From box art to battlefield, the EU’s newly proposed Toy Safety Regulation is poised to transform the wargaming landscape. With tabletop miniatures classified as toys in the TSR, and a set of new rules for imitation firearms, painting models might never be the same. Learn how this legislation will affect manufacturers, retailers, and even your own collection in gaming stores and events.

In February 2025, the EU published communication C/2025/1032 on its draft TSR. This document is the position of the European Parliament, adopted at first reading in March 2024, with a view to the adoption of the draft TSR and the repeal of Directive 2009/48/EC (Toy Safety Directive, TSD, current consolidated version to December 2022).

How does this affect wargaming? 

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Imitation firearms cannot be sold to under-18s. Toy retailers must be careful not to inadvertently sell what may seem to be a harmless toy gun, but which the law may actually view as being an imitation firearm. 

The new draft legislation which categorises the wargaming industry as toy manufacturers, means they will have to abide by the legislation if they wish to sell their product to the European Union.

TSD (Toy Safety Directive) compliance comparison chart
Some examples given for non-compliant and compliant firearm paint jobs

Product shots on box art and marketing will require painting firearms (like boltguns, stubbers, or fusion guns) in bright, non-realistic colours such as yellow, orange, or red. Miniatures for public display such as those found in Warhammer stores from Games Workshop Ltd. will need to adhere to these standards, too. From what we’ve heard, Warhammer World will be partially closed for several months later this year so that the models in the exhibition area can be revised and updated. In the meantime, a temporary exhibition entitled “The red period: ‘Eavy Metal works 1983 – 1998” will be set up instead.

It is currently unclear if the plastic sprues featuring weapons will have to be moulded in brightly coloured plastic, too. There is also speculation that miniatures brought into public settings such as gaming cafés or Warhammer retail stores by end users will have to have at least the muzzles painted in bright colours for gaming purposes. However, that might only affect models that have been put into circulation after the directive comes into effect.

What you can do now

To avoid any restrictions during the transition period (e.g., the disqualification of certain models at official events like tournaments), we recommend the following:

As one of the leading tabletop hobby websites, Tale of Painters were hired as consultants to aid the research and development process of the draft legislation in an advisory capacity. For example, we provided painted miniatures for assessment. We’ll keep you updated on future developments.

Update: Fortunately, this is just an April Fool’s joke 🙂

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