Corrected Harmonized Toy Standards: What Manufacturers and Importers Must Review

Key data

If you manufacture, import or distribute olfactory toys, cosmetic kits or gustatory games in Europe, this regulatory correction directly affects you. The European Commission has published a correction of errors regarding Implementation Decision (EU) 2025/2519, which in turn amended Implementation Decision (EU) 2023/740 concerning harmonized standards for these types of toys and for the migration limits of certain elements.

The practical impact is clear: if the corrected errors affect specific technical requirements of your products, your current technical documentation may have become outdated. And without technical documentation aligned with current standards, the CE marking of your products is called into question.

What does this regulation establish?

This correction of errors acts on Implementation Decision (EU) 2025/2519, published on 15 December 2025, which amended the reference harmonized standards for three specific categories of toys and for element migration limits.

Harmonized standards are technical documents whose compliance provides presumption of conformity with the Toys Directive. This means that if your product complies with these standards in their current version, you do not need to demonstrate in any other way that it complies with the essential safety requirements of the Directive.

The products and areas affected by the correction are:

• Olfactory board games: toys that incorporate fragrances or elements for olfactory stimulation.
• Cosmetic kits: toys that include cosmetic products for children's use.
• Gustatory games: toys that incorporate edible elements or elements for taste stimulation.
• Migration of certain elements in toys: technical limits that regulate the amount of certain chemical elements that can migrate from toy material.

The correction of errors may have modified specific technical requirements within these standards. Given that the published information does not detail exactly which errors have been corrected, it is essential to consult the full text in the official source to identify the specific changes that apply to each product.

Economic and operational impact

The economic impact of this correction is not measured in direct fees or sanctions, but in the operational cost of reviewing and updating the technical documentation of affected products.

The specific consequences for companies are:

• Review of technical documentation: each product in the affected categories must be evaluated against the corrected versions of the standards. This may require engineering time, technical consulting or testing laboratories.
• Possible repetition of tests: if the corrected errors affect test parameters or limit values, previous tests may not be valid to demonstrate compliance with the corrected standard.
• Risk of loss of CE marking: placing a toy on the EU market without valid CE marking can result in market withdrawal, sanctions by market surveillance authorities and reputational damage.
• Impact on supply chain: importers must verify that their manufacturing suppliers have updated technical documentation before introducing new batches into the European market.

Who does it affect?

• Toy manufacturers that produce olfactory games, cosmetic kits or gustatory games for the European market.
• Importers that introduce these types of toys into the EU from third countries, as they are responsible for product compliance when the manufacturer is not established in the EU.
• Distributors that market these products and must ensure that manufacturers and importers have fulfilled their compliance obligations.
• Manufacturers of any type of toy whose products are subject to element migration limits, as this area has also been subject to correction.
• Quality and regulatory compliance managers in toy sector companies that manage technical documentation and CE marking.

Practical example

A Spanish company imports children's cosmetic kits from China (face paints, glitter, nail varnishes for girls) that it markets under its own brand in Spain and other EU countries. As an importer, it is the legal responsible for product compliance in the European market.

Until now, its technical documentation accredited compliance with the harmonized standards in force according to Implementation Decision (EU) 2023/740 and its amendment by Decision (EU) 2025/2519. With the publication of this correction of errors, the company must:

1. Consult the text of the correction in the Official Journal of the EU to identify exactly which technical requirements have changed in the standards applicable to cosmetic kits.
2. Assess whether tests already performed remain valid or whether they need to be repeated against the corrected requirements.
3. Update the EU declaration of conformity and the product technical file if the changes require it.
4. Communicate to its Chinese supplier the new requirements so that future batches come with updated technical documentation.

Failure to act poses the risk that a market surveillance inspection will detect that the technical documentation is not aligned with current standards, which can result in product withdrawal from the market.

What should companies do now?

1. Consult the full text of the correction in the Official Journal of the EU to identify exactly which errors have been corrected and which technical requirements have changed in the standards applicable to your products.
2. Identify which products in your catalog are affected: review whether you market olfactory games, cosmetic kits, gustatory games or any toy subject to element migration limits.
3. Review the technical documentation of each affected product and verify that tests and declarations of conformity are aligned with the corrected versions of the harmonized standards.
4. Assess whether it is necessary to repeat tests with an accredited laboratory if the corrected errors affect test parameters or limit values that had already been certified.
5. Update the EU declaration of conformity and the product technical file if changes in standards require it, before continuing to market the product.
6. Communicate to suppliers and external manufacturers (especially if you are an importer) that they must update their technical documentation in accordance with the corrected standards.
7. Document the review process to be able to demonstrate to market surveillance authorities that you have acted diligently since the entry into force of the correction (16 December 2025).