Directive 2014/53/EU · Del. Reg. 2022/30Generate my documentation — €99
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Your Bluetooth toy is covered by the Toy Safety Directive. But from 1 August 2025, it also needs cybersecurity documentation under the Radio Equipment Directive — even if it never connects to the internet.

You manufacture or sell educational robots, interactive plush toys, Bluetooth-connected tablets for children or any toy with a radio function that falls under Directive 2009/48/EC. You thought the Toy Safety Directive was your only regulatory concern. It is not. Art. 1(2)(c) of Delegated Regulation (EU) 2022/30 activates Art. 3(3)(e) of Directive 2014/53/EU for radio equipment covered by Directive 2009/48/EC — if the toy processes personal data. No internet connection required. A BLE toy that records voice, captures images or collects play data processes personal data under GDPR Art. 4(1). If the toy also connects to the internet, Art. 3(3)(d) applies as well. REDCheck generates the 5 PDF documents. 30 minutes. €99 per product. 100% in your browser.

Generate my RED documentation — €99Free: does my product need RED cybersecurity documentation?

€99 one-time payment · 5 PDF documents in ZIP · 30 minutes · 100% in your browser

Directive 2014/53/EU · Art. 3(3)(d)(e)(f) · Art. 21 + Annex V · Art. 18 + Annex VI · Art. 10(9) + Annex VII · Delegated Reg. (EU) 2022/30 · EN 18031-1, -2, -3

Bluetooth toys and EU cybersecurity: the numbers

Delegated Regulation (EU) 2022/30 treats radio toys as a special category. Art. 1(2)(c) activates cybersecurity requirements specifically for radio equipment covered by the Toy Safety Directive — with a lower threshold than general consumer electronics: no internet connection needed.

Art. 1(2)(c)
Toys under Directive 2009/48/EC with radio function: Art. 3(3)(e) applies even without internet, if personal data is processed
5 documents
Product classification, technical documentation, risk assessment, EU declaration of conformity, simplified declaration + label
Double directive
Your toy must comply with Directive 2009/48/EC (safety) AND Directive 2014/53/EU (radio + cybersecurity). Two separate documentation sets.

What REDCheck does with your toy data

You enter your product specifications. REDCheck structures the cybersecurity documentation requirement by requirement, following the EN 18031 categories.

1
Company details
Legal name, role under Directive 2014/53/EU (manufacturer, Art. 10), country of manufacture, EU contact.
2
Product classification
Determines which essential requirements apply. Art. 1(2)(c) of the Delegated Regulation covers toys under Directive 2009/48/EC. Art. 3(3)(e) (personal data protection) applies if the toy processes personal data — voice recordings, images, play patterns, child profiles. If the toy also connects to the internet, Art. 3(3)(d) (network protection) applies additionally under Art. 1(1).
3
Cybersecurity assessment
Requirement-by-requirement review mapped to EN 18031-1 (network) and EN 18031-2 (personal data) categories: access control, authentication, secure communications, software updates, vulnerability management.
4
Risk assessment
Assessment of implementation status for each applicable requirement of Arts. 3(3)(d) and (e). Maps your answers to a structured risk table.
5
EU Declaration of Conformity
Formal declaration under Art. 18 and Annex VI. Signed by the manufacturer. Basis for CE marking under Arts. 19–20.
6
Download ZIP
5 PDF documents generated in your browser. Add to your technical file alongside test reports and user manual. Retain for 10 years (Art. 10(4)).

Three mistakes toy manufacturers make about RED cybersecurity

COMMON ERROR

"Our toy only uses Bluetooth — no internet, no cybersecurity"

Art. 1(2)(c) of Delegated Regulation (EU) 2022/30 does NOT require an internet connection for Art. 3(3)(e) to apply. Radio equipment covered by Directive 2009/48/EC (toys) is a special category: if the toy processes personal data as defined in Art. 4(1) of GDPR, Art. 3(3)(e) applies regardless of internet connectivity. A BLE toy that records a child's voice processes personal data.

COMMON ERROR

"The Toy Safety Directive already covers everything"

Directive 2009/48/EC covers physical, chemical, mechanical and electrical safety of toys. It does NOT cover cybersecurity of radio functions. Directive 2014/53/EU covers radio equipment — including toys with Bluetooth, WiFi or any other radio technology. From 1 August 2025, Delegated Regulation (EU) 2022/30 adds cybersecurity requirements on top. Your toy needs BOTH: toy safety AND radio cybersecurity documentation.

COMMON ERROR

"Our toy doesn't collect personal data — it only plays sounds"

Check carefully. Art. 4(1) of GDPR defines personal data broadly: any information relating to an identifiable natural person. If your toy's companion app collects the child's name, age, play preferences, usage statistics or location — that is personal data. If your toy has a microphone that captures voice — that is personal data. If it only plays pre-loaded sounds with no data collection and no app, Art. 3(3)(e) may not apply — but Art. 3(3)(d) still applies if the toy connects to the internet.

What's in the ZIP

5 PDF documents generated from your product data. Each cites the exact article of Directive 2014/53/EU that it covers.

1

Product Classification

Art. 1, Del. Reg. (EU) 2022/30 + Art. 3(3), Dir. 2014/53/EU.

2

Cybersecurity Technical Documentation

Art. 21 + Annex V. Requirement-by-requirement documentation.

3

Risk Assessment

Arts. 3(3)(d) and (e). Structured risk table.

4

EU Declaration of Conformity

Art. 18 + Annex VI.

5

Simplified Declaration + Label

Art. 10(9) + Annex VII.

Look before you buy — Download sample dossier (PDF, fictitious product) — Real structure, real articles, real format. Fictitious data.

Generated from your data, in your browser. No product data leaves your computer.

What you pay

🧾 NOTIFIED BODY / TOY TESTING LAB
€5,000–12,000
Per toy model. 3–6 months. Queue time. 8 toy models = €40,000–96,000.
✓ REDCHECK
€99
5 documents. 30 minutes per model. 8 toy models = €792.

Technical documentation and third-party testing: two layers

● LAYER 1

Cybersecurity technical documentation (Annex V)

5 PDF documents. 30 min. €99 per product. The documentation that Art. 21 requires BEFORE your product can bear CE marking.

∅ LAYER 2

Conformity assessment by a Notified Body

If you fully apply EN 18031, you can self-declare via Module A (Annex II) without a Notified Body. If you partially apply or don't apply the harmonised standards, Art. 17(4) requires third-party involvement. REDCheck does not replace a Notified Body — it generates the documentation that is a prerequisite for any conformity route.

We do not sell testing. We do not sell consulting. We sell the tool that structures your cybersecurity documentation under Art. 21 and Annex V.

What happens without cybersecurity documentation

Art. 46 of Directive 2014/53/EU requires Member States to establish penalties. Children's products receive heightened scrutiny.

🧸
Toy recall and market withdrawal
Immediate + Safety Gate

Market surveillance authorities treat non-compliant children's products with heightened urgency. A toy that fails cybersecurity requirements may be recalled under Arts. 40 and 43 — and the recall will be published in the Safety Gate (RAPEX) system, visible to all 27 Member States.

🇪🇺
Safety Gate (RAPEX) notification
Reputational damage

Non-compliant toys are published in the EU Safety Gate system. The product, the manufacturer and the country of origin are publicly identified. For children's products, media amplification is immediate.

🛒
Marketplace listing removal
Revenue loss

Amazon, eBay and European marketplaces require conformity documentation. Children's products receive heightened scrutiny. Listings can be removed without prior notice.

Alternatives

AlternativeCostWhat you get
Notified Body / toy testing lab€5,000–12,000 per model3–6 months. Full third-party assessment.
Cybersecurity consultancy€5,000–15,000 per modelCustom report. Weeks of wait.
Assemble documentation yourself€0 (your time)EN 18031 has 600+ pages. No guidance.
REDCheck€995 documents, 30 min, per model

Manufacturing more than one toy model with radio function?

If you document 10 or more product models, write to us for the Professional Pack: €999 for 70 generations with a single license key.

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What REDCheck guarantees and what it does not

REDCheck generates a document structured under Art. 21 and Annex V of Directive 2014/53/EU based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as manufacturer of the radio equipment.

We guarantee that the document structure follows Art. 21 and Annex V of Directive 2014/53/EU and that the legal references cited are correct as of the latest verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case, nor by a commercial buyer in a procurement process.

REDCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions — Bluetooth toys EU cybersecurity

My toy uses BLE but never connects to the internet. Does Art. 3(3)(d) apply?
Art. 3(3)(d) applies to radio equipment that can communicate over the internet, directly or indirectly (Art. 1(1) of the Delegated Regulation). If your BLE toy connects only to a phone via Bluetooth and the phone connects to the internet, the toy communicates indirectly over the internet — Art. 3(3)(d) applies. If the toy uses BLE only for local interaction (sound playback, no cloud, no app with internet) AND does not process personal data, neither 3(3)(d) nor 3(3)(e) may apply. Use the free test to check.
Does Art. 3(3)(e) apply to ALL toys with radio, or only those that process personal data?
Art. 1(2)(c) of the Delegated Regulation activates Art. 3(3)(e) for toys under Directive 2009/48/EC — but only if the toy is 'capable of processing personal data as defined in Art. 4(1) of GDPR or traffic data and location data as defined in Art. 2 of Directive 2002/58/EC.' The toy must have the CAPABILITY to process such data. A toy that physically cannot record, store or transmit personal data is not subject to Art. 3(3)(e).
We already passed EN 71 testing for the Toy Safety Directive. Does that count?
No. EN 71 (parts 1–14) covers mechanical/physical safety, flammability, migration of chemicals, etc. It does not cover cybersecurity. The relevant standards for RED cybersecurity are EN 18031-1 (network) and EN 18031-2 (personal data). These are entirely separate test series with different scope and requirements.
What happens when the CRA replaces the RED cybersecurity requirements?
Delegated Regulation (EU) 2022/30 will be repealed with effect from 11 December 2027, when the Cyber Resilience Act — Regulation (EU) 2024/2847 — enters full application. REDCheck covers the window from 1 August 2025 to 11 December 2027. For CRA documentation from that date, SolidwareTools offers CRACheck.
Is it a subscription?
No. One-time payment. Each license includes a 30-day editing window and up to 10 regenerations. The 5 PDF documents you download are yours permanently.
Can I request a refund?
Under Art. 16(m) of Directive (EU) 2011/83 on consumer rights, by activating the license you give express consent to the immediate generation of the digital content, waiving the 14-day right of withdrawal. Refunds are accepted only for reproducible technical failures reported to hello@solidwaretools.com within 14 days of purchase.
What if the regulation changes?
If Directive 2014/53/EU, Delegated Regulation (EU) 2022/30 or the EN 18031 standards change during your license validity period, you can regenerate the documents with the updated version of the generator at no additional cost.
⚠️ Important notice: REDCheck is a documentary self-assessment tool, not legal advice or a third-party audit. The document is generated from the data you enter. The accuracy of the data is your responsibility under Art. 10(1) of Directive 2014/53/EU. REDCheck does not replace a conformity assessment by a Notified Body where required under Art. 17(4) of the Directive.

Your toy has a radio function. From 1 August 2025, it needs cybersecurity documentation. Generate it in 30 minutes.

Five PDF documents. Art. 21 and Annex V fully structured. Directive 2014/53/EU. Your product data never leaves your computer. The ZIP you download is yours permanently.

€99 per product
One-time payment · No subscription · 30 minutes · 10 regenerations · 30-day editing window · Professional Pack: €999
Generate my RED documentation — €99
✓ Last regulatory check: 6 May 2026 · No substantive changes detected · View history