Sector
Toys digital product passport
The new Toy Safety Regulation was adopted on 25 November 2025 and published on 12 December 2025. It replaces Directive 2009/48/EC and makes the Digital Product Passport mandatory for all toys placed on the EU single market.
Key dates
28 July 2023
Commission proposal for a new Toy Safety Regulation published.
25 November 2025
European Parliament adopts the regulation.
12 December 2025
Regulation (EU) 2025/2509 published in the Official Journal.
1 January 2026
Regulation enters into force. Certain articles (28 to 44 and 49 to 55) apply from this date.
1 August 2030
General application, including the mandatory DPP for all toys.
Required data points
- Unique product identifier
- Manufacturer, importer and authorised representative details
- Country of assembly
- Age range and safety warnings
- Chemicals banned or restricted in toys (annexed list)
- Substances of concern above thresholds
- Material composition
- Conformity documentation and CE marking
- Notified-body involvement where required
- Instructions for safe use, storage, and disposal
Accepted data carriers
Thresholds and exemptions
- The 4.5-year transition is designed to give the toy industry time to implement the DPP and remove restricted chemical substances.
- Importers of second-hand toys from outside the EU are expected to be in scope; used toys placed on the market by consumers are not.
- Small and micro enterprises benefit from simplified technical documentation routes.
Open questions
- Full alignment of the toy DPP with the ESPR horizontal DPP data model (CIRPASS) is still being worked out.
- Treatment of digital and connected toys interacts with the GPSR, Cyber Resilience Act and AI Act.
- Mutual recognition with UK and US toy-safety regimes.
Frequently asked questions
When does the Digital Product Passport become mandatory for toys?
From 1 August 2030 under the Toy Safety Regulation (EU) 2025/2509. The regulation entered into force on 1 January 2026 — with certain articles applying earlier — but the mandatory DPP for all toys placed on the EU market applies from 1 August 2030.
Which regulation requires a Digital Product Passport for toys?
Regulation (EU) 2025/2509, the new EU Toy Safety Regulation, adopted on 25 November 2025 and published on 12 December 2025. It replaces Directive 2009/48/EC and makes the DPP mandatory for all toys sold in the EU single market.
What data must a toy Digital Product Passport contain?
A unique product identifier; manufacturer, importer and authorised-representative details; country of assembly; age range and safety warnings; banned or restricted chemicals; substances of concern; material composition; conformity documentation and CE marking; and instructions for safe use, storage and disposal.
How is the toy Digital Product Passport accessed?
Primarily through a QR code on the packaging, with an optional data carrier on the toy itself for durable products.
Do the toy DPP rules apply to small businesses?
Yes. All toys placed on the EU market are in scope, but small and micro enterprises benefit from simplified technical-documentation routes under the regulation.
