Annex III, Class I (18)
Internet-connected toys with social interactive or location-tracking features
Connected toys are important product, class i under Regulation (EU) 2024/2847 when the listed function is the product's core functionality. Children cannot assess risk and the data involved is uniquely sensitive; several high-profile toy breaches preceded the regulation.
Updated 2026-09-12 · Operational guidance, not legal advice.
- Classification
- Important product — Class I
- Conformity route
- Self-assessment only with fully applied standards
- Reference
- Annex III, Class I (18) · Art. 32(2)
What the annex says
Internet connected toys covered by Directive 2009/48/EC that have social interactive features (e.g. speaking or filming) or that have location tracking features.
Paraphrase of Annex III, Class I (18); the Official Journal text governs.
Typical products in this category
- Toys with microphones, cameras or chat features
- GPS-enabled toys and trackers marketed as toys
Where the boundary runs
Connected toys without social interaction or location features are default products (still in scope of the CRA and the Toy Safety Directive). Children's wearables are a separate Class I category.
The test is core functionality (Article 7). Record the reasoning and the approver: the category determines the conformity assessment route and market surveillance authorities can challenge it.
Conformity assessment
Self-assessment only with fully applied standards. Module A is permitted only where harmonised standards, common specifications or a European cybersecurity certification scheme are applied in full; otherwise EU-type examination (Module B) followed by conformity to type (Module C), or full quality assurance (Module H). (Art. 32(2))
What to prepare operationally
- Data minimisation and parental controls belong in the risk assessment and user information.
- The support period must reflect realistic use; toys are handed down.
- Plan for coordinated disclosure with consumer-protection authorities in the loop.
- Maintain an SBOM per released version, match it continuously against vulnerability intelligence, and keep the Article 14 runbook rehearsed — these apply to every product with digital elements, listed or not.
Frequently asked
- Is every connected toys product an important product — class i?
- Only where the listed function is the product's core functionality (Article 7). Connected toys without social interaction or location features are default products (still in scope of the CRA and the Toy Safety Directive). Children's wearables are a separate Class I category.
- What changes compared with a default product?
- Module A is permitted only where harmonised standards, common specifications or a European cybersecurity certification scheme are applied in full; otherwise EU-type examination (Module B) followed by conformity to type (Module C), or full quality assurance (Module H). The essential requirements of Annex I, the vulnerability-handling duties and Article 14 reporting apply to every product with digital elements regardless of category.
- From when?
- Article 14 reporting obligations have applied to all manufacturers since 11 September 2026. Conformity assessment and CE marking under the CRA apply from 11 December 2027; products placed on the market before that date are not required to be re-assessed unless substantially modified.