Binding 1 Aug 2030

The toy
digital product
passport

From 1 August 2030, toys covered by Regulation (EU) 2025/2509 need a digital product passport when placed on the EU market. This obligation comes from the adopted Toy Safety Regulation, not an ESPR delegated act.

Timing

Already in force, applying in 2030

The gap is the transition, not the wait

The Toy Safety Regulation was published in the Official Journal on 12 December 2025 and entered into force on 1 January 2026. Its general application, including the mandatory passport, begins on 1 August 2030, and it repeals the Toy Safety Directive 2009/48/EC on that date.

Some of it already applies. Articles 28 to 44 and Articles 49 to 55 have been in effect since 1 January 2026.

The dates

Five dates that actually matter

A four and a half year transition sounds generous until you count what has to happen in it.

Date What happens
12 Dec 2025 Publication of Regulation (EU) 2025/2509. Directive 2009/48/EC is repealed later, from 1 August 2030.
1 Jan 2026 Entry into force. Articles 28 to 44 and 49 to 55 begin to apply; the general application date remains 1 August 2030.
1 Aug 2030 General application for toys within the regulation’s scope, including the passport requirement. Directive 2009/48/EC is repealed, subject to the transition rules.
1 Feb 2031 EC type-examination certificates issued under Article 20 of Directive 2009/48/EC remain valid until this date, unless they expire earlier.
Before 1 Aug 2030 Toys placed on the market before 1 August 2030 in conformity with Directive 2009/48/EC benefit from the transition rule.

Article 55 allows toys placed on the market in conformity with Directive 2009/48/EC before 1 August 2030 to continue to be made available. It does not set a general sell-through end date for those toys.

What counts as a toy

  • Under 14

    Products designed or intended, whether or not exclusively, for use in play by children under 14 years of age.

  • Reasonable assumption

    “Intended for use in play” is read as what a parent or supervisor could reasonably assume, not just what the packaging claims.

  • Connected toys

    Connected products can be toys within the regulation’s scope. Assess relevant digital risks and any separately applicable privacy and cybersecurity rules.

  • Sold online

    Distance selling and marketplace listings are in scope, with obligations on the platforms themselves.

  • Imported toys

    Importers have specific checking and compliance duties. Manufacturers outside the EU also retain the manufacturer obligations.

  • Scope and exclusions

    Check the regulation’s scope and Annex I exclusions for your product, especially borderline products.

Review borderline products against the new regulation’s definition and exclusions. Do not assume an earlier classification automatically settles the position under the new rules.

Passport content

What the toy passport must carry

The regulation sets the core passport requirements and Annex VI content. Further technical measures and amendments may follow. This is a conformity-focused passport, and it does not make the entire technical file public.

Required physical warnings and markings remain on the toy, packaging or accompanying material as specified by the rules.

  1. Conformity statement

    The passport replaces the EU declaration of conformity under the toy rules and contains the conformity information required by Annex VI.

  2. Required passport information

    Use Annex VI to identify the required fields. Distinguish passport information from the separate technical documentation and safety assessment duties.

  3. Applicable safety rules

    The toy must meet the relevant safety requirements, including chemical restrictions. A passport does not replace evidence of compliance.

  4. Traceability information

    What the product is, which batch or type, and how it can be identified across the supply chain.

  5. Responsible operator identification

    Who placed it on the market and who answers for it, accessible to customs and market surveillance.

Three regimes

Not every passport is an ESPR passport

Three separate legal routes produce something called a digital product passport. They are not the same instrument and they do not arrive together.

Regime How it works
Batteries Regulation (EU) 2023/1542 requires passports from 18 February 2027 for EV batteries, light means of transport batteries and industrial batteries with a capacity greater than 2 kWh.
Toys Regulation (EU) 2025/2509 requires passports from 1 August 2030 for toys within its scope when placed on the market. Its focus is toy safety and conformity.
ESPR groups Regulation (EU) 2024/1781 is an adopted framework. Product-specific acts set the detailed DPP obligations, including fields, granularity, access and application dates. Other ESPR provisions can already apply.

Responsibility

Who carries the obligation

The regulation assigns explicit duties to every operator in the chain, including the platforms.

  1. Manufacturer

    Carries out the required safety and conformity assessment, prepares technical documentation and provides the digital product passport when the new requirements apply.

  2. Importer

    Checks that imported toys meet the applicable requirements. These duties do not remove the obligations of the manufacturer outside the EU.

  3. Fulfilment

    Fulfilment service providers are given explicit obligations, closing a gap the old Directive left open.

  4. Marketplace

    Online marketplaces carry duties of their own, and customs can use passport data to screen imported toys.

If you import toys and sell them under your own brand, you are the manufacturer in the regulation’s terms. That is not new, but the passport makes it visible to a customs officer with a phone.

Worn clown figure on a playground ride with chipped green, red and white paint.

Three things this is not

  • Not an ESPR delegated act. The toy passport comes from its own regulation and does not depend on the ESPR working plan.

  • A passport does not replace required physical labelling and warnings. Their location and presentation must follow the toy rules.

  • Preparation can begin before 2030. Allow time for supplier information, evidence review and any testing your products actually need.

Access model

Who sees what

  1. Consumers Scan the code, see safety data
  2. Retailers Conformity before listing
  3. Customs Screening at the border
  4. Authorities Access under the applicable rules

The passport supports access to toy information and checks by customs and market surveillance authorities. The information available to each actor follows the applicable rules.

Problems with required passport information can affect compliance checks and the release of a shipment. The result depends on the issue and the relevant procedures.

Readiness

Most of this already exists on paper

Existing conformity documents, safety assessments, test reports and traceability records are a useful starting point. Check what you actually hold and what must be updated for the new rules.

Some information will need to be structured for the passport. This does not mean that every supporting document becomes publicly accessible.

  • Declaration of conformity

    Already mandatory, already drawn up per product.

  • Technical documentation

    Exists for CE marking, usually as documents rather than data.

  • Traceability

    Batch and type identification is standard practice for recalls.

  • Safety assessment

    Already required under the current Directive, including flammability and hygiene. Review changes under the new regulation, including relevant digital risks.

  • Chemical testing

    Review the expanded restrictions and determine whether existing evidence is sufficient or additional testing is needed.

  • Machine-readable

    Review how existing records can supply the structured information required by the passport.

What to do now

Four years is less than it sounds

  • Review the chemical requirements

    Compare the new restrictions with your materials and existing evidence. Arrange additional testing where needed and allow realistic lead times.

  • Clarify supplier requests

    Agree the documents, product references and evidence you need. Clear requests and realistic response times can make preparation easier.

  • Map the technical information

    Gather the documents and traceability records you already hold. Identify the data needed for the passport and any remaining gaps.

  • Check your sales partners’ requirements

    Ask retailers and marketplaces which documents and formats they require and from what date. Earlier commercial requirements are not a universal legal deadline.

FAQ

See all questions

When do toys need a digital product passport?

From 1 August 2030 for toys within the regulation’s scope when placed on the EU market. Regulation (EU) 2025/2509 entered into force on 1 January 2026, and some provisions already apply.

Is the toy passport part of ESPR?

No. It comes from the Toy Safety Regulation, which is its own instrument. It does not depend on an ESPR delegated act or on the ESPR working plan.

Does it apply to every toy or only some?

The passport requirement applies to toys within the regulation’s scope when placed on the EU market from 1 August 2030. Check the definition and exclusions. There is no battery-style capacity threshold for toys.

We import toys from outside the EU. Who is responsible?

Both the manufacturer and importer have duties. An importer must check compliance before placing the toy on the market. If you market it under your own name or trademark, manufacturer obligations can apply to you.

What happens to toys already on the market in 2030?

Toys placed on the market in conformity with Directive 2009/48/EC before 1 August 2030 may continue to be made available under Article 55. EC type-examination certificates issued under Article 20 of the Directive remain valid until 1 February 2031 unless they expire earlier.

Does the passport replace the label and the warnings?

No. Warnings, age markings and safety information a buyer needs before purchase stay physically on or with the toy. The passport supplements them.

Should we wait until closer to 2030?

You can begin by reviewing product records and supplier evidence. Plan any changes or testing that your products need, and check the actual requirements of your sales partners.

A confirmed date and a practical starting point

The regulation gives toy businesses a confirmed application date and core passport requirements. DPPVIEW can help organise existing product information and identify gaps through our passport preparation service. Hosting is in development.

Discuss passport preparation

Sources

This page describes adopted law. Every date and obligation traces to Regulation (EU) 2025/2509 or to the European Commission’s own announcement.