GPSR risk assessment example: Crochet amigurumi bunny for babies

⚠ Red flags found for this product

• THIS PRODUCT IS A TOY under the Toy Safety Directive 2009/48/EC. Before it is sold to DE, FR or IE it must have a conformity assessment against the essential safety requirements: EN 71-1, EN 71-2 and EN 71-3 testing, a toy safety assessment, a technical file and an EU Declaration of Conformity. It must carry CE marking, a type/batch number and manufacturer details. GPSR documentation alone is NOT sufficient, and selling it without CE marking is not lawful.
• It is intended for children under 36 months, so the stricter EN 71-1 requirements for under-3s apply. These cover small parts, torque and tension tests on eyes and ears, seam strength, filling accessibility and cleanliness, and the soaking test for under-18-month toys. Plastic safety eyes fitted by hand are a frequent cause of EU Safety Gate (RAPEX) recalls of handmade amigurumi for choking hazard. Strongly consider replacing them with tightly embroidered eyes for the under-3 version.
• Do NOT use the 'Not suitable for children under 3 years' warning on this toy. It is intended for babies, and the Toy Safety Directive prohibits that warning on toys clearly intended for under-3s. Using it to avoid the under-3 requirements would be misleading and unlawful.
• The manufacturer is in the United Kingdom, which is outside the EU. The toy carries CE marking, so Regulation (EU) 2019/1020 Art. 4 requires an economic operator established in the EU, such as an authorised representative or importer, before sale to DE, FR or IE. Their name and address must appear on the toy, packaging, parcel or accompanying document. Under GPSR Art. 16 and 19, these details must also appear in the Etsy listing. UKCA marking is not valid in the EU.
• Warnings and instructions must be in the language of each destination country: German for DE, French for FR, English for IE. Germany and France will not accept English-only safety information.
• Handmade, small-batch production does not exempt the toy from testing. Testing can be targeted: test a representative sample of each design, keep supplier certificates for each material lot, and use a consistent, documented construction method.
• The new EU Toy Safety Regulation (EU) 2025/2509 will replace the Directive after its transition period. It adds a mandatory Digital Product Passport and stricter chemical rules. Plan for it, but the current Directive applies now.