Digital Product Passport for toys
The Digital Product Passport for toys becomes mandatory on 1 August 2030 and replaces the paper declaration of conformity. Deadlines, data and sources.
Where Transpareo supports you
From 1 August 2030 manufacturers create the passport before the toy is placed on the market. Transpareo is the DPP platform on which you create, maintain and publish your product passports for toys. The cards lead to the sections with the details. The passport checklist for toys lists every point to tick off.
Your toy needs a unique identifier and a data carrier that is visible before purchase. Transpareo creates both, from your GTIN or as an identifier of its own.
The passport replaces the paper declaration of conformity. In Transpareo you set up its content points once as fields, and every article fills them in.
The passport has to be available in the language of every market you supply. Transpareo translates warnings and safety information into 40 languages, and you review them before publishing.
The list of banned substances grows, and fragrances that need labelling go into the passport. In Transpareo every change becomes a signed version of the same passport.
Importers check passport, data carrier and registry entry, and own brands become manufacturers themselves. With Transpareo Upstream your producer enters the data, and you review every value.
A range holds thousands of short-lived articles. By Excel import or through the API, a whole season becomes a single import.
Parents read warnings and conformity without logging in, while authorities see more. In Transpareo you decide for every field who may read it.
Before a toy reaches the market, its identifiers go into the EU registry. Today your company makes the entry, and Transpareo prepares the details.
Your passport has to stay reachable for ten years. Transpareo gives it a permanent address, and once it is in the EU registry, Transpareo Vault archives it for ten years.
What is coming for toy manufacturers
Toys have long been one of the most closely regulated product groups in Europe. From 1 August 2030 they are among the first after batteries to carry a digital product passport. Transpareo is the DPP platform on which toy manufacturers create their passports today.
Where the law stands
The Toy Safety Regulation replaces the Toy Safety Directive of 2009. It was published on 12 December 2025 and has been in force since 1 January 2026. It applies from 1 August 2030.
From then on every toy needs a passport before it is placed on the market. The data carrier sits on the toy, its packaging or the accompanying documents. It has to be clearly visible before purchase, in online sales too. The passport takes the place of the paper EU declaration of conformity.
A regulation of their own for the toy passport
A useful thing to know when you read about the Ecodesign Regulation: its first working plan does not list toys among the priority product groups.
Toys get their passport from their own regulation.
The toy passport shares the plumbing with every other passport. That means the central EU registry, running since 20 July 2026, the same identifier scheme and the same technical elements. So you build a toy passport once.
For electronic toys this saves double work. The passport can replace the declarations of conformity under other directives, such as those on radio equipment or hazardous substances. By 1 August 2029 the Commission gives small and medium-sized enterprises guidelines for their first passport.
What this page covers
This page is your reference work on the digital product passport for toys. It shows the timeline with every date the regulation sets and the roles with their duties. Then come the data the passport carries and the official sources to read for yourself. At the end are the questions toy manufacturers ask us most often. Whatever is underlined with dots opens the wording of a provision.
From the rules to the passport
The diagram shows the rules for your toy in grey. Teal is the data you already hold for them, from the declaration to the fragrance list. Blue is the Transpareo product passport with its reading tiers.
The three biggest hurdles in practice
- The passport is more than the declaration you already have. A declaration of conformity is one page signed once. The passport carries identifier, manufacturer, conformity statement, standards and fragrances in a fixed structure. A customs system reads it without a human in the loop. Your current declarations are a good first draft.
- Chemistry keeps moving. The new regulation bans more substances than the old one, PFAS and certain bisphenols among them. The substance list can grow by delegated act. Every update touches products already on sale. In Transpareo every change becomes a new signed version of the same passport.
- The catalogue is the work. A mid-sized range is a few thousand articles with short lives, seasonal variants and shared components. One passport is easy. Four thousand passports that stay correct for ten years after the last unit shipped are a data problem. By Excel import you bring a whole season into Transpareo at once.
More on this: the DPP register is law and how Transpareo meets the harmonised standards.
Regulatory timeline for toys
The key dates of the rules that apply to toys or are still to come, in order. Dates that hang on acts not yet adopted are marked as such.
- 12 December 2025Toy Safety Regulation published
Regulation (EU) 2025/2509 on the safety of toys appears in the Official Journal. It replaces the Toy Safety Directive 2009/48/EC. The directive’s national transpositions become one directly applicable rulebook.
- 1 January 2026In force, and the transition starts
The regulation enters into force. The rules on notified bodies, on the Commission’s powers and on penalties apply from this day. Nothing changes yet for a toy on the shelf.
- 20 July 2026EU DPP register goes live
The central register of the ESPR starts operating, with a test environment. Implementing Regulation (EU) 2026/1778 sets out how it works. Toy passports go there too, with product and operator identifiers uploaded before placing on the market.
- 1 August 2029Guidelines for smaller manufacturers
By this date the Commission gives small and medium-sized enterprises guidelines. They show how to set up and run a passport for toys. That is one year before the duty.
- Expected before the deadlineDelegated acts and harmonised standards
A delegated act sets the data carriers, standards and access rights of the passport. The harmonised standards under the new regulation have still to be cited. No date is fixed for either; watch the Commission’s toy safety page.
- 1 August 2030The regulation applies
From this day a toy may only be placed on the market with a digital product passport. It takes the place of the EU declaration of conformity of the old directive. It is reached through a data carrier on the toy, its packaging or the accompanying documents.
Old stock keeps its marketToys lawfully placed on the market before that day under Directive 2009/48/EC may continue to be made available without a time limit. The cut runs at the moment of placing on the market. The sale to the consumer does not count for it.
- 1 February 2031Old type-examination certificates expire
EC type-examination certificates under Directive 2009/48/EC stay valid until this day, unless they expire earlier. Whoever relies on such a certificate plans the new assessment before then.
- Ten years after placing on the marketHow long the passport lives
Manufacturers keep the technical documentation and the passport at the authorities’ disposal for ten years. A toy placed on the market in 2031 therefore needs its passport until 2041.
- After the actsChemistry keeps moving
The new regulation bans carcinogenic, mutagenic and reprotoxic substances, endocrine disruptors and certain sensitisers. PFAS and certain bisphenols are banned too. The Commission can extend the substance list by delegated act. Every update means a new passport version.
Who is affected?
Duties for toys: what falls on each economic operator on the way to the market.
Carries out the safety assessment and draws up the technical documentation. Before placing the toy on the market, it creates the passport, affixes data carrier and CE marking and uploads the identifiers to the registry. It keeps everything for ten years.
Whoever brings a toy into the EU from a third country places it on the market. Before that, the importer checks that the manufacturer did its part. This covers conformity assessment, passport, data carrier and registry entry. Importer name and address belong on the toy or its packaging. With a supplier request in Transpareo, the manufacturer delivers its data directly.
Before selling, checks warnings, data carrier and CE marking. The warnings have to be in the language of its market. Maintains no passport data of its own. Does not make available a toy whose passport is missing.
Whoever puts a toy on the market under their own name or trade mark counts as the manufacturer. The same holds for a substantial modification that affects safety. That is the trap for own-brand ranges and for marketplaces that import on their own account. From 21 September 2027 the new Union Customs Code applies. For distance sales from outside the EU, the seller or the marketplace is then the importer, depending on the arrangements. That importer makes sure the toy complies with the rules customs apply.
What goes in the DPP for toys?
Data fields for toys: the key ones the relevant EU regulation requires.
The regulation sets limit values and bans for heavy metals, plasticisers, allergenic fragrances and nickel. On top of that it bans endocrine disruptors, PFAS and certain bisphenols. Fragrances that need labelling go into the passport. Your recipe stays with you.
This covers the recommended age, warnings about small parts and the safety information. Buyers have to be able to read them before purchase, in the language of every market. In the passport they are voluntary, but useful for online sales.
This covers the CE marking, the technical documentation with the safety assessment and the assessment route. The passport states that conformity has been demonstrated. It takes the place of the EU declaration of conformity. For electronic toys it also covers the declarations under other directives, such as those on radio equipment and hazardous substances.
Type, batch or serial number, the manufacturer’s and the importer’s name and address, and the unique product identifier belong here. The identifier ties the toy to its passport and to the EU register. So a recall reaches exactly the lots concerned.
Downloads
The checklist for toys as a PDF to print and tick off - no account needed.
The checklist for toys follows the regulation text: every data point is binding law.
Transpareo for toys
Transpareo is the DPP software for toy manufacturers and importers. You set up the content points of the regulation once as fields of your own. They include identifier, conformity statement, standards, notified body and fragrances. Warnings and the age rating sit beside them. The checklist above names every point.
Your catalogue comes in by Excel import or through the API. A season’s range is then one import. Producers enter their data themselves through a supplier request, and you review every value.
Each field has its own visibility. Parents see warnings and conformity without logging in, authorities also the route to the documentation. Information appears in 40 languages, machine-translated and reviewed by you.
Before publication Transpareo checks every passport for missing required data. Every publication is signed, and earlier versions stay retrievable. So a tightened limit value becomes a new version of the same passport. You can export at any time as JSON-LD, CSV, Excel spreadsheet or SQL.
Frequently asked questions about the DPP for toys
Does the passport duty apply to importers too?
The manufacturer creates the passport. The importer checks before placing the toy on the market that this has happened. This covers conformity assessment, technical documentation, passport, data carrier and registry entry. So you need contractual access to your supplier’s data long before the shipment sails. From 1 August 2030 a toy without a passport may not enter the market. If you sell under your own name or trade mark, you are the manufacturer in law. With a supplier request in Transpareo, your producer delivers the data straight into your passport.
Which toys need a passport, and what is not a toy?
Every product designed or intended for use in play by children under 14, whether or not exclusively. What counts is what a parent can reasonably assume from its functions, dimensions and characteristics. Excluded are, for example, playground equipment for public use, sports equipment and collectors’ items for ages 14 and up. A list in the regulation’s annex names every exclusion. There is no size or price threshold. So a promotional plastic figure needs the same passport as a ride-on car.
Does the passport replace the declaration of conformity?
Yes, and that is the practical heart of the change. The EU declaration of conformity of the old directive becomes the conformity statement inside the passport. It is reached through a data carrier, and the sheet of paper in the box goes. For electronic toys the passport replaces further declarations of conformity too. The technical documentation behind it stays with you and is not published. Your current declarations are a good first draft of the passport content.
What happens if I only start in 2030?
The regulation is generous with time and strict at the line. A toy placed on the market under the old directive by 31 July 2030 can go on being sold. One placed on the market from 1 August 2030 without a passport cannot. Whoever starts in 2030 soon finds that the technology is the small part. Gathering model data, warnings and translated safety information for thousands of articles takes quarters. Start with an inventory of your data. Once the data is at hand, Transpareo publishes the passports in a few minutes.
Do I need a GTIN?
No. The passport needs a persistent unique product identifier and a data carrier. The regulation prescribes no particular number scheme. If you have a GTIN, Transpareo turns it into a GS1 Digital Link. Retailers’ and marketplaces’ systems resolve it as well, which saves you a second barcode on the packaging. Without a GTIN, Transpareo issues an identifier of its own, and the QR code leads to the passport just the same. More on the choice in why GS1 Digital Link is the right standard.
Is the passport per model, per batch or per item?
For toys the passport corresponds to a toy model. So one passport covers every unit of that article. Batch and serial numbers still matter. Traceability runs on them, and a recall has to reach exactly the lot concerned. Transpareo keeps passports per model, batch or item. A batch passport holds the values that applied to its batch.
Who sees which data in a toy passport?
Consumers need the identity of the toy, the warnings and the conformity statement. They read the passport without registering or giving a password. Market surveillance and customs also need the route to the technical documentation. The safety assessment stays confidential. In Transpareo every data field has its own visibility, and the public tier appears without any login. The same QR code shows a parent a different view than an inspector. On the mechanics, disclosure does not cost you the signature.
How long does the passport have to stay available?
The passport stays available for ten years after the toy is placed on the market, even after an insolvency. For the same period the manufacturer keeps it with the technical documentation. If a range stays in production for five years, the duty runs well into the next decade. That is longer than most supplier contracts. Ask your provider what becomes of your passports after a cancellation. With Transpareo, published passports stay reachable through a permanent address. Our provider checklist names further questions for choosing a provider.
Do I have to register the passport in the EU register?
Yes. Before placing a toy on the market, you upload the product and operator identifiers to the registry. It is the central registry of the ESPR and has run since 20 July 2026. The registry holds identifiers, and your product data stays in the passport. It returns a registration identifier that customs check at import from 2030. Today your company makes the entry. We expect service providers to be allowed to do it in future. Transpareo checks every passport first and prepares the details the entry needs. Background in our analysis of the register regulation.
What does a missing or wrong passport cost?
The member states set the level of fines. The penalties have to be effective, proportionate and dissuasive. So the number differs from Munich to Milan. The expensive part is rarely the fine. A toy without a valid passport may not be placed on the market. That means a container held at customs in the fourth quarter. A Safety Gate entry with your brand on it outlives any penalty notice. We did the arithmetic in what the DPP costs, what penalties cost.
Official documents
Legal sources for toys to read for yourself: what each document is and when you need it.
- Regulation (EU) 2025/2509 on the safety of toysThe regulation itself, in force since 1 January 2026 and applicable from 1 August 2030. It governs the passport and its content, the register entry and the safety requirements. The source for every question this page leaves open.
- Directive 2009/48/EC on the safety of toysThe old directive, still the law that a toy placed on the market before 1 August 2030 is measured against. Worth keeping open while you map your current declarations of conformity onto the passport fields.
- Toy safety page of the European CommissionThe Commission’s own overview of the new regulation, the transition period and the guidance in preparation. The place where changes to dates and new delegated acts appear first.
- Implementing Regulation (EU) 2026/1778 on the DPP registryLays down how the central register works, from identity verification and the model, batch and item levels to versioning and retention. Read it when you plan who in your company registers what.
- Regulation (EU) 2024/1781 (ESPR)The framework regulation in whose register the toy passport is registered, and whose technical elements the toy passport follows. Toys get their passport from their own regulation and share the plumbing with the ESPR.
- DPP page of the European CommissionThe official roadmap for the product passport across all industries, with the state of the register and the delegated acts. Useful for seeing where toys sit next to batteries, textiles and construction products.
- Safety Gate, the EU rapid alert systemThe public alert database for dangerous non-food products, where toys are the most reported category week after week. Read it as a list of the failure modes your traceability data has to answer for.
Further reading on our blog
The EU register for Digital Product Passports became law on 16 July 2026. What it asks of you, and what we prepare for you.
Six harmonised DPP norms are set in stone. The target has stopped moving, and we already meet it.
Transpareo signs each field of a product passport on its own, so a disclosed protected field keeps its proof. Its reader need not trust the platform.
A product passport introduced on time costs less than a late one. We set the platform plan against the fine.
Ready for toy DPPs?
Set up your passports for toys today. By the time the obligation takes effect, you have long been up and running.