Digital Product Passport for Toys
A real passport obligation with a real date, and it is not ESPR. Regulation (EU) 2025/2509, the new Toy Safety Regulation, creates a binding toy Digital Product Passport that applies from 1 August 2030, when Directive 2009/48/EC is repealed. It is adopted law, so the data model is knowable today even though the date is years out. Toys placed on the market before that date may continue to be made available with no end date, so catalogues will be mixed for years.
Passport binding (Art. 19)
1 Aug 2030
Toy Safety Regulation
2025/2509
Passport granularity
Model level
Applicable EU regulations
Regulations covering toys
Toy Safety Regulation
(EU) 2025/2509
In force since 1 January 2026 and applicable from 1 August 2030. Art. 19 creates a binding toy passport at model level with the 14 Annex VI Part I data points, 10-year availability, and a Safety Gate Portal link displayed whenever the passport is accessed. The Art. 49(1) delegated act setting technical requirements and access rights is not adopted yet.
Key articles
- Art. 19 - Toy digital product passport, from 1 Aug 2030
- Art. 19(11) - Safety Gate Portal link shown on access
- Art. 19(13) and Annex VI Part I(n) - Back-up via a DPP service provider
- Art. 20 - No consumer registration, no password, no tracking beyond the strictly necessary
Ecodesign for Sustainable Products Regulation
(EU) 2024/1781 (ESPR)
The toy passport is NOT an ESPR passport. Toys are not an ESPR priority product group; recital 57 of Reg. (EU) 2025/2509 only says ESPR might cover toys in the medium term. What the toy regulation does borrow is ESPR's identifiers and data carriers (Art. 21) and the ESPR registry (Art. 22).
Key articles
- Art. 12-13 - Identifiers, data carriers and the EU DPP registry
REACH Regulation
(EC) No 1907/2006
Regulates chemicals in toys, including restrictions on phthalates, heavy metals and other substances of concern. Binding today.
Key articles
- Annex XVII - Restrictions
- Art. 33 - SVHC communication
Key dates
Compliance timeline for toys
Each entry is tagged with how firm it is. Binding means the date is fixed in the Official Journal. Adopted means the instrument exists but the date has not arrived. Indicative means it comes from a Commission working plan or our own estimate and is not law.
18 Jul 2024
BindingESPR enters into force
Framework law. It does not cover toys, and the toy passport comes from a different instrument entirely.
Reg. (EU) 2024/1781
1 Jan 2026
BindingToy Safety Regulation enters into force
Regulation (EU) 2025/2509 became law. Its substantive obligations, including the passport, wait for the application date.
Reg. (EU) 2025/2509
Not adopted
Indicative, not lawArt. 49(1) delegated act on toy passport technical rules
The delegated act setting toy passport technical requirements and access rights has not been adopted. Until it is, the exact carrier and access-tier design is unsettled.
Reg. (EU) 2025/2509 Art. 49(1)
1 Aug 2030
BindingToy passport binding
Model-level passport with the 14 Annex VI Part I data points, available for 10 years, showing a Safety Gate Portal link on every access, with a back-up copy held by a DPP service provider. Directive 2009/48/EC is repealed on the same date.
Reg. (EU) 2025/2509 Art. 19 and Annex VI Part I
What compliance reviewers look for
DPP data requirements for toys
Where no delegated act has been adopted for this category, the list below is our reading of the likely data set, not a legal requirement. Collecting it early is still the work that takes the longest. Everything below is supported out of the box in LabelEU.
Safety and chemicals
- CE marking and EU declaration of conformity
- Chemical migration limits (heavy metals, phthalates)
- REACH SVHC declaration
- Age grading and choking hazard warnings
Traceability and identification
- Manufacturer and importer identification
- Batch or serial number for traceability
- Responsible person in the EU (GPSR)
- Country of manufacture
Sustainability and materials
- Primary material composition
- Recycled content share (where applicable)
- End-of-life disposal guidance
- GS1 Digital Link URL and QR code
How LabelEU helps
Built for toys compliance
Chemical compliance tracking
Record phthalate levels, heavy metal migration limits, and REACH SVHCs in structured fields with threshold alerts.
Age grading and warnings
Add age recommendations, choking hazard warnings, and safety pictograms that display alongside product data in the passport.
Batch traceability
Link each toy batch to its production data and test reports. If a recall happens, the QR code shows the latest safety notice.
Product examples
Common toys and their key requirements
Plastic building blocks
- Phthalate and heavy metal compliance
- Age grading and small parts warning
- Material composition and recyclability
Wooden toy train set
- Paint and coating chemical safety
- Wood origin and finish materials
- CE marking and conformity declaration
Electronic learning tablet (toy)
- Battery safety and type
- RoHS and REACH compliance
- Software/data privacy considerations
Frequently asked questions
Common questions about Digital Product Passports for toys.
Ready to create toys passports?
Ship the QR with confidence today and keep updating the passport as your supply chain evolves.