What GPSR means for prams, high chairs, safety gates, playpens and other nursery products sold in the EU, including obligations for manufacturers, importers, distributors and online sellers.
Baby and toddler equipment occupies an unusual position in EU product law. The safety risks are among the most significant of any consumer product category, yet there is no single EU regulation dedicated specifically to childcare articles. Instead, most nursery products are governed by the General Product Safety Regulation, supported by product-specific European standards and, where applicable, additional legislation.
Prams, pushchairs, high chairs and safety gates generally fall outside the Toy Safety Directive, and are not CE marked simply because they are childcare articles. However, CE marking may still apply where a product incorporates a separately regulated function, such as a toy, electrical equipment, radio equipment or another product subject to harmonisation legislation.
For most childcare articles, the General Product Safety Regulation (GPSR) — Regulation (EU) 2023/988 provides the primary legal framework. Since 13th December 2024, it has applied directly in every EU Member State.
This article covers how GPSR governs baby and toddler products, and what this legislation requires from each business in the supply chain.
Babycare product or children's toy? Classification under EU law
When it comes to product legislation, items classed as babycare products — prams, high chairs, safety gates, playpens and the like — are regulated differently from children's toys such as ride-ons and climbing equipment. Classification depends on a product's intended and reasonably foreseeable use, not just what it's called.
Babycare products are generally governed by GPSR and assessed against the European standards developed for childcare articles (the regulatory term commonly used for non-toy nursery products). Toys, by contrast, are subject to CE marking requirements and an EU Declaration of Conformity under the Toy Safety Directive 2009/48/EC, with compliance typically demonstrated through testing to the relevant parts of the EN 71 series.
Our guide to GPSR for outdoor toys and play equipment covers toy classification in more detail.
Some items cover both categories. For example, a bouncer with a detachable play arch. The bouncer is a babycare product assessed under GPSR, while the detachable toys are generally subject to toy legislation in their own right.
For products like these, each element must be classified, assessed and documented against its own framework, with testing carried out where needed to substantiate compliance. This is why classification — down to component level where needed — must be correct before any further regulatory work takes place.
“Classification decides everything about how a product is regulated, from the legislation it answers to through to the standards it is normally assessed against. In this category the line runs between babycare products, which come under GPSR, and toys, which need CE marking and, in most cases, EN 71 testing. Plenty of products straddle it. Getting that call right is the first piece of compliance work on any nursery range.”
— Chris Giddings, Product Compliance Specialist, Hooley Brown
Which standards apply to baby and toddler products under GPSR?
GPSR sets a general safety requirement rather than rules for individual product types. The specifics — such as test loads, permitted opening sizes and stability criteria — are usually set out in the European standards for each product type. Following the relevant standard is the normal way manufacturers show that a product meets GPSR's safety requirements. Although these standards are voluntary, using one that's officially recognised under GPSR gives you a strong basis for demonstrating compliance.
- Prams and pushchairs: EN 1888-1 and EN 1888-2 (wheeled child conveyances)
- Carry cots and bassinets: EN 1466; cribs, cradles and bedside sleepers: EN 1130
- High chairs: EN 14988
- Baby bouncers and reclined cradles: EN 12790 series
- Playpens: EN 12227
- Stair and safety gates: EN 1930 (safety barriers)
- Cots and folding cots: EN 716
- Step stools: EN 14183
Standard references, editions and scopes change over time, so always confirm the current version (and whether its reference is published under GPSR) before relying on it for a specific product.
Some product types have no product-specific European standard of their own, such as toddler beds and bed guards. In these cases, compliance is typically evidenced through related European and national standards alongside a documented risk analysis. Where a standard has been applied only in part, the technical documentation should identify which parts and how the remaining risks were assessed.
Other EU legislation to keep on your radar
In addition to GPSR, your babycare products may need to meet specific EU regulatory requirements, including:
- Toy Safety Directive 2009/48/EC for any product or component with a play function, e.g. ride-on toys, activity and climbing toys. The new Toy Safety Regulation (EU) 2025/2509 entered into force in January 2026 but applies from 1st August 2030. Until then, the Directive remains the operative framework.
- REACH for products containing phthalates and other restricted substances in plastics, coatings, foams and textiles.
- Food contact materials Regulation (EC) 1935/2004 for high chair trays and any surface intended or reasonably expected to touch food.
- Packaging and Packaging Waste Regulation, which applies generally from 12th August 2026 with further obligations phasing in after this date. National packaging registration and extended producer responsibility obligations continue to apply across Member States alongside it.
What your GPSR risk analysis needs to cover
Under Article 9 of GPSR, manufacturers must carry out an internal risk analysis before placing a product on the EU market. This analysis forms part of the technical documentation (commonly referred to as the technical file). It must consider the product's characteristics, its intended and reasonably foreseeable use, and the people likely to use it.
GPSR names children among the vulnerable consumers a safety assessment must consider. For baby and toddler products, your risk analysis should address hazards such as the following — treat this as a starting point rather than an exhaustive list:
- Entrapment and strangulation: design features that could trap a head, limb, finger or clothing, such as openings between bars and slats, V-shaped apertures, adjustment cords and harness straps.
- Falls and containment failure: for example, a stair gate that pops out of its fittings under load, or a bed rail that leaves an opening against the mattress, turning a protective product into a hazard.
- Stability and structural integrity: folding mechanisms on pushchairs and playpens, locking indicators, tip-over resistance on high chairs and step stools, and fatigue in frames subjected to daily folding and carrying.
- Suffocation and positional risk: for any product a baby sleeps or reclines in, your assessment needs to address soft padding, recline angles, mattress fit and the safe-sleep warnings required by the applicable standards and your own risk assessment.
- Chemical hazards: restricted substances in plastics, coatings, textiles and foams. Babies often chew and suck whatever is within reach, so substances that migrate from materials pose a greater risk in this age group. REACH obligations apply alongside GPSR.
- Foreseeable misuse and the second-hand life: nursery products are routinely resold and handed down, and GPSR applies to second-hand products re-entering the market commercially (with limited exceptions, such as products supplied for repair or reconditioning). Safety over the product's reasonably expected service life, including worn straps and fatigued folding mechanisms, belongs in your assessment.
“GPSR asks two things of a manufacturer: make the product safe, and be able to prove it. The technical documentation (often referred to as the technical file) is that proof. For baby and toddler products it needs to include a documented risk analysis — the hazards you identified, from entrapment to stability, and the design decisions that address each one. Test reports support the analysis, but they are no substitute for it. Technical documentation that contains only test reports, without the underlying risk analysis and rationale, is one of the most common compliance failures we see.”
— Chris Giddings, Product Compliance Specialist, Hooley Brown
GPSR obligations through the supply chain
Manufacturers of baby and toddler products
Manufacturers carry the primary compliance burden. Before placing a product on the EU market, you must compile technical documentation containing a description of the product, its risk analysys, relevant test reports and other supporting evidence, together with details of the measures taken to address identified risks. This documentation must be retained for 10 years after the product has been placed on the market.
Every product needs a type, batch or serial number visible to the consumer (or on its packaging or accompanying documents where the product's size or nature prevents this), along with your business name and both postal and electronic contact details.
Instructions and safety information, covering assembly, correct installation, harness use, age and weight limits, and safe sleep guidance where relevant, must be provided in the language(s) determined by each Member State where the product is sold.
For manufacturers based outside the EU, GPSR requires an economic operator established in the EU to be responsible for the product under Article 16. Depending on your supply chain, that responsible person can be your EU importer, an appointed EU Authorised Representative or, in certain circumstances, a fulfilment service provider. Their details must appear on or with the product and in online offers.
You must also maintain public channels for consumers to report accidents or safety concerns, keep an internal register of complaints and corrective actions, and notify authorities through the Safety Business Gateway if a product turns out to be dangerous.
If a product has to be recalled, GPSR requires economic operators to directly notify all affected consumers who can be identified, and to offer at least two remedies from repair, replacement or refund. A single remedy is permitted only where the others would be impossible or disproportionate, and remedies must be free of charge, timely and without significant inconvenience.
Importers
Importers of baby and toddler products must verify that the manufacturer has prepared the required technical documentation, carried out the required risk analysis, and applied the appropriate identification and labelling before the product is placed on the EU market.
You'll also need to add your own contact details to the product or packaging (without obscuring the manufacturer's details) and ensure instructions are in the right languages for your sales market. On documentation, you must be able to make the technical documentation available to market surveillance authorities for 10 years, and keep supply chain traceability records for at least six. If an imported product proves dangerous, you must take corrective action and notify authorities, whether or not the manufacturer cooperates.
Distributors and retailers
Before making a product available, distributors must check that it carries the required identification, manufacturer and responsible person details, and safety instructions in the correct language. You must not sell products you have reason to believe are non-compliant.
Storage and transport conditions matter too: crushed cartons and damp warehousing can compromise materials, fittings, packaging and printed safety information. If a safety issue emerges, inform the manufacturer or importer immediately and ensure EU authorities are notified via the Safety Business Gateway.
Online sellers and marketplaces
Many nursery products are bought online, and GPSR applies in full to distance sales targeted at EU consumers. Every listing must display the manufacturer's name and contact details, the EU responsible person's details where the manufacturer is outside the EU, product identification including a picture of the product, its type and any other product identifier, and any warnings in a language easily understood by consumers in the target market.
Marketplaces have GPSR obligations too, including Safety Gate Portal registration and the rapid removal of dangerous listings. Independent testing has repeatedly found non-compliant children's products sold through online platforms, which is precisely why authorities are watching this channel closely.
How Hooley Brown can help with GPSR compliance
Baby and toddler products face some of the heaviest scrutiny of any consumer category. Hooley Brown works with manufacturers, importers and distributors of nursery items to meet GPSR requirements, from classification and standards mapping to development of GPSR technical documentation (technical files), labelling review and setting up the right Article 16 responsible person arrangement — including acting as your EU Authorised Representative where that's the appropriate route.
Book a free discovery call or email hello@hooleybrown.com to discuss GPSR.
This article was published in August 2026. Regulations, standards and enforcement guidance can change. Always verify current requirements and seek professional advice for your specific situation.
