EU’s general product safety rules instead.
Frequently Asked Questions
Is EN 71 mandatory?
The standard itself is voluntary, but it is the usual way to show that a toy meets the safety requirements. A manufacturer that does not apply the harmonised standards in full has to go through an EC-type examination by a notified body instead.
Is a plush mascot a toy?
In most cases, yes. Soft filling, a three-dimensional shape and easy handling are the Commission guidance’s criteria for a toy, and a soft souvenir figure is one of its examples of a toy.
Does an enamel pin need EN 71 testing?
A flat pin with no play value is, by our reading of the guidance, not a toy, so EN 71 does not apply to it as a toy standard. It still has to be safe under the general product safety rules, and nickel in plated pins is restricted under REACH.
When does the new Toy Safety Regulation apply?
From 1 August 2030. It entered into force on 1 January 2026, and the Commission’s toy safety page describes the time in between as a transition period of four and a half years.
<nav class="article-breadcrumb"><a href="https://www.amball.com/magazine">Magazine</a><span class="article-breadcrumb__sep">/</span><a href="https://www.amball.com/glossary">Glossary</a><span class="article-breadcrumb__sep">/</span><span class="article-breadcrumb__current">EN 71 (European Toy Safety Standard)</span></nav> <h1 class="article-h1">EN 71 (European Toy Safety Standard)</h1> <p class="article-byline"><span class="cluster-badge">Licensing, Manufacturing & Compliance</span> · Updated October 19, 2026</p> <div class="article-intro"><p>EN 71 is the series of European standards for the safety of toys, used to show that a toy meets the EU's safety requirements. Its main parts cover mechanical and physical properties, flammability and the migration of certain chemical elements.</p></div> <ul><li>EN 71 is a series of harmonised European standards for toys: Part 1 covers mechanical and physical properties, Part 2 flammability and Part 3 the migration of certain elements.</li><li>A product is a toy if it is designed or intended, whether or not exclusively, for play by children under 14, and soft, three-dimensional figures such as plush mascots usually are.</li><li>The Toy Safety Regulation (EU) 2025/2509 applies from 1 August 2030 and requires a digital product passport for every toy placed on the EU market.</li></ul><p>The European standardisation organisation CEN develops the EN 71 parts. Under the Toy Safety Directive 2009/48/EC, a toy may only be sold in the EU with a CE marking, and the manufacturer shows compliance in one of two ways: self-verification against harmonised standards such as EN 71, or an EC-type examination by a notified body. Source: the European Commission’s <a href="https://single-market-economy.ec.europa.eu/sectors/toys/toy-safety_en">page on toy safety</a>.</p><h2>What EN 71 Covers</h2><p>EN 71 is split into parts. The Commission’s <a href="https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/toy-safety_en">overview of harmonised standards for toys</a> lists Part 1 on mechanical and physical properties, Part 2 on flammability and Part 3 on the migration of certain elements, next to parts for chemistry sets, finger paints, activity toys for home use and N-nitrosamines.</p><p>For merchandise, the first three parts are usually the relevant ones. A plush mascot, for example, is assessed for its mechanical and physical properties, for how its materials burn and for which elements can migrate from them. Which parts and which edition apply to a specific product is a question for an accredited test laboratory, and the Commission’s list marks some editions with restrictions.</p><h2>When Merchandise Counts as a Toy</h2><p>A toy is any product designed or intended, whether or not exclusively, for use in play by children under 14. The words “whether or not exclusively” matter for merchandise: a product with another function, such as a keyring or a fridge magnet, can still be a toy if it has play value.</p><p>The Commission’s <a href="https://single-market-economy.ec.europa.eu/document/311e36d8-7e98-47e1-a41c-11cd66b8e6cb_en">Guidance Document No 20</a> on decorative products and products for collectors gives the criteria. Soft filling, a three-dimensional shape, suitability for cuddling and easy handling point towards a toy; fragile materials, a flat shape, low play value and a weight or size that makes handling hard point away from it.</p><p>Its examples are close to a club range. A panda bear attached to a key ring is a toy, a flat key ring is not; a three-dimensional fridge magnet with play value is a toy, a flat one is not; a plush souvenir figure is a toy. By the same criteria a plush mascot is a toy whoever buys it, while a flat enamel pin sits closer to the flat key ring; the guidance does not name pins, so that last point is our reading.</p><h2>The 14+ Collector Label</h2><p>The directive excludes products for collectors, provided the product or its packaging carries a visible and legible indication that it is intended for collectors aged 14 and over. The guidance gives detailed and faithful scale models and their kits, folk dolls and decorative dolls, historical replicas of toys and reproductions of real firearms as examples.</p><p>A label does not decide the question on its own. The guidance says the reasonably foreseeable use prevails over the use the manufacturer declares, and that marking a product “This is not a toy” goes against the directive when its criteria point to a toy. A plush mascot resembles none of the collector examples and meets the soft-toy criteria, so a 14+ sticker is unlikely to change its classification.</p><h2>The New Toy Safety Regulation</h2><p><a href="https://single-market-economy.ec.europa.eu/sectors/toys/toy-safety_en">Regulation (EU) 2025/2509</a> on the safety of toys was adopted on 26 November 2025, entered into force on 1 January 2026 and applies from 1 August 2030, replacing the 2009 directive. It bans further hazardous chemicals from toys, including PFAS and bisphenols, and every toy placed on the EU market will need a digital product passport, readable through a QR code or another data carrier (<a href="https://single-market-economy.ec.europa.eu/news/stronger-toy-safety-rules-enter-force-2025-12-23_en">Commission news of 23 December 2025</a>).</p><p>Until 1 August 2030, the directive and the EN 71 parts listed under it remain the reference. Our article on the <a href="https://www.amball.com/magazine/digital-product-passport-merchandise">digital product passport for merchandise</a> shows how the toy passport fits next to the passports planned for textiles.</p><p>Take a club that plans a plush version of its mascot and a flat enamel pin with the same design for its club shop. The plush mascot meets the toy criteria, so it needs a CE marking and one of the two conformity routes before it goes on sale. The pin, by our reading of the guidance, is a general consumer product and falls under the EU’s general product safety rules instead.</p><h2 id="frequently-asked-questions">Frequently Asked Questions</h2><h3>Is EN 71 mandatory?</h3><p>The standard itself is voluntary, but it is the usual way to show that a toy meets the safety requirements. A manufacturer that does not apply the harmonised standards in full has to go through an EC-type examination by a notified body instead.</p><h3>Is a plush mascot a toy?</h3><p>In most cases, yes. Soft filling, a three-dimensional shape and easy handling are the Commission guidance’s criteria for a toy, and a soft souvenir figure is one of its examples of a toy.</p><h3>Does an enamel pin need EN 71 testing?</h3><p>A flat pin with no play value is, by our reading of the guidance, not a toy, so EN 71 does not apply to it as a toy standard. It still has to be safe under the <a href="https://www.amball.com/glossary/gpsr">general product safety rules</a>, and nickel in plated pins is restricted under <a href="https://www.amball.com/glossary/reach">REACH</a>.</p><h3>When does the new Toy Safety Regulation apply?</h3><p>From 1 August 2030. It entered into force on 1 January 2026, and the Commission’s <a href="https://single-market-economy.ec.europa.eu/sectors/toys/toy-safety_en">toy safety page</a> describes the time in between as a transition period of four and a half years.</p><hr class="faq-end"> <section class="related-section"><h2>Related Glossary Terms</h2><div class="related-grid"><a href="https://www.amball.com/glossary/reach" class="related-card"><p class="related-label">Licensing, Manufacturing & Compliance</p><p class="related-title">REACH (EU Chemicals Regulation)</p><p class="related-snippet">REACH is the EU's core chemicals regulation, controlling which substances can be used in a product sold into the EU and how their presence has to be disclosed. For merchandise, the parts that matter most are the Substances of Very High Concern (SVHC) disclosure duty and specific Annex XVII restrictions like the nickel release limit on metal goods.</p></a><a href="https://www.amball.com/glossary/ppwr" class="related-card"><p class="related-label">Licensing, Manufacturing & Compliance</p><p class="related-title">PPWR (EU Packaging and Packaging Waste Regulation)</p><p class="related-snippet">PPWR (Regulation (EU) 2025/40) is the EU's Packaging and Packaging Waste Regulation. It applies from 12 August 2026 to all packaging placed on the EU market, including the gift boxes, polybags and cartons used for merchandise.</p></a></div></section> <section class="from-blog-section"><h2>From the Magazine</h2><a class="from-blog-link" href="https://www.amball.com/magazine/digital-product-passport-merchandise">Digital Product Passport: Merchandise Starts With Apparel</a><a class="from-blog-link" href="https://www.amball.com/magazine/gpsr-nickel-metal-pins-keychains-eu">GPSR and Nickel Rules for Metal Pins and Keychains</a></section>
