GPSR for Children's Products That Are Not Toys: High Chairs, Cots, Baby Bottles, Carriers and Other Childcare Articles

Toy or childcare article? Why the classification decides everything

Under Article 2(1) of the Toy Safety Directive 2009/48/EC, a toy is a product designed or intended, whether or not exclusively, for use in play by children under 14. Products that help a parent feed, seat, carry, bathe or put a child to sleep are not designed for play, so they are not toys. Annex I to the Directive also expressly excludes babies' soothers (point 16) and fashion accessories for children that are not for use in play (point 19).

Because no Union harmonisation act sets safety requirements for these childcare articles, the GPSR (Regulation (EU) 2023/988) is their main safety law. The Commission's business guidelines (Notice C/2025/6233, section 2.2) give childcare articles as an example of products to which the GPSR applies fully. That has a practical consequence: the manufacturer duties in Chapter III Section 1 (Articles 9 to 18), which do not apply to CE products, do apply here.

Watch out for combination products. A high chair with a detachable play tray, or a baby gym sold with hanging soft toys, can contain toy elements that follow the toy rules while the seat or frame follows the GPSR. Marketing matters too: if you present a product as something for children to play with, an authority may treat it as a toy. Full toy rules are in our toys and children's products white paper.

What the GPSR requires for childcare articles

Article 5 allows only safe products on the market. A safe product is one that, under normal or reasonably foreseeable conditions of use, presents no risk or only the minimum risk compatible with its use (Article 3(2)). For childcare articles, “reasonably foreseeable” includes what children actually do: climb, lean, chew, pull and wriggle out of harnesses. The core duties are:

• Internal risk analysis and technical documentation before placing the product on the market (Article 9(2)), kept up to date and available to authorities for 10 years (Article 9(3)). See GPSR technical documentation and risk assessment.
• Series production control so every batch stays safe (Article 9(4)).
• Type, batch or serial number on the product, or on the packaging or an accompanying document if the product's size or nature does not allow it (Article 9(5)).
• Manufacturer's name, registered trade name or trade mark, and postal and electronic address on the product, or where that is not possible on the packaging or in an accompanying document (Article 9(6)).
• Clear instructions and safety information in a language consumers easily understand, as decided by the Member State (Article 9(7)).
• A responsible economic operator in the EU whose details are on the product, packaging, parcel or accompanying document (Article 16, see EU responsible person).
• A complete online offer with manufacturer and responsible person details, a product picture and identifier, and the warnings and safety information (Article 19).

Children as vulnerable consumers: what Article 6 adds to your risk analysis

Article 6(1) lists the aspects that must be considered when deciding whether a product is safe. Three are central for childcare articles:

• Article 6(1)(d): presentation and labelling, explicitly “including the labelling regarding age suitability for children”, warnings and instructions for safe use and disposal.
• Article 6(1)(e): the categories of consumers using the product, in particular the risk for vulnerable consumers such as children.
• Article 6(1)(f)(ii): products not designed for children that are likely to be used by them or look appealing to them, for example a novelty adult cup decorated with cartoon characters.

In general terms, a risk analysis for a childcare article usually looks at these hazard groups:

• Entrapment of the head, fingers or limbs in gaps and openings, for example between cot bars or in folding hinges;
• Falls and tip-over: stability of high chairs, bouncers and changing units, and whether restraint systems keep the child in;
• Strangulation from cords, ribbons, straps or loops long enough to go round a child's neck;
• Choking and ingestion of small parts that can detach, such as caps, decorative buttons or screws, and of button batteries in electronic accessories;
• Suffocation from soft padding, pillows, plastic films and packaging in the sleep environment;
• Chemical and thermal hazards, covered in more detail below.

Record each hazard, the users concerned (newborn, sitting baby, toddler), the measures taken and the test evidence. That record is the heart of your technical documentation.

Which standards give a presumption of safety (Implementing Decision (EU) 2026/901)

Under Article 7(1)(a), a product that conforms to a European standard whose reference is published in the Official Journal is presumed to meet the general safety requirement for the risks that standard covers. Commission Implementing Decision (EU) 2026/901 of 17 April 2026 publishes the full list of such standards for the GPSR and repeals the previous list in Implementing Decision (EU) 2019/1698. Childcare standards on the list include:

The presumption covers only the risks the standard deals with, and authorities can still act if a product proves dangerous (Article 7(3)). Ask your laboratory to test to the edition on the current list.

Gaps to know about. The list has no standard for pushchairs and prams, cot bumpers, baby sleeping bags or children's duvets. Commission Decision 2010/376/EU set safety requirements for European standards on cot mattresses, cot bumpers, suspended baby beds, children's duvets and sleeping bags, but of these only cot mattresses (EN 16890) currently have a standard on the GPSR list. Where no listed standard applies, Article 8(1) tells you which other elements count, for example other European standards, international standards, Commission guidance and the state of the art. Name the references you used in the technical documentation, as Article 9(2)(b) requires.

Chemicals and food contact: REACH, bottles and the BPA ban

The GPSR sits on top of chemicals law, which sets specific limits for childcare articles. REACH (Regulation (EC) No 1907/2006) Annex XVII defines a childcare article as any product intended to facilitate sleep, relaxation, hygiene, the feeding of children or sucking on the part of children. It then sets:

• Entry 51: DEHP, DBP, BBP and DIBP, individually or combined, must be below 0.1% by weight of the plasticised material in toys and childcare articles;
• Entry 52: DINP, DIDP and DNOP must not exceed 0.1% of the plasticised material in toys and childcare articles that children can put in their mouth;
• Entry 50(6): rubber or plastic components of childcare articles that come into direct, prolonged or repeated contact with skin or the mouth must not contain more than 0.5 mg/kg of any of the listed PAHs.

Bottles, cups, plates, spoons and teats are also food contact materials. They must meet Regulation (EC) No 1935/2004 and, if made of plastic, Regulation (EU) No 10/2011. Commission Regulation (EU) 2024/3190 prohibits the use of BPA in the manufacture of food contact materials and articles (Article 3); repeat-use articles made with BPA could only be first placed on the market under the transitional rule until 20 July 2026 (Article 12(1)). Food contact details are covered in GPSR for kitchenware and food contact products.

Electrical childcare products, such as bottle warmers, baby monitors and sterilisers, are CE products under the electrical and radio equipment rules; see the electronics white paper.

Labels, age warnings and the online listing

Article 6(1)(d) makes age labelling and warnings part of the safety assessment itself, so a correct label is not a cosmetic detail. In practice:

• Follow the standard's marking clause. Many childcare standards specify warnings and their content, for example the age or weight range, the need to use the restraint system or not to leave the child unattended. Use the content your test report confirms rather than inventing your own.
• Do not borrow toy warnings. The toy symbol “not suitable for children under 36 months” is a toy-law tool. It does not replace the warnings a high chair or stair gate needs, and putting a toy warning on a non-toy can confuse authorities about what the product is.
• Translate. Instructions and safety information must be in a language consumers easily understand, as decided by the Member State (Article 9(7)); see warning and instruction language rules.
• Traceability on the product. Put the type and batch number and the manufacturer and responsible person details on the product where possible. A batch number linked to a test report makes a targeted recall possible.
• Repeat it online. Article 19(d) requires the warnings and safety information to appear in the online offer. Age and weight limits that affect the purchase decision belong in the listing, not just in the box.

You can lay out a label with the free tool at gpsrtools.com; the general rules are in GPSR label requirements.