Digital product passport checklist for toys

Does the passport duty apply to your product?

Tick what holds for your product. The first statement is the scope test, the rest decide which role you carry. The articles in brackets point to Regulation (EU) 2025/2509.

• The product is designed or intended, whether or not exclusively, for use in play by children under 14 years of age, judged by what a parent or supervisor may reasonably assume from its functions, dimensions and characteristics (Art. 2(1)).
• It is not on the list of products in Annex I, which are outside the regulation entirely (Art. 2(2)).
• You place it on the EU market from 1 August 2030, as the manufacturer that has it designed or made and markets it under your own name or trade mark (Art. 3(3), Art. 7(2)).
• You import it from a third country: the duty to create the passport stays with the manufacturer, but you may not place the toy on the market until you have verified that the passport exists, the data carrier is affixed and the identifiers are in the registry (Art. 9(2)).
• You place it on the market under your own name or trade mark, or you substantially modify a toy already on the market so that its safety is affected: either makes you the manufacturer in law (Art. 12(1) and (2)). As a distributor instead, you verify the data carrier and the manufacturer’s compliance before making the toy available (Art. 10(2)).

Your duties

Everything Regulation (EU) 2025/2509 asks of whoever places a toy on the market, in the order you will meet it. Tick off what is already in place; every item names its article, and the deadlines below say when it applies.

• Draw up the technical documentation of Article 27 with the elements of Annex V, and carry out the applicable conformity assessment procedure, before anything else happens (Art. 7(2)).
• Carry out the safety assessment and keep it in the technical documentation; it stays with you and is not published (Art. 25, Annex V point 2).
• Create the digital product passport for the toy model before the toy is placed on the market (Art. 7(2)(a), Art. 19(1)).
• Affix the data carrier physically on the toy or on an affixed label, or on the packaging or the accompanying documentation where the size or nature of the toy does not allow it, clearly visible to the buyer before purchase, distance selling included (Art. 19(7)).
• Affix the CE marking visibly, legibly and indelibly, and before the toy is placed on the market (Art. 7(2)(c), Art. 18).
• Upload the unique product identifier and the unique operator identifier to the EU registry before placing the toy on the market (Art. 7(2)(d), Art. 22(1)).
• Keep the passport accurate, complete and up to date, and available in the language or languages the member state of sale requires (Art. 19(2)(d) and (e)).
• Keep the technical documentation and the passport for ten years after the toy was placed on the market (Art. 7(3)).
• Have a back-up copy of the passport held through a digital product passport service provider (Art. 19(13)).
• Show a link to the Safety Gate portal section for reporting risky toys whenever the passport is opened (Art. 19(11)).
• Give distributors and online marketplaces a digital copy of the data carrier or the unique product identifier, free of charge and within five working days of a request (Art. 19(12)).
• Give the toy a type, batch, serial or model number, and put your name, trade name or trade mark and your postal and electronic address on the toy, its packaging, an accompanying document or the passport (Art. 7(5) and (6)).
• Mark the warnings of Article 6 and Annex III, and accompany the toy with instructions for use and safety information, in a language the buyer easily understands and visible before purchase (Art. 6, Art. 7(7) and (8)).
• Keep publicly available communication channels for complaints and accident reports, investigate what arrives and hold an internal register of it (Art. 7(12) and (13)).

What the passport must contain

Annex VI Part I is the content list, and it is where your current declaration of conformity turns into structured fields. It applies from 1 August 2030; the items that carry a condition say so, and Part II is the optional block. Under each item you find its place in the annex.

• The unique product identifier of the toy Annex VI, Part I (a)
• Name and address of the manufacturer and, where applicable, of the authorised representative, with the unique operator identifier Annex VI, Part I (b)
• Name and address of the economic operator responsible for the tasks of Article 4 of Regulation (EU) 2019/1020, with its unique operator identifier Annex VI, Part I (c)
• A statement that the passport is issued under the sole responsibility of the manufacturer Annex VI, Part I (d)
• The object of the passport: identification of the toy allowing traceability, including a colour image clear enough to identify it Annex VI, Part I (e)
• The commodity code under which the toy is classified at the moment the passport is created, where applicable Annex VI, Part I (f)
• References to all Union law the toy complies with Annex VI, Part I (g)
• Where applicable, the mention that the passport replaces the EU declaration of conformity under the other acts it covers Annex VI, Part I (h)
• References to the harmonised standards used, or to the common specifications against which conformity is declared Annex VI, Part I (i)
• Name and number of the notified body that intervened, and the reference to its certificate, where one was issued Annex VI, Part I (j)
• The CE marking Annex VI, Part I (k)
• The allergenic fragrances present in the toy that are subject to specific labelling under Part B point 1 of the Appendix to Annex II Annex VI, Part I (l)
• The communication channel for complaints and accident reports required by Article 7(12) Annex VI, Part I (m)
• The digital product passport service provider hosting the back-up copy Annex VI, Part I (n)
• Optional, and worth carrying anyway: safety information and warnings, and the instructions of use Annex VI, Part II

How the passport has to be built

The content is one half; the other is a set of properties the passport has to have as a system. These are the ones you cannot retrofit cheaply, so they belong in the decision you make before you pick how to publish.

• One passport per toy model, a model being toys under the same manufacturer with uniform design, technical characteristics, materials and processes, identified by a type number Art. 19(2)(a), Art. 3(15)
• Batch level instead, where other Union law requires that granularity Art. 19(9)
• Reached through a data carrier that connects to a persistent unique product identifier Art. 19(2)(h)
• Free of charge for everyone entitled to read it, with no registration and no password for consumers Art. 20(3) and (4)
• Based on open standards, machine-readable, structured, searchable and transferable without vendor lock-in Art. 20(2)
• Fully interoperable with the passports other Union law requires, under one carrier and one passport Art. 19(8) and (9), Art. 20(1)
• Stored by you or by a service provider that may not sell or reuse the data beyond the service Art. 20(5) and (7)
• Linked to the earlier passports where a new one is created for a toy that already has one Art. 20(6)
• Free of reader tracking, and holding no personal data without explicit consent Art. 20(10)
• Authentic, reliable and tamper-evident, designed and operated so that fraud is avoided Art. 20(8) and (9)
• Following the identifier and data-carrier standards of the Ecodesign Regulation, including its rules on identifier lifecycle and on service providers Art. 21

Registry and customs

The registry holds identifiers, not your product data. It is the same central register the Ecodesign Regulation set up, which has been operating since 20 July 2026, and the entry is what customs check against.

• Upload the unique product identifier and the unique operator identifier before placing the toy on the market Art. 22(1)
• Expect the commodity code to be stored alongside them for toys intended for release for free circulation Art. 22(1)
• Keep the unique registration identifier the registry returns automatically, and do not read it as proof of compliance Art. 22(2)
• Provide that identifier to customs at release for free circulation, where the check is electronic and automatic against the registry and runs on the commodity codes of Annex VII Art. 23(2) to (4) and (6)
• Expect the upload set to grow: a delegated act may add further Annex VI information, and information on non-compliance, to what the registry stores Art. 49(3)

Deadlines

The dates that matter for a toy, taken from the application and transitional articles of the regulation. The last entry hangs on delegated acts the Commission has not adopted and is marked as such.

1. 12 December 2025
   The regulation is published

   Regulation (EU) 2025/2509 of 26 November 2025 on the safety of toys appears in the Official Journal (OJ L, 2025/2509, 12.12.2025). It repeals Directive 2009/48/EC and turns its national transpositions into one directly applicable rulebook (Art. 56).

2. 1 January 2026
   In force, and three chapters already apply

   The regulation enters into force on the twentieth day after publication. Most of it waits, but Articles 28 to 44 on notified bodies, Articles 49 to 53 on the delegated and implementing powers and Articles 54 and 55 on confidentiality and penalties apply from this day (Art. 59). The five-year delegation of power to the Commission also starts here (Art. 50(2)).

3. 1 August 2029
   Commission guidance for smaller manufacturers

   No later than this date the Commission provides guidelines on how to set up and operate a digital product passport for toys, aimed at micro, small and medium-sized enterprises and drawn up with the national authorities (Art. 24). One year before the duty bites.

4. 1 August 2030
   The regulation applies and the passport is due

   From this day a toy may only be placed on the market with a digital product passport created before it goes on the market, with the data carrier affixed, the CE marking affixed and the identifiers uploaded to the EU registry (Art. 7(2), Art. 19, Art. 59). Directive 2009/48/EC is repealed with effect from the same day (Art. 56).

   Old stock keeps its market

   Member States may not impede the making available of toys placed on the market in conformity with Directive 2009/48/EC before this day (Art. 57(1)). The cut runs at the moment of placing on the market, not at the moment of sale to the consumer.

5. 1 February 2031
   Old type-examination certificates expire

   EC type-examination certificates issued under Article 20 of Directive 2009/48/EC stay valid until this date, unless they expire earlier (Art. 57(3)). Anyone relying on a certificate from the old regime needs a plan that ends before it does.

6. Ten years after placing on the market
   How long the passport lives

   The passport stays available for ten years after the toy was placed on the market, including in cases of insolvency, liquidation or the operator ceasing activity in the Union (Art. 19(2)(g)). The manufacturer keeps the technical documentation and the passport for the same period (Art. 7(3)), the importer keeps the unique product identifier (Art. 9(8)).

7. 1 November 2033
   First evaluation of the regulation

   By this date, and every five years after it, the Commission evaluates the regulation and reports (Art. 58(1)). The first point at which the passport rules themselves are formally reviewed against practice.

8. After the acts
   The technical requirements and the chemistry

   The data carrier, its layout and positioning, the standards, who may read which field and who may create or update one all come from a delegated act under Art. 49(1) that has not been adopted; its date of application must normally be at least eighteen months after it enters into force. Annex VI itself and the restricted substances of the Appendix to Annex II may be amended the same way (Art. 49(2), (6) to (9)).

Sources

The documents this checklist is drawn from, and what each one is good for.

How to prepare

Six steps in the order they pay off, from your existing declarations to the first published passport.

1. Map one declaration onto Annex VI: take a current EU declaration of conformity and fill Annex VI Part I with it. What is missing after that exercise is your actual gap, and it is usually the identifiers, the image and the fragrance list.
2. Pull the allergenic fragrances out of the recipe: point (l) wants the fragrances subject to specific labelling, per article. That data sits with your chemical suppliers and their safety data sheets, so put it into the purchasing contracts now.
3. Decide the identifier scheme: the passport needs a unique product identifier, not a particular numbering system. Settle whether you build on an existing GTIN or on your own article numbers before you print anything.
4. Plan one carrier: the carrier goes on the toy, an affixed label, the packaging or the accompanying documentation, and it has to stay readable and visible before purchase. Decide once, per packaging family rather than per article.
5. Pilot with a handful of articles: Register for free, set up the fields of this checklist once and build a few real models as passports. Fields that do not apply to an article stay empty without blocking the passport.
6. Plan for the catalogue, not the pilot: a season is thousands of articles that have to stay correct for ten years after the last unit shipped. Sort out the import route and the ownership of each field before 2029, because the technology is the small part.