Very small scale electronic goods manufacturing regulations
The key to safety for electronic goods is to use a cUL/CE approved external adapter, then the AC product directives do not apply to the toy as it is low voltage DC.

The EC (european commission) for EMC have released a new proposal as a legislation directive. 11/2011 to harmonize all members of the EU.
It complies with  business "proportionality" so as not to impose the same burden on smaller corporations. This framework adds to existing new framework (2008) that applied to accreditation, market surveillance and marketing.

The new framework is being proposed to raise consumer confidence in certified products so it must be legislated and be enforced.

It still retains "The conformity assessment obligation should require the manufacturer to perform an electromagnetic compatibility assessment of apparatus, based on relevant phenomena, in order to determine whether or not it meets the protection requirements under this Directive. ".
So that means someone who is qualified to assess your product's EMC must document   what tests were done to do this. This means Egress /Ingress radiated, conducted and ESD. How you conduct this does not mean you have to go to a certified agency to test it, but to test whether that is necessary.

They go on to say "identifying the electromagnetic compatibility characteristics of these installations should be sufficient to ensure exemption from the conformity assessment procedure." 

As I see it, any business that is responsible will conduct the necessary tests to see if it further tests are required. This proposed framework for legislation will give the EC more teeth.

i.e. By comparing a reliable competitor product who is certified with your own, might be suitable to document relative performance to assess exemption from conformity at a certified lab. But that takes an expert to decide.