Regulation (EU) 2025/2509 is final sector law. The DPP applies to toys placed on the EU market from 1 August 2030. Article 57 allows toys lawfully placed earlier under Directive 2009/48/EC to remain available without the new passport. Detailed access rights still depend on delegated acts under Article 49.
Toy DPP is a legal obligation with a fixed date. The question is no longer whether it will apply, but how to organise safety, compliance and substance data before 1 August 2030.
The European Commission published its proposal to replace Directive 2009/48/EC with a directly applicable regulation. The proposal introduced a mandatory Digital Product Passport for toys, strengthened chemical safety requirements, added connected-toy provisions and enhanced market surveillance powers.
The Regulation entered into force on 1 January 2026. Most provisions apply from 1 August 2030, when Directive 2009/48/EC is repealed; specified institutional and delegated-power provisions apply earlier (Articles 56–59).
Commission Implementing Decision (EU) 2026/1736 published the references of six CEN/CENELEC JTC 24 DPP standards in the Official Journal. They support a presumption of conformity with ESPR Articles 10 and 11 only to the extent covered. FprEN 18239 and FprEN 18246, together with WI JT024009, remain to be monitored. Companies should prepare data-carrier implementation, digital Declaration of Conformity workflows and substance-reporting systems. Connected-toy manufacturers should assess alignment with the Cyber Resilience Act (the EU cybersecurity law for products with digital elements).
The ESPR (Ecodesign for Sustainable Products Regulation) mid-term review in 2028 may bring additional alignment between the toy-specific DPP and broader product-category rules. Companies should test DPP publication workflows and validate data completeness across the full product portfolio.
Regulation (EU) 2025/2509 is final sector law. The DPP applies to toys placed on the EU market from 1 August 2030. Article 57 allows toys lawfully placed earlier under Directive 2009/48/EC to remain available without the new passport. Detailed access rights still depend on delegated acts under Article 49. Article 19(5) requires all information demanded by the listed Union acts before the DPP can fulfil their declaration-of-conformity obligations. The replacement mention in Article 19(6) and Annex VI Part I(h) is additional, not sufficient on its own. Annex V does not require a separate full DoC as a universal toy technical-file element.
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This addendum is based directly on Regulation (EU) 2025/2509 and clarifies what may sit in the digital passport layer and what must still be physically present on, or accompany, the toy.
For toys, the digital product passport replaces the EU declaration of conformity and, where it contains all required information, can also serve declaration-of-conformity functions under other applicable Union product rules.
The Regulation explains that manufacturers should be able to include warnings in digital format through the DPP. However, warnings still have to be marked on the toy, an affixed label or the packaging and, where appropriate, in the instructions that accompany the toy.
Manufacturers must ensure the toy is accompanied by instructions for use and safety information in the language or languages required by the Member State concerned. The DPP can add a digital copy or extra guidance, but it does not remove that accompanying-information duty.
The DPP is accessed through a data carrier physically present on the toy or on an affixed label. If the size or nature of the toy does not allow that, it may be placed on the packaging or documentation accompanying the toy. Additional digital information may be offered through the same carrier, but it must be clearly separated from the mandatory passport layer.
Scope for toys with digital elements, support, user information and separate application dates.
REACH Article 33 and the 0.1% threshold at constituent-article level, paragraph 82.
Each row identifies the information location or type of duty. A label, documentation or process duty does not mean publication in the DPP is required. Supporting passport data do not remove duties under other legislation. See details for conditions and dates.
Access badges are shown only where label or technical-documentation rules establish access. No badge does not mean public access: these fields appear under “All”. Detailed DPP access rights will be set by acts under Article 19(2)(f) and Article 49(1)(d) of Regulation 2025/2509.
attributes: 73 · clusters: 8
Technical documentation must be available to competent authorities under the applicable rules. This does not require publishing all documentation in the DPP. Delegated acts under Article 49 will set detailed access rights to passport data.
Source labels (e.g. ERP = enterprise resource planning system, PIM = product information management, Lab = laboratory, Legal = legal department) indicate which enterprise system typically holds each data cluster. They are guidance for IT integration, not regulatory requirements. This list combines toy passport data explicitly mentioned in Annex VI of Regulation (EU) 2025/2509 with supporting technical-file, conformity and supply-chain data commonly needed to operate the passport in practice. Official legal source for the minimum passport layer: Article 19 and Annex VI of Regulation (EU) 2025/2509; detailed access and system rules still depend on delegated acts under Article 49.
The Toy Safety Regulation applies to all economic operators in the toy supply chain:
Toys are products designed or intended, whether or not exclusively, for play by children under 14. Check exclusions against Annex I, including bicycles with a maximum saddle height above 435 mm. Sports equipment and educational products are not excluded without qualification; their precise description and intended use matter.
