Does the CRA apply to connected toys?
Likely yes
Likely yes. A toy with an app, a microphone, Bluetooth or Wi-Fi is connected hardware with embedded software, made available to consumers in the course of a commercial activity: a product with digital elements [[F-005]] [[F-007]].
The deciding factors
| Factor | If true | If false | Source |
|---|---|---|---|
| Made available on the EU market | Scope questions continue | Likely out of scope | F-101 |
| Supplied in the course of a commercial activity | Scope questions continue | Likely out of scope (or the open-source light regime) | F-007 |
| Has a direct or indirect connection to a device or network | It is a product with digital elements | Likely out of scope | F-005 |
| Product cannot perform a function without your own backend | That remote processing is part of the product | Only the installed part is the product | F-107 |
Check your own product
Start the short scope check with the product type pre-selected. Every legally material fact — EU availability, commercial activity, exclusions, your role — is asked, never assumed.
Example scenarios
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App-connected plush toy sold in EU toy stores
Likely in scope · role: _
Connected hardware sold commercially to consumers: a product with digital elements in scope.
Deciding fact: Art. 3(1), Art. 2(1)
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Toy whose speech features run on your cloud service
Likely in scope · role: _
In scope; where the toy cannot perform a function without your backend, that remote processing is part of the product.
Deciding fact: Art. 3(1), Art. 2(1)
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EU retailer selling a toy brand's connected robot in its stores
In scope — operator obligations differ by role · role: _
The toy is in scope; the retailer holds distributor obligations rather than manufacturer ones.
Deciding fact: Art. 3(1), Art. 2(1)
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Toy sold only through marketplaces that do not ship to the EU
Likely out of scope · role: _
Not made available on the EU market, so the Regulation does not apply.
Deciding fact: Art. 3(22)
Each scenario is a fixture: the shared CEMarque rules engine evaluates its inputs at build time and the page cannot be served if the outcome shown here differs from the engine's.
Edge cases
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Why
Connected toys are products with digital elements
The definition covers hardware products with a direct or indirect connection to a device or network, together with their remote data processing solutions [1]. A toy with Bluetooth, Wi-Fi or an app pairing meets it. Sold to consumers, it is made available in the course of a commercial activity [2] [3].
In addition to toy safety rules
This Regulation sits alongside, not instead of, product safety legislation for toys. Applicability here is decided only by the definition and the commercial-activity test [1] [2]. The sectoral exclusions do not remove toys as a category.
The app and the cloud
Where the toy is designed to rely on your own remote data processing and cannot perform a function without it, that remote processing is part of the product with digital elements [4] [5]. The companion app is itself installed software supplied commercially and is a product with digital elements in its own right [1].
Own-brand toys
Marketing a product under your own name or trademark makes you the manufacturer even if a contract manufacturer developed it [6]. A retailer selling another brand's toy is a distributor, with a different set of obligations; the scope check reports the role.
Timing
Article 14 reporting applies from 2026-09-11; full requirements and CE marking apply from 2027-12-11. Dates come from the Facts Table entries cited below, evaluated for the first example; run the check for your own product's dates.
What to do next
CRARequired only answers applicability. CEMarque carries your answers forward and adds your role, class, conformity route, dates, obligations, and a permanent cited verdict.
Check my product Run the full cited determination on CEMarque
Related applicability questions
Sources
- F-005 A product with digital elements is a software or hardware product and its remote data processing solutions, including components placed on the market separately, whose intended purpose or reasonably foreseeable use includes a direct or indirect logical or physical data connection to a device or network. Art. 3(1), Art. 2(1) EUR-Lex ↩
- F-007 The Regulation applies to products made available on the market in the course of a commercial activity; charging a price, charging for support, monetising via advertising or data, or otherwise intending to monetise are commercial activity. Art. 2(1), Art. 3(22), Recitals EUR-Lex ↩
- F-101 Made available on the market means supply for distribution or use on the EU market in the course of a commercial activity. Art. 3(22) EUR-Lex ↩
- F-006 Remote data processing means data processing at a distance for which the software is designed and developed by the manufacturer, or under the responsibility of the manufacturer, and the absence of which would prevent the product from performing one of its functions. Art. 3(2) EUR-Lex ↩
- F-107 Where a product depends on your own remote data processing (a backend or API without which it cannot perform one of its functions), that remote processing is part of the product: it is covered by the essential requirements, the technical documentation and market surveillance alongside the client software or device. Art. 3(1)–(2), Annex I, Annex VII EUR-Lex ↩
- F-106 Marketing a product under your own name or trademark makes you the manufacturer even if someone else developed it. Art. 3(13), Art. 21 EUR-Lex ↩
CRARequired answers applicability only, using scope logic and cited regulatory facts maintained by CEMarque, which encodes Regulation (EU) 2024/2847 and published guidance as of Facts v2026.09.4 (10 September 2026). Results are "likely" or "conditional" readings of your answers, not a legal opinion and not a conformity assessment. Run the full cited determination on CEMarque before you act. Methodology.