Toy Digital Product Passport Requirements

Which products are covered?

The Toy Safety Regulation applies to products designed or intended, whether or not exclusively, for use in play by children under 14 years of age, subject to the exclusions and specific boundaries set out in the Regulation and Annex I.¹

Not every product used by a child is legally a toy, and Annex I excludes specified products from the Regulation's toy scope.

The DPP obligation follows the product's status under the Toy Safety Regulation. So the first implementation step is to establish that the product is a toy within the Regulation before treating Annex VI as its mandatory passport schema.

When does it apply?

Adoption date, implementation date and application date shouldn't be collapsed into one "deadline". For the rest of EU product law, see which EU product rules apply now and which start later.

What information does the Toy DPP contain?

Article 19 requires at least the information in Annex VI Part I. Part II allows additional optional information.¹

What the allergenic-fragrance field does not mean

Annex VI does not say the Toy DPP must contain an unlimited inventory of every chemical substance in every toy.

It specifically requires a list of allergenic fragrances that are present in the toy and subject to the particular labelling requirements identified by the Regulation.¹

The wider Toy Safety Regulation contains extensive chemical and safety requirements. Those should not all be relabelled as DPP fields.

To see what your own product data already supports, check one toy's data.

Article 19(5)-(6) also allows the Toy DPP to satisfy declaration duties under the listed interacting Union acts where all information required by those acts is present. Where that route is used, Annex VI Part I(h) requires the passport to state that it replaces the relevant EU Declaration of Conformity. So the substitution is conditional, not automatic across every law that touches a toy.

Article 19(11) adds a separate consumer-safety connection: when the DPP is accessed, it must display a link to relevant Safety Gate Portal information about risks associated with the toy.

Identifiers and data carrier

Article 19 requires the passport to be connected through a data carrier to a persistent unique product identifier.¹

Before placing a toy on the market, Article 22 requires the economic operator to upload the toy's UPI and UOI to the DPP Registry. For toys intended for release for free circulation, the Registry also stores the commodity code and communicates a unique registration identifier associated with the registered identifiers.¹

The unique registration identifier is a Registry/customs mechanism. The Regulation expressly says communication of that identifier is not proof of compliance.¹

The carrier itself is physically located on the toy or affixed label. Where the size or nature of the toy prevents that, the Regulation allows the carrier to be placed on packaging or accompanying documentation in accordance with the technical rules to be adopted.¹

The DPP carrier must also be made visible to potential customers in distance sales through the relevant digital copy or identifier mechanism.

Three points should remain separate:

• UPI identifies the product under the DPP architecture
• UOI identifies the relevant operator
• data carrier connects the physical/digital sales context to the passport.

None of those statements means a GTIN is automatically mandatory for every toy DPP.

See Barcodes and Product Identifiers: What You Need.

Is the Toy DPP model, batch or item-level?

The default is model-level.

Article 19 says the DPP corresponds to a specific toy model.¹

There is a controlled exception. Where other Union law requires a DPP for the toy at batch level, the Toy DPP can correspond to that batch level. The Regulation also provides for a single DPP where other Union law creates overlapping DPP requirements.¹

The safe public description:

model-level by default, with alignment to batch-level obligations where another applicable Union law requires it.

Do not call the Toy DPP item-level simply because an individual physical toy carries or is associated with a data carrier.

For the wider comparison, see Model, Batch or Item Level for a Textile Passport.

Who can see what?

Article 19 identifies the broad actor groups that may access the Toy DPP:

• consumers or other end users
• market surveillance authorities
• customs authorities
• notified bodies
• the Commission
• other economic operators.¹

But it does so according to access rights to be set under Article 49(1)(d).

Article 49 gives the Commission power to adopt the detailed technical DPP rules, including:

• one or more data carriers
• carrier layout and position
• applicable technical standards
• the actors that have access to data and which data they can access
• actors that may create or update information
• detailed updating arrangements.¹

As at 1 September 2026, those category-specific detailed access arrangements remain an implementation dependency.

So the adopted law tells businesses which kinds of actors the system must support, but it is not safe to invent a complete field-by-field public/restricted access matrix before the relevant delegated rules are adopted.

See Who Can See What in a Digital Product Passport.

Registry, storage and persistence

The Toy DPP uses the common ESPR Registry architecture without turning the Registry into the full central passport database.

Article 22 requires the UPI and UOI to be uploaded to the Registry and, for relevant imports, connects the Registry to customs verification through the unique registration identifier.¹

Article 20 requires the passport to operate as an interoperable system and carries forward the DPP technical principles on data storage, persistence and service providers.¹²

The EU DPP Registry became operational on 20 July 2026.³

The useful separation is:

• passport: the fuller toy information and evidence-facing data layer
• Registry: registered identifiers and the information needed for regulatory/customs use.

See EU DPP Registry: Where Passport Data Actually Lives.

The horizontal Registry position is now more settled than the toy-specific technical layer. Commission Implementing Regulation (EU) 2026/1778 expressly covers toys under Regulation (EU) 2025/2509, entered into force on 6 August 2026, and the Registry became operational on 20 July 2026. None of those dates moves the Toy DPP application date forward from 1 August 2030.

There is also a granularity distinction worth keeping. The Registry can register model, batch or item-level identities and applies its “most granular level required by applicable law” rule. Toy law, however, sets a model-level default with a controlled batch-level interaction. Registry capability does not create an item-level Toy DPP requirement by itself.

Factory and storage addresses: required in technical documentation, not automatically a DPP field

Annex V, which governs technical documentation, requires the addresses of the places of manufacture and storage.¹

Annex VI Part I, which lists the mandatory Toy DPP information, does not simply reproduce that factory/storage-address requirement.¹

So:

Factory or storage addresses required in the technical documentation are not automatically mandatory Toy DPP fields.

It shows why businesses should not take information required elsewhere in product law and silently move it into the passport schema.

A manufacturer address is a mandatory Annex VI DPP field. The separate addresses of the places of manufacture and storage are a technical-documentation requirement.

For the cross-category factory/origin question, use the future Factory / Origin reference.

Other toy-safety obligations are not automatically DPP content

The Regulation contains extensive requirements on:

• essential safety
• chemical restrictions
• warnings
• conformity assessment
• technical documentation
• CE marking
• traceability
• market surveillance.

Some of these connect directly to mandatory Annex VI fields, such as CE marking, standards and notified-body certificates.

Others remain obligations elsewhere in the law.

So the passport must be built from Annex VI plus the specific cross-references in Article 19, not from a blanket copy of the entire technical file.

Connected toys do not stop at the Toy DPP

A toy can have a Toy Digital Product Passport and still sit inside other EU product regimes.

If the toy intentionally uses radio, connects to the public internet, processes personal data, has social interactive or location-tracking features, contains a battery or relies on software, those facts create separate scope questions.

The Toy Safety Regulation itself anticipates this overlap. It sits alongside radio and cybersecurity law, and its DPP rules are designed to interoperate with other applicable Union requirements rather than replace them.

Use Connected Toys: Toy, Radio Product, Cyber Product or Several at Once? when the question is which rulebooks apply to a connected toy. Stay on this page when the question is what the Toy DPP itself requires.

That distinction prevents two opposite errors: treating the Toy DPP as if it absorbs radio and cyber obligations, and treating a connected toy as if cyber law replaces the toy-safety and DPP route.

What businesses can prepare now

PREPARE

Confirm toy scope. Use the Regulation's legal definition and exclusions rather than a commercial product category alone.

Build model identity. The default DPP is for a specific toy model.

Structure UPI and operator identity. Keep UPI, UOI and Registry registration identity separate.

Map Annex VI Part I. Prepare governed sources for operator identity, traceability image, legal references, standards, certificates, CE marking and applicable allergenic-fragrance data.

Separate technical documentation from DPP content. Keep factory/storage addresses and other Annex V records available for compliance without automatically publishing them as passport fields.

Prepare backup/service-provider continuity. Annex VI includes the backup DPP service-provider reference.

Design evidence links. Standards, certificates and conformity statements need stable provenance and scope.

WATCH

• Article 49 DPP delegated acts
• detailed access-right allocation
• final data-carrier specification and positioning rules
• technical standards and service-provider requirements
• Registry/customs implementation
• amendments to Annex VI or other DPP information before application.

IMPLEMENTATION DETAIL STILL PENDING

The Regulation has already adopted the model-level DPP, the minimum Annex VI dataset and the 1 August 2030 application date.

The main open layer is technical implementation under Article 49, especially access rights, carrier details and updating roles.

A future marketplace handoff is already fixed. Article 19(12) requires the manufacturer or importer to give the DPP data carrier and UPI to distributors and online marketplaces. If a digital copy of the carrier or a web link is requested, it must be provided free of charge within five working days.

Article 14 separately requires an online-marketplace interface to let sellers provide the CE marking, the pre-purchase warning required by the toy rules and the DPP data carrier or web link. These are future Toy Regulation duties from 1 August 2030, not current GPSR duties in disguise.

What the Toy DPP shows about DPPs

The Toy DPP demonstrates a model-level safety and conformity-oriented passport.

That is materially different from:

• the Battery Passport's hybrid model + individual lifecycle architecture
• the detergent DPP's model-level ingredient/substance and compliance architecture.

The shared idea is a governed digital passport system. The product information remains category-specific.

Open questions and implementation pending

As at 1 September 2026:

1. Detailed category-specific access rules under Article 49 remain to be adopted.
2. Final carrier choice/layout/positioning details are subject to the Article 49 technical rules.
3. Detailed create/update roles may be supplemented by delegated action.
4. The Registry/customs technical workflow will need to be implemented operationally before the 2030 application date.
5. Annex VI can be amended under the Regulation's delegated powers, so the adopted dataset should be monitored rather than treated as permanently frozen.

Six DPP standards are OJ-cited under Decision (EU) 2026/1736 as at 6 September 2026. The remaining two should stay “not yet cited” at this evidence date. A September roadmap milestone is not the same as an adopted OJ decision.

The detailed Toy Article 49 access, carrier and updater rules remain the category-specific implementation boundary.

Direct questions

When does the Toy DPP apply?

The Toy Safety Regulation applies from 1 August 2030, including its model-level DPP obligation.¹

Is the Toy DPP item-level?

No. The default passport corresponds to a specific toy model. It can align to batch level where another applicable Union law requires a batch-level DPP.¹

Is factory information part of the Toy DPP?

The manufacturer's name and address are mandatory DPP data. The addresses of places of manufacture and storage are required in Annex V technical documentation, but are not automatically part of the mandatory Annex VI DPP field set.¹

What conformity information is included?

Annex VI includes references to applicable Union law, relevant harmonised standards or common specifications, notified-body and certificate information where applicable, and CE marking.¹

Does the Toy DPP contain chemical information?

It includes specified allergenic-fragrance information where those fragrances are present and subject to the Regulation's labelling requirements. That should not be expanded into a claim that the DPP contains every chemical in the toy.¹

Does the Registry prove that a toy complies?

No. Article 22 explicitly says the Registry's communication of a unique registration identifier is not proof of compliance.¹

How we know

Material claims were checked against Regulation (EU) 2025/2509 and current official DPP infrastructure material on 1 September 2026.

Primary and official sources

• Regulation (EU) 2025/2509 on the safety of toys, especially Articles 2, 19-23, 49, 59 and Annexes V-VI
  EU law
• Regulation (EU) 2024/1781 (ESPR), horizontal DPP system and Registry architecture
  EU law
• European Commission, DPP Registry now live, 20 July 2026
  European Commission
• European Commission, Digital Product Passport implementation overview:
  European Commission

https://single-market-economy.ec.europa.eu/single-market/digital-product-passport_en