30 October 2025
Product regulation and compliance update series
October 2025Toys: new toys safety regulation getting closer
On 13 October 2025, the Council of the European Union approved the toy safety regulation.
Context
Until now, toy safety has been regulated by Directive 2009/48/EC, which established safety requirements for toys manufactured in the EU and toys imported into the EU. Compliance with these requirements was a prerequisite for placing products on the EU market.
The new regulation aligns with the EU’s Chemicals Strategy for Sustainability. It aims to enhance consumer protection, especially for children and other vulnerable groups, from the most hazardous chemical substances.
Key solutions
The new regulation introduces a ban or significant restrictions on the use of several hazardous substances, including:
- endocrine-disrupting chemicals,
- contact allergens,
- biocidal substances,
- per- and polyfluoroalkyl substances (PFAS).
To improve enforcement, the regulation introduces a digital product passport. This document will contain key safety information about toys, facilitating border controls and market surveillance activities.
Next steps
The next step in the legislative process is the adoption of the regulation by the European Parliament. Once formally adopted, it will enter into force after a transition period of four and a half years.
New regulation restricting the use of PFAS in firefighting foams now in force
In September 2025, the European Commission adopted Regulation 2025/1988, amending Annex XVII to the REACH Regulation.
Context
The regulation, which was published on 3 October 2025, prohibits the use of per- and polyfluoroalkyl substances (PFAS) in firefighting foams due to their harmful effects on health and the environment. The regulation includes transitional periods but also introduces a range of new obligations.
Key solutions
Under the regulation, obligations are introduced both users of foams and fire extinguishers and entrepreneurs placing on the market products containing PFAS in a concentration equal to or higher than 1 mg/l. From 23 October 2026 both entrepreneurs and users will be required to (among other things):
- use such foams exclusively for extinguishing flammable liquid fires (Class B),
- minimise emissions and exposure,
- ensure selective collection of waste and wastewater,
- develop and annually review a management plan for these products,
- label extinguishers and foams in the official languages of the Member States where the foam extinguishers are placed on the market - this only applies to entrepreneurs who place the products on the market.
The regulation entered into force 20 days after its publication, i.e. on 23 October 2025. Transitional periods range from 12 months to 10 years, depending on the specific circumstances.
Next steps
The European Commission plans to develop a comprehensive piece of legislation covering all uses of PFAS, with the exception of firefighting foams, which are already regulated. The aim is to harmonise legislation and more effectively reduce the use of PFAS in various sectors of the economy.
New bill amending the Act on Plant Protection Products
On 21 October 2025, a bill amending the Act on Plant Protection Products appeared on the list of legislative and programme work of the Council of Ministers. It is one of the bills being implemented as part of deregulation activity.
Context
According to European Commission Regulation 2023/564, from 1 January 2026, professional users of plant protection products who place them on the market will be required to keep records of plant protection treatments ‘electronically in a machine-readable format’. The records must contain the data specified in the annex to the Regulation.
Key solutions
The amendment to the Act on Plant Protection Products aims to better prepare farmers and other professional users for the new EU requirement. It introduces:
- postponement of the electronic record-keeping obligation to 1 January 2027;
- temporary exemption from the 30-day entry deadline for treatment records until the end of 2029, provided that all documentation is available in electronic format by 31 January of the year following the use of the product.
Next steps
According to the Council of Ministers’ legislative schedule, the new law is expected to be adopted in Q4 2025, with the goal of entering into force before 1 January 2026.
Measuring instruments: EU Council adopts position on updating Directive 2014/32/EU
On 8 October 2025, the Council of the European Union adopted its negotiating position on the revision of the directive concerning harmonised requirements for measuring instruments.
Context
Directive 2014/32/EU was originally adopted in 2004 and updated in 2014. However, the current rules do not cover new types of measuring instruments and are no longer aligned with the principle of technological neutrality.
Key solutions
The amendment to Directive 2014/32/EU aims to adapt the rules to modern technologies and support the implementation of the European Green Deal objectives. The planned changes include:
- extending the scope to cover new types of measuring instruments relevant to energy and digital transitions,
- ensuring technological neutrality of the legal framework,
- clarifying rules for reading measurement results remotely (e.g. via smartphone),
- facilitating the use of new gases, such as hydrogen,
- reducing discrepancies in national regulations to lower costs and accelerate innovation.
Next steps
The Council of the European Union has formally approved its negotiating position on the update of Directive 2014/32/EU. This document will now be used as a basis for negotiations with the European Parliament. Negotiations will begin once the Parliament has adopted its own position.
October reports from the Trade Inspection Authority
Below is a summary of inspection reports published last month on the website of the Office of Competition and Consumer Protection (UOKiK).
Electric Ovens
On 3 October 2025, UOKiK published the results of an inspection conducted by the Trade Inspection Authority (IH), aimed at verifying whether suppliers and retailers of household electric ovens comply with energy labelling requirements. Additionally, selected parameters declared on the labels were verified through laboratory testing.
No irregularities were found:
- in the use of labels at points of sale and on websites, or
- in the parameters declared by manufacturers on energy labels.
Baby sleeping products
The website of the Office of Competition and Consumer Protection (UOKiK) also published the results of an inspection by the Trade Inspection Authority (IH) concerning baby sleeping products – cocoons, sleeping bags and Moses baskets. The aim of the inspection was to check the labelling and physical and mechanical parameters affecting child safety.
As a result of the inspection:
- irregularities in labelling were found in 8 out of 15 models due to incomplete or missing user instructions and warnings or markings directly on the product.
- 14 out of 15 models were challenged due to design flaws, including discrepancies revealed in laboratory tests such as non-compliance with declared technical parameters, poor material quality, and inconsistent durability test results.
Due to these design flaws, IH submitted 13 requests to the President of UOKiK to initiate administrative proceedings. Entities responsible for placing these products on the market may face fines of up to PLN 100,000. So far, seven proceedings have been initiated, one resulted in a warning, another allowed corrective actions, and the remaining cases are under review.
Electric scooters
This month, UOKiK also published the results of inspections of electric scooters, focusing on labelling and construction.
As a result of the inspection:
- irregularities in labelling and formal requirements were found in 5 out of 10 models, including incorrect instructions, missing or incorrect declarations of conformity, and missing required markings.
- no mechanical safety issues were found in any of the scooters tested in laboratory conditions for static strength of handlebars and steering columns.
In all five of the questioned cases, businesses were given the opportunity to take corrective actions.
Heat pumps
UOKiK also reported on a joint inspection conducted by the Trade Inspection Authority and the National Revenue Administration (KAS), focusing on heat pumps. Initially, KAS inspected imported heat pumps at customs offices across Poland, then forwarded cases to IH for further review.
The aim of the inspection was to eliminate non-compliant or hazardous products at the KAS verification stage. Its subject matter included checking the labelling (including labels and the CE mark), technical documentation and declarations of conformity.
As a result of the inspection:
- irregularities were found in 32 out of 34 products, with each of the questioned models having at least two irregularities, and one of them having as many as five;
- most issues involved improperly prepared product information sheets or their absence, and incorrect or missing EU declarations of conformity.
As a result, 32 models (a total of 786 units) were banned from being placed on the market. After businesses corrected the formal issues and received approval from KAS, 2 models (455 units) were allowed to be placed on the market