32025R2509#rec_15Regulation (EU) 2025/2509 of the European Parliament and of the Council

Recital (15)

In accordance with Regulation (EU) 2024/1689, toys with AI systems as safety components that require a third-party conformity assessment are classified as high-risk AI systems. The choice by the manufacturer of the conformity assessment procedures for such toys, if it is possible to opt out of a third-party conformity assessment where harmonised standards have been applied, should not affect the classification as a high-risk AI system in accordance with Article 6(1) of that Regulation. Furthermore, in accordance with Regulation (EU) 2024/2847, internet-connected toys that have social interactive features, such as speaking or filming, or that have location-tracking features are considered to be important products with digital elements (Class I) and require a third-party conformity assessment, unless the manufacturer has applied relevant harmonised standards, common specifications or European cybersecurity certification schemes at assurance level at least substantial.

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