ECHA Takes on New Tasks to Strengthen Toy Safety (TSR 2026)

The new Toy Safety Regulation (TSR) raises the bar for toy safety in the European Union. The regulation introduces a stricter approach to chemical safety in toys, product transparency, and digital traceability, while also expanding ECHA's role. Under this framework, ECHA will conduct scientific assessments for chemical substances used in toys and handle companies' derogation (exception) requests for banned chemicals.

What are ECHA's new responsibilities?

TSR consolidates ECHA's tasks into two main areas:

1) Safety assessments for chemicals in toys

At the request of the European Commission, ECHA will conduct safety assessments for chemical substances present in or released from toys. These assessments, supported by expert scientific opinions, aim to clarify the risks of toys to children's health.

2) Review of derogation (exception) applications for banned chemicals

In some cases, companies may request derogation to allow limited use of a banned chemical under certain conditions. ECHA will evaluate these requests, ensuring scientific reviews that consider both risk and socio-economic dimensions.

These two mechanisms aim to strengthen oversight of the chemical safety of toys sold in the EU market and ensure decisions are made on a scientific basis.

What changes for manufacturers, importers, and brands?

TSR shifts the "compliance" approach in the toy sector from mere product testing or labeling to supply chain evidence + chemical restriction management + digital accountability. Therefore:

- Formula and material-based chemical compliance checks become more critical.

- The verifiability of supplier declarations and documentation quality gain importance.

- Product safety and transparency expectations also rise in online sales.

- In exceptional scenarios requiring derogation, time and cost risks increase if scientific justification and file structure are not done correctly.

How do we support as Pier Compliance?

In toy compliance projects under TSR, we clarify "what businesses need to do" and create an actionable roadmap. Our typical support areas:

- Chemical compliance screening: Restriction and risk screening by product/raw material/material, identification of non-compliance points

- Supply chain documentation: Preparation of supplier declarations, technical files, and evidence packages

- Derogation preparation (if needed): Analysis of exception scenarios, technical justification framework, file architecture

- Digital traceability approach: Product data management, digital accountability, and sustainability of documentation

- EU market entry compliance: Management of compliance steps together with brand, importer, and distributor roles

Quick compliance checklist for 2026–2030

To prepare for TSR in a planned manner, not "last minute":

- Extract product tree by SKU (material/supplier breakdown)

- Conduct material-based chemical screening (prioritize high-risk groups)

- Restructure technical file with evidence focus (who verifies what, how?)

- Set up transparency requirements in online sales and customer information processes

- Identify products that may require derogation early and develop strategy

Source: [ECHA Takes on New Tasks to Strengthen Toy Safety](https://echa.europa.eu/-/echa-takes-on-new-tasks-to-strengthen-toy-safety)