Digital product passport for toys: when does it apply and what must it contain?

Legal basis: the new Toy Safety Regulation

Regulation (EU) 2025/2509 was published in the Official Journal on 12 December 2025 and entered into force on the twentieth day after. It applies from 1 August 2030; some articles on notified bodies and the Commission’s powers apply from 1 January 2026 (Art. 59). On 1 August 2030 it repeals Directive 2009/48/EC (Art. 56).

Here the passport does not come through the ESPR but from the Toy Safety Regulation itself (Chapter V). Technically it has to fit the ESPR: data carriers and identifiers follow its standards (Art. 21(1)), and the identifiers go into the same registry (Art. 22(1)). The basics are in the guide Digital product passport: deadlines and product groups.

Timeline with status

What the passport must contain

The passport corresponds to a specific toy model, is accurate, complete and up to date, is available in the language required by the Member State and remains available for ten years after the toy is placed on the market, including after an insolvency (Art. 19(2)). Part I of Annex VI requires at least:

• the unique product identifier of the toy
• name and address of the manufacturer and, where applicable, of the authorised representative, with the unique operator identifier
• the economic operator responsible for the tasks under Article 4 of Regulation (EU) 2019/1020
• a statement that the passport is issued under the sole responsibility of the manufacturer
• identification of the toy with a colour image, and the commodity code where applicable
• references to all Union law the toy complies with, and to the harmonised standards or common specifications used
• where applicable, the notified body and its certificate, plus the CE marking
• the list of allergenic fragrances subject to labelling
• the communication channel under Article 7(12) and the service provider hosting the back-up copy

Data carrier, online sales and customs

The data carrier sits on the toy or on an affixed label; only where that is not possible on the packaging or accompanying documentation. It has to be clearly visible before any purchase, including in distance sales (Art. 19(7)). Distributors and providers of online marketplaces receive a digital copy free of charge, at the latest five working days after a request (Art. 19(12)). Whoever imports toys into the EU gives customs the unique registration identifier from the registry (Art. 23(2)), so a manufacturer outside the EU needs the passport in place before the goods are declared.

The passport may also contain safety information and warnings and instructions for use (Annex VI, Part II). If the toy has radio or electronic functions, the passport can also replace the declaration of conformity under directives such as 2014/53/EU (Art. 19(5)). Today, toys sold online need the information under Article 19 GPSR, see GPSR obligations for online sellers.

What you can do today

• Keep a list per model of the legislation and standards you rely on. It goes into the passport later.
• Have a colour image per model that is good enough for identification.
• Plan space for a data carrier on the toy itself, not only on the packaging.
• Decide who will store the back-up copy. It has to be a digital product passport service provider (Art. 19(13)).
• If the toy contains a rechargeable battery, also check the product passport for batteries.

Further reading

• The product passport module: permanent address, QR code and documents per product
• The basics in the guide Digital product passport: deadlines and product groups
• Every date per product group in the deadline tracker
• All industries at a glance: product passport by industry

Frequently asked questions