Must safety pictograms under the Toy Safety Directive and PPWR symbols both appear on the packaging at the same time?

Yes, both labelling obligations apply independently of one another. The safety pictograms under the EU Toy Safety Directive (2009/48/EC) — such as age warnings or choking hazard symbols — and the new PPWR symbols for material labelling and sorting information must both be present on the packaging. They must not visually overlap and must remain clearly legible.

Does the PPWR obligation also apply to blister packaging consisting solely of plastic film?

Yes. Plastic blister packaging is fully subject to the PPWR labelling obligation since 12 August 2026. The type of plastic must be labelled with the corresponding material abbreviation (e.g. PET, PP, PVC) and the associated recycling symbol. If the blister packaging consists of several materials — such as plastic film and cardboard backing — an additional separability notice is required.

What happens to toy inventory produced before 12 August 2026?

The PPWR provides transitional arrangements for packaging already placed on the market. Products manufactured and packaged before the cut-off date of 12 August 2026 can generally still be sold within a defined transitional period. The exact deadlines vary depending on the packaging type and member state. We strongly recommend consulting your Chamber of Commerce or a specialist lawyer in packaging law to ensure your inventory is handled in compliance.

Does the PPWR also affect baby care products such as wet wipes or baby food within the same product line?

Yes, the PPWR applies across all sectors to all packaging placed on the EU market — including wet wipes, baby bottles, dummies and packaged baby food. For food packaging (e.g. baby food), the requirements of the Food Contact Materials Regulation additionally apply. Ask your Chamber of Commerce about the combined regulatory framework relevant to your specific product categories.

Industry Guide · PPWR

PPWR for Toys & Baby Products: What Manufacturers and Retailers Must Observe since 12 August 2026

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) hits the toys and baby products industry with particular force: plastic blister packaging, elaborate display packaging and multi-piece product sets are under heightened regulatory pressure. Since 12 August 2026, binding labelling obligations apply that directly affect manufacturers and importers. Anyone who ignores the new PPWR requirements risks fines and market bans across the entire EU.

PPWR Hits Toys Hard: What Changes since 12 August 2026

The PPWR (Regulation (EU) 2025/40) obliges all companies placing products on the EU market to relabel their packaging. For the toys and baby products industry, this represents a particular challenge, as two regulatory frameworks converge here: the EU Toy Safety Directive (2009/48/EC) and the new PPWR.

Blister Packaging: Double Obligation in Minimal Space

Plastic blister packaging is standard in the industry. Since 12 August 2026, in addition to the safety pictograms already prescribed under the Toy Safety Directive, this packaging must also bear PPWR labelling symbols. This specifically concerns:

Material labelling in accordance with harmonised symbols (e.g. recycling arrow with material code such as PP, PET, PS)
Separability notice where blisters consist of different materials (e.g. PVC film + cardboard backing)
Sorting guidance for the end consumer (which bin, which system)

Existing CE markings and age warnings under the Toy Safety Directive remain unaffected but must be visually distinguishable from the PPWR symbols. Plan the surface layout of your packaging in good time.

Minimisation Requirement: Less Plastic, More Function

The PPWR stipulates that packaging must be reduced to the necessary minimum. For baby products and toys, where large display packaging often serves marketing purposes, this means a critical review of design. Consider:

Can the void space in the packaging be reduced to below 40 % of the total packaging surface area?
Can plastic films be replaced by recycled paper or certified cardboard material?
Are reusable transport packaging solutions feasible for the wholesale sector?

Labelling Hierarchy on the Packaging

With toys, symbol clutter quickly arises: CE marking, age warning, choking hazard symbol, EN 71 notices and now the PPWR symbols. Practical recommendations:

1. Create an internal labelling matrix per packaging type 2. Commission your graphic design agency to carry out a template update before the end of 2025 3. Have the new packaging design reviewed by a lawyer specialising in product safety law before print files are approved

Importers Bear Full Responsibility

Anyone who imports toys or baby products from China, the Far East or other third countries and places them on the EU market for the first time is regarded as the manufacturer under the PPWR. You bear full responsibility for the PPWR conformity of the packaging, even if the supplier provided the packaging design. Bind your suppliers contractually to compliance and request PPWR-compliant sample packaging now.

Practical Tip for Small and Medium-Sized Enterprises

Many toy retailers and importers operate as SMEs. The PPWR contains no exemption for small businesses. Contact your local Chamber of Commerce for legally sound initial advice on the PPWR obligations relevant to your company — particularly regarding whether you are classified as a manufacturer, importer or retailer. Chambers of Commerce also offer free information events on the PPWR.

Frequently Asked Questions

Must safety pictograms under the Toy Safety Directive and PPWR symbols both appear on the packaging at the same time?: Yes, both labelling obligations apply independently of one another. The safety pictograms under the EU Toy Safety Directive (2009/48/EC) — such as age warnings or choking hazard symbols — and the new PPWR symbols for material labelling and sorting information must both be present on the packaging. They must not visually overlap and must remain clearly legible.
Does the PPWR obligation also apply to blister packaging consisting solely of plastic film?: Yes. Plastic blister packaging is fully subject to the PPWR labelling obligation since 12 August 2026. The type of plastic must be labelled with the corresponding material abbreviation (e.g. PET, PP, PVC) and the associated recycling symbol. If the blister packaging consists of several materials — such as plastic film and cardboard backing — an additional separability notice is required.
What happens to toy inventory produced before 12 August 2026?: The PPWR provides transitional arrangements for packaging already placed on the market. Products manufactured and packaged before the cut-off date of 12 August 2026 can generally still be sold within a defined transitional period. The exact deadlines vary depending on the packaging type and member state. We strongly recommend consulting your Chamber of Commerce or a specialist lawyer in packaging law to ensure your inventory is handled in compliance.
Does the PPWR also affect baby care products such as wet wipes or baby food within the same product line?: Yes, the PPWR applies across all sectors to all packaging placed on the EU market — including wet wipes, baby bottles, dummies and packaged baby food. For food packaging (e.g. baby food), the requirements of the Food Contact Materials Regulation additionally apply. Ask your Chamber of Commerce about the combined regulatory framework relevant to your specific product categories.

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Stand: 25.08.2026 · geprüft von Erik Eggerth