Are Toy Safety Warnings Mandatory in the Toy Digital Product Passport?

Toy Safety Regulation general application date: 1 August 2030

What information is mandatory in the Toy DPP?

Article 19 requires the Toy DPP to contain at least the information in Annex VI Part I. ¹

Part I includes defined product and compliance information such as:

• unique product identifier
• manufacturer information and applicable authorised-representative information
• the responsible economic operator information required by the Regulation
• traceability identification and a clear colour image
• commodity code where applicable
• references to applicable Union law
• relevant standards/common specifications
• notified-body and certificate information where applicable
• CE marking
• the specified list of allergenic fragrances that are present and subject to the linked labelling requirements
• the Article 7(12) communication channel
• reference to the DPP service provider hosting the backup copy

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Generic safety warnings and instructions are not in that mandatory Part I list.

What does Annex VI Part II say about warnings?

Annex VI Part II is short and important. It says the digital product passport may include:

• safety information and warnings
• instructions of use

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"May include" is not a universal DPP mandate.

So a manufacturer should not build a schema assumption that every Article 6 warning must automatically be copied into the mandatory DPP dataset.

When are toy warnings mandatory outside the DPP?

Article 6 creates the actual warning obligation.

Warnings needed for safe use

Where necessary to ensure safe use, toys must bear warnings specifying appropriate user limitations. The user limitations include at least the minimum age and, where appropriate, matters such as required user abilities, maximum or minimum user weight and the need for adult supervision. ¹

Warnings for specified toy categories

The categories in Annex III must bear the warnings set out for those categories. ¹

Annex III includes category-specific rules rather than one universal warning text for every toy.

Where must the warnings appear?

Article 6(3) requires the manufacturer to mark warnings clearly, visibly, legibly, understandably and accurately:

• on the toy
• on an affixed label
• or on the packaging
• and, where appropriate, in the accompanying instructions for use

For unpackaged toys, the Regulation also addresses affixing warnings to the toy or label as the relevant conditions allow. ¹

The warnings required by Article 6(1) and (2) must also be clearly visible to the consumer before purchase, including in distance sales. ¹

These are independent obligations. Putting a warning into the DPP does not, by itself, erase a physical or pre-purchase warning requirement.

Can a mandatory warning also appear in the DPP?

Yes. Annex VI Part II expressly allows safety information and warnings to be included.

That can be useful for a richer digital experience, accessibility or consistent product-information delivery.

But the compliance logic should remain:

1. determine whether Article 6 or Annex III makes the warning mandatory
2. satisfy the legally required warning placement and visibility rules
3. decide separately whether to include the warning in the DPP as optional Part II information

Do not reverse the logic and assume that a DPP entry satisfies every warning-placement requirement.

Which safety information is mandatory in the DPP even though generic warnings are optional?

One important example is allergenic fragrance information.

Annex VI Part I(l) requires a list of allergenic fragrances that are present in the toy and subject to the specific labelling requirements referenced in the Appendix to Annex II. ¹

That is mandatory Part I information when the legal conditions are met.

It should not be described as proof that "all safety warnings" are mandatory DPP data. It is a specific, conditional DPP field created by Part I.

For the detailed fragrance-allergen rule, the existing specialist owner remains:

/knowledge/digital-product-passport/toys/allergen-information/

What belongs in the DPP, on the product and in technical documentation?

Toy safety information sits in several legal layers.

The DPP should therefore be built from the actual Annex VI dataset, not by copying the full safety file.

Do instructions have to be in the DPP?

Not under Annex VI Part II as a universal DPP requirement. Part II says instructions of use may be included. ¹

Separately, Article 7(7) requires manufacturers to ensure that the toy is accompanied by instructions for use and safety information in a language or languages easily understood by consumers and other end users as determined by the relevant Member State. ¹

Those are different statements.

An instruction can be legally required to accompany the toy while remaining optional as passport content.

What about online sales?

Article 6 says required warnings must be visible before purchase, including in distance sales. ¹

Article 19 separately requires the DPP data carrier to be visible before purchase, including in distance sales. ¹

The fact that both have pre-purchase requirements does not merge them. A compliant online product page should not assume that making the DPP carrier visible automatically satisfies every required warning presentation rule.

What belongs in technical documentation instead?

Annex V requires a much wider technical evidence layer than Annex VI Part I.

The technical documentation includes, among other things:

• description of design and manufacture
• list of components and materials
• Safety Data Sheets on chemicals used, obtained from chemical suppliers
• safety assessments
• conformity-assessment material
• relevant test reports and evidence

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Those records explain and support compliance. They are not automatically mandatory public DPP fields.

This distinction matters for product-data architecture. A company should be able to trace a warning back to the safety assessment and evidence without publishing the entire technical file in the passport.

Can other EU law make additional information mandatory in the same DPP?

Yes, potentially.

Article 19 provides for a single DPP where other Union law also requires a DPP for the toy. In that case the combined passport can contain data required under this Regulation and data required under the other applicable Union law. ¹

So the statement "warnings are optional Part II Toy DPP data" is a statement about the dataset created by the Toy Safety Regulation. It should not be stretched into a claim that no other applicable Union law can ever require additional information in the same passport.

What should manufacturers avoid assuming?

Avoid warning = mandatory DPP field as a universal rule

Article 6 warning duties and Annex VI DPP duties are separate.

Avoid optional in DPP = optional everywhere

A warning can be mandatory on the toy, label or packaging even though including it in the DPP is optional.

Avoid using the DPP as a replacement for physical warning placement

Article 6 has explicit placement and pre-purchase rules. A scan-only implementation should not be assumed to satisfy them.

Avoid copying the technical file into the passport

Safety assessments, material lists, supplier SDSs and test evidence have their own technical-documentation role.

Keep the decision trail

A governed product record should be able to show:

• which hazard/safety assessment triggered a warning
• the exact warning text and applicable category
• required physical/online placement
• whether the warning is also published into the optional DPP Part II layer
• evidence and version history

That is a data-governance recommendation, not an extra statutory DPP field list.

Common mistakes

"All toy safety warnings must be in the DPP"

No. Annex VI Part II makes safety information and warnings optional DPP content.

"If warnings are optional in the DPP, they are optional on the toy"

No. Article 6 and Annex III can make warnings mandatory outside the passport.

"Putting the warning in the DPP means it can come off the packaging"

Not established. Article 6 has its own location and visibility requirements.

"All toy safety evidence should be public in the DPP"

No. The technical documentation is materially broader than the mandatory Annex VI Part I dataset.

Practical conclusion

Treat toy safety data as separate but connected layers:

1. mandatory Toy DPP Part I information
2. optional DPP Part II safety information, warnings and instructions
3. mandatory Article 6 / Annex III warning presentation where applicable
4. instructions and safety information that must accompany the toy
5. underlying technical documentation and safety evidence

A strong system can govern all five from connected source data without pretending they are one legal output.

What we're watching

1. The Article 49 delegated acts setting detailed Toy DPP carrier, access, create/update and technical rules.
2. Any Article 49(2) amendment to Annex VI that changes the mandatory or optional DPP dataset before 1 August 2030.
3. Commission SME guidance on creating Toy DPPs, due no later than 1 August 2029, where it clarifies implementation without changing the law.

As of 2 September 2026, no current primary source identified a change that turns Annex VI Part II warnings into universal mandatory DPP fields.

Where this connects

The canonical ActivateDigital resources this classification question depends on and feeds into.

• Toy Digital Product Passport Requirements

Sources

• Regulation (EU) 2025/2509 on the safety of toys, especially Articles 6, 7, 19, 24, 25, 27, 49 and 59; Annex III; Annex V; Annex VI. This resource explains the current EU regulatory position and does not constitute legal advice.

  View official source

https://eur-lex.europa.eu/eli/reg/2025/2509/oj/eng

This resource explains the current EU regulatory position and does not constitute legal advice.