Anyone exporting children's toys to the Eurasian Economic Union must meet the requirements of Technical Regulation TR ZU 008/2011 “On the Safety of Toys”. EAC certification is mandatory for toys within the scope of this regulation. Neither an EAC declaration nor European CE marking replaces the required certificate.
The assessment covers the safety of the product, its materials, the intended age group and the labelling. For serial production, production conditions are also assessed and conformity is monitored regularly throughout the certificate's validity period.
This article explains which toys are covered, how the procedure works and which documents manufacturers should prepare for export.
What is EAC certification for toys?
EAC certification confirms a product's conformity with the applicable technical requirements of the EAEU. TR ZU 008/2011 provides the main basis for children's toys.
The Eurasian Economic Union comprises:
- Armenia
- Belarus
- Kazakhstan
- Kyrgyzstan
- Russia
A duly issued EAC certificate can be used for these member states within its scope. Additional national requirements, for example concerning language or digital product marking, must be considered separately.
The EAC certificate is product‑specific proof of conformity. It is not a general approval for all toys made by a manufacturer. The products, models and production sites covered by the document and its annexes are decisive.
Which toys fall under TR ZU 008/2011?
The regulation generally defines toys as products or materials intended for play by children under 14 years of age. The scope and the expressly listed exclusions must be taken into account.
Typical product groups include:
- Dolls and doll accessories
- Plush animals and other soft‑filled toys
- Toy vehicles
- Building and construction toys
- Board games and other parlour games for children
- Rattles and certain baby toys
- Electrical and electronic toys
- Toys for outdoor activities
- Certain experimental and creative kits
Classification is based on function, design, intended use and age group. The trade name or customs tariff code alone is often insufficient.
Distinction from other children's products
Not every product for children is a toy. Children's clothing, footwear, certain care products, sports equipment and playground equipment must be assessed against the respective applicable requirements. Particularly in borderline cases, classification should take place before quotation and testing planning. Examples include decorative collectible figurines, learning materials, sports equipment or products that have both a practical function and play value.
An age marking such as “14+” should not be used solely to exclude a product actually intended for younger children from the scope of toy legislation.
EAC certificate or EAC declaration?
Certification is mandatory for toys within the scope of TR ZU 008/2011.
The current regulation provides for schemes 1c and 3c:
Feature | Scheme 1c | Scheme 3c |
|---|---|---|
Type of supply | Series production | Defined batch of goods |
Product testing | Testing of representative samples | Testing or assessment of the batch covered in accordance with the prescribed rules |
Production assessment | Provided for | No production assessment as under scheme 1c |
Ongoing surveillance | Annual periodic assessment | No annual series production surveillance under scheme 1c |
Typical application | Recurring deliveries from ongoing production | Specifically defined delivery or batch |
Certification is carried out by a body authorized for this purpose and listed in the unified EAEU register. The required tests are conducted by an appropriately accredited testing laboratory listed in the register. Older overviews that also mention scheme 2c should not be used as a basis for new procedures without verification.
Who can be the applicant?
The applicant must be registered as a legal entity or individual entrepreneur in an EAEU member state. For series production under scheme 1c, the manufacturer or its authorized representative may act as the applicant. For a batch of goods under scheme 3c, a seller or importer may also assume this role.
A manufacturer from Germany or another country outside the EAEU therefore requires a suitable authorized representative within the Union for series production certification.
The agreement should clearly define responsibilities. These include in particular:
- Cooperation with the certification body and authorities
- Provision and retention of relevant documentation
- Notification of product changes
- Cooperation in surveillance and corrective actions
- Access to certificates and test reports
Which safety requirements apply to toys?
The test programme depends on the type of toy, the materials used and the intended age of the children. Not every test is required for every product.
Mechanical and physical safety
Items to be assessed include, for example, small parts that can be swallowed, sharp edges, accessible points, moving parts, cords and the strength of connections.
For toys that support a child's body weight, additional requirements for stability and load‑bearing capacity may be relevant. For plush toys, the focus includes seam strength and the accessibility of the stuffing.
Chemical and hygienic safety
Materials, coatings, printing inks, adhesives and filling materials must be suitable for the intended use. Compliance with the applicable hygienic and chemical requirements is tested depending on the material and its contact with the child. A general supplier statement such as “non‑toxic” does not replace verifiable evidence for the materials actually used.
Flammability and other properties
Depending on the product, fire behaviour, sound levels or electrical properties must also be examined. The amendments adopted in 2024 added, among other things, definitions and requirements for further types of toys to the regulation, such as certain olfactory games and gustative kits.
For electronic toys, supplied power adapters, chargers and radio functions should also be considered separately when reviewing the scope of applicable regulations.
Specific requirements for toys
The intended age group has a significant influence on the safety assessment. Young children frequently put objects in their mouths and cannot yet reliably recognise hazards. For toys intended for children under three years of age, the size of detachable parts and the accessibility of hazardous components are particularly relevant. Toys and removable parts must be designed so that they cannot enter the upper respiratory tract.
Manufacturers should therefore clarify the following during product development:
- Which age group is actually being targeted
- Which parts can become detached under foreseeable stress
- Which materials come into contact with the mouth and skin
- Whether cleaning and care can be carried out safely
- Which specific material restrictions apply
A warning stating “Not suitable for children under three years of age” does not replace age‑appropriate design if the product's actual design indicates that it is intended for this age group.
Which documents are required for certification?
A complete initial dossier facilitates classification and reduces follow‑up queries.
The following compilation is recommended for preparation:
- Product description and overview of functions
- List of model and item numbers
- Product photographs
- Intended age groups
- Overview of materials and components
- Details of paints, coatings, adhesives and filling materials
- Existing test reports
- Draft labels and packaging designs
- Instructions for use, care and assembly
- Manufacturer details and production site addresses
- Applicant details
- Representation agreement, where required
- Delivery documents for batch certification
The final list of documents is determined on the basis of the specific product and the selected scheme.
EAC certification procedure for toys
Classify the product and define the scope
First, it is checked whether the product falls under TR ZU 008/2011. The models, materials, age groups and production sites are then recorded. These details form the basis for the requested scope of the certificate.
Agree on product groups and test samples
Not every item number necessarily requires a completely separate testing programme. However, grouping must be technically justified. Different materials, designs or age groups may require additional samples and tests. Even a new colour may be relevant if it changes the chemical composition of a coating. The selection and number of samples should therefore be agreed with the certification body before shipment.
Provide samples and conduct tests
The samples must correspond to the intended series production version or the batch to be certified. The necessary shipping and customs documents must be prepared for importation for testing purposes. The laboratory examines the properties relevant to the toy in question. Any identified non‑conformities must be resolved before a positive certification decision can be made.
Assess production
Under scheme 1c, the condition of production is also analysed. This determines whether ongoing manufacturing can consistently deliver products that correspond to the tested version. An existing quality management system can support preparation. However, it does not replace the required product‑specific assessment.
Issue the certificate and check the register entry
Following a positive assessment of the required evidence, the certification body issues the certificate and enters the information in the register. Before the first delivery, the manufacturer, production site, models, age groups and certificate status in particular should be checked against the actual goods. The procedural steps and registration are described in the amended Article 6 of the regulation.
EAC marking of children's toys
The marking must be unambiguous, legible and attributable to the product. Additional consumer information is required alongside the EAC mark.
Depending on the product, this includes in particular:
- Name of the toy
- Details of the manufacturer and the other designated responsible companies
- Contact information
- Minimum age or corresponding age marking
- Date of manufacture
- Required warnings and safety instructions
- Care, cleaning or storage instructions
- Assembly and operating instructions, where required
The marking and the accompanying technical documentation must be provided in Russian. Additional official languages must be taken into account if required by the legislation of the member state concerned. Under the amendments in force since November 2024, the indication of the country of manufacture must also be taken into account if the production site is located in a different country from the manufacturer's registered office.
EAC mark and digital product marking
The EAC mark documents conformity with the applicable technical regulations. Digital identification markings serve additional purposes, such as the traceability of individual goods.
Corresponding requirements may additionally apply to certain toys. Their product scope and national implementation dates must be checked separately. A digital mark does not replace the EAC certificate. The EAEU legal portal lists a separate decision on identification marking for certain toys.
Marking amendment from March 2027
The EAEU Council adopted a further amendment to TR ZU 008/2011 through Decision No. 106 of 9 September 2026. According to the official legal portal, it enters into force on 27 March 2027. A distinction must therefore be made between the current legal situation and the future amendment that has already been adopted. Manufacturers preparing packaging for deliveries from that date should incorporate the new version into their release review.
Regardless of this, a comprehensive cross‑check of all information on the product, packaging, translation labels and instructions is already recommended today. Age indications, intended use and warnings should be consistent.
Annual surveillance for series production
For certification under scheme 1c, a periodic assessment is carried out once a year during the certificate's validity period. This may include testing of representative samples and/or an analysis of production conditions. Manufacturers should take this surveillance into account when planning budgets and schedules. It is distinct from reissuance or renewal after the certificate expires.
Effective internal organisation includes:
- Person responsible for certificate management
- Schedule of surveillance activities
- Documented approval of material changes
- Up‑to‑date model and supplier lists
- Availability of technical evidence
Can CE documentation and EN‑71 test reports be used?
European test reports can provide a useful starting point. However, they do not automatically replace the assessment by the competent EAEU bodies required under TR ZU 008/2011.
Before any potential use, the following should be checked:
- Do the tested items match the products intended for export?
- Are the materials and production sites unchanged?
- Do the reports cover the applicable requirements?
- What additional testing does the EAC procedure require?
CE marking alone does not authorise the placing of toys on the market under TR ZU 008/2011.
Practical example: Plush toys for Kazakhstan
A German manufacturer wishes to supply a series of plush animals to Kazakhstan. The collection includes several sizes and colours. Some models have sewn‑on textile eyes, while others use plastic eyes.
To prepare the project, age groups, materials, fillings and design differences are first recorded. It is then assessed which models can be evaluated together and which differences require additional testing.
The following are particularly relevant in this example:
- Strength of seams and attachments
- Accessibility of the filling
- Detachability of small parts
- Differences in materials and dyes
- Consistency of age indications
Scheme 1c is used as the basis for the planned supply of series‑produced products. In addition to product testing, the production assessment and subsequent annual surveillance must be planned.
This example is illustrative. It shows why a similar external appearance does not automatically mean that all models can be covered by the same samples and evidence.
Costs and duration of EAC certification
Costs depend primarily on the technical scope. Key factors are:
- Number of product groups
- Different materials and designs
- Intended age groups
- Scope of laboratory testing
- Number of production sites
- Production assessment for series production
- Sample logistics and translations
- Annual surveillance
A reliable quotation should list the costs of initial certification and subsequent surveillance separately. The processing time also depends on the completeness of the documentation, the provision of samples, testing and any necessary corrections. Binding delivery dates should only be confirmed on the basis of an agreed project plan.
Checklist before exporting children's toys
- Classification as a toy under TR ZU 008/2011 confirmed
- Age groups determined on a technical basis
- Models, materials and production sites documented
- Appropriate certification scheme determined
- Eligible applicant designated
- Sample requirements agreed with the certification body
- Required testing completed
- Production assessment under scheme 1c carried out
- Labelling and language versions checked
- Certificate and register entry checked against the goods
- Additional national requirements clarified
- Surveillance and change management organised
Prepare for certification of your toys
An early assessment helps identify unsuitable materials, incomplete labelling and missing supporting evidence before the first delivery. Are you planning to export children's toys to the EAEU? Send AC Inorms your product catalogue, model overview, material specifications and intended age groups. This information can be used to determine the scope of certification, testing requirements and next steps.
Further information is available on our page on EAC certification for the EAEU member states.
The principal basis is TR ZU 008/2011 “On the Safety of Toys”. Whether a specific product falls under this regulation must be assessed based on its characteristics and the scope of application.
No. Certification is mandatory for toys within the scope of this regulation.
The current regulation provides for scheme 1c for series production and scheme 3c for a defined batch of goods.
Not necessarily. Colour variants may, where appropriate, be covered together. However, differences in materials or coatings must be taken into account when planning sampling and testing.
A company registered exclusively in Germany does not meet the requirement for an applicant registered in the EAEU. For series production by a foreign manufacturer, a suitable authorized representative is required for this purpose.
The prescribed tests and supporting evidence are required for certification. The selection and number of samples are determined based on the product and the procedure.
Under scheme 1c, the regulation provides for an annual periodic assessment during the certificate's validity period. This is not merely an administrative renewal.
No. CE and EAC belong to different legal systems. Existing European documentation can support preparation but does not replace the required EAC evidence of conformity.
Yes. In addition, the language requirements of the respective destination country must be taken into account.
In principle, a separate certificate for each member state is not required if the valid EAC certificate covers the specific product. Additional national requirements must still be reviewed separately.
