Legal sale of Labubu and Lafufu: What do sellers, importers and producers need to consider?
Labubu and Lafufu are popular collectible figures and cuddly toys that are in high demand, especially among children and collectors in Asia, and this trend has now reached Europe.
These products are often sold as toys or plush figures in online shops or on marketplaces such as Amazon, eBay, or Etsy – some as originals, some as imitations. However, strict product safety requirements apply when placing these products on the EU market, and these are often not met.
Product compliance: What requirements apply to the sale of Labubu, Lafufu, and similar products?
As soon as Labubu or Lafufu products are sold as toys or cuddly toys in the EU – whether as originals or replicas – the provisions of the Toy Safety Directive 2009/48/EC and national product safety laws such as the Product Safety Act (ProdSG) in Germany apply.
What are the typical defects found in imported figures such as Labubu and Lafufu?
- Missing or incomplete CE marking
- Eyes and other small parts that can fall out
- Loose limbs (hands/feet)
- Poor seams and workmanship
- Missing accompanying information and manufacturer's identification
Checklist: Which EU requirements apply to Labubu figures (classified as toys)?
If Labubu is sold as a toy (e.g. plush toy or collectible figure for children under 14 years of age) in the EU, the following requirements must be met:
Legal basis
- Toy Safety Directive 2009/48/EC
- Product Safety Act (ProdSG)
- Regulation (EC) No. 1907/2006 (REACH) – Chemicals Regulation
- Regulation (EU) 2019/1020 – Market surveillance
- Packaging Directive 94/62/EC (e.g. labelling of packaging)
Product requirements
- CE marking correctly and permanently affixed
- EU declaration of conformity available (to be provided on request)
- Safety requirements in accordance with EN 71 series of standards fulfilled:
EN 71-1: Mechanical and physical properties (e.g., loose parts, sharp edges)
EN 71-2: Flammability
EN 71-3: Migration of certain elements (e.g. heavy metals in paints and materials) - Age classification correctly defined, e.g. “Not suitable for children under 3 years of age” for small parts (note: GamePro reported on July 8, 2025: It has been officially confirmed that Labubus are NOT suitable for children – manufacturer announces age recommendation)
- Warning notices clearly, visibly, and comprehensibly affixed
- Name and address of the responsible EU economic operator on the product or packaging
Documentation requirements
- Technical documentation including risk assessment, test reports, materials
- Proof of traceability (e.g. batch number, origin)
- Product liability and recall management prepared
When must products be recalled or withdrawn from the market?
If a safety defect is identified, there is an obligation to withdraw and, if necessary, recall the product. Distributors and importers are obliged to:
- Inform the authorities (e.g. via the EU Safety Gate system)
- Withdraw affected products from the market or recall items that have already been sold
- Take appropriate measures to minimize risk (e.g. warning notices or retrofits)
Market surveillance authorities (e.g. trade inspectorates, Federal Network Agency) carry out regular checks, especially on imports from third countries such as China.
What recommendations does trade-e-bility have for sellers and producers of imitation products?
Anyone wishing to sell products similar to Labubu or Lafufu should definitely:
- Prove CE conformity
- Arrange for safety tests (EN 71) to be carried out before import
- Have the trademark and design rights legally assessed. (This text does not go into detail about trademark rights and licensing issues relating to “Labubu” or “Lafufu.” However, commercial sellers should definitely check whether they are legally permitted to use the trademarks or designs. On July 2, 2025, BILD reported on the “trademark dispute over cult figure Labubu.”
- Choose a transparent supply chain and reliable partners
- Secure product liability, e.g. through appropriate insurance
Conclusion: Whether original or inspired: Anyone wishing to sell Labubu, Lafufu, or similar plush figures and toys in the EU must be aware of their responsibilities. Product conformity, product safety, and clear legal relationships are essential – not only from a regulatory perspective, but also to protect consumers. Only through consistent testing and implementation of the applicable regulations can fines, product recalls, and damage to your image be avoided.
Questions about selling Labubu in compliance with regulations? The trade-e-bility consulting team is happy to assist you at +49/40/750687-300 or send us an email.
