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The new EU Toy Safety Regulation introduces a Digital Product Passport as part of the conformity requirements for toys placed on the European market.
Rather than supporting ecodesign requirements, the Digital Product Passport becomes part of the product safety and conformity framework for toys. It is designed to make compliance information more accessible to consumers, manufacturers, market surveillance authorities and customs authorities, while strengthening the safety of toys placed on the European market.
While the regulatory objective differs from the Ecodesign for Sustainable Products Regulation (ESPR), the Toy Safety Regulation also shows something broader: different pieces of European legislation are beginning to build on a common Digital Product Passport infrastructure while defining their own product-specific requirements.
Regulation (EU) 2025/2509 replaces the previous Toy Safety Directive and introduces a mandatory Digital Product Passport for toys placed on the European market.
Rather than relying solely on physical documentation accompanying products, manufacturers will be required to create a Digital Product Passport before placing a toy on the market and link it to the product through a data carrier.
The passport becomes part of the conformity assessment process, supporting product identification, regulatory compliance and access to product information throughout the toy’s lifecycle.
The Regulation explains that this approach aims to simplify access to compliance information, strengthen market surveillance and support customs controls before products enter the European market.
One of the most interesting aspects of the Regulation is that it does not establish a separate Digital Product Passport ecosystem for toys.
Instead, it explicitly relies on the common DPP infrastructure introduced under the ESPR.
This includes common rules for:
Rather than creating different technical systems for different regulations, the European Union is progressively building a common infrastructure that can support multiple Digital Product Passport frameworks while allowing each regulation to define its own dataset and regulatory purpose.
This also means that manufacturers already preparing Digital Product Passports under other EU legislation will encounter familiar technical building blocks, including identifiers, Registry registration, data carriers and service provider requirements. While the product information differs, the underlying infrastructure increasingly follows common rules across different regulations.
The Toy Safety Regulation defines a dedicated Digital Product Passport dataset in Annex VI.
Depending on the product, the passport includes information such as:
Unlike many customer-facing experiences, the Toy Digital Product Passport primarily functions as a structured compliance record supporting product safety and regulatory requirements.
The Toy Digital Product Passport is more than a digital source of product information.
It becomes part of the conformity assessment process itself.
The Regulation allows the Digital Product Passport to fulfil the function of the EU Declaration of Conformity, provided it contains all the information required under the applicable legislation.
Manufacturers remain responsible for the accuracy and maintenance of the information contained in the passport, even where technical activities such as hosting or publication are delegated to a DPP service provider.
The Regulation also integrates the Digital Product Passport into customs procedures. Before toys are released for free circulation within the European Union, customs authorities can use the Registry and the DPP itself to support compliance checks.
This illustrates how the passport becomes part of the broader product compliance infrastructure, extending beyond consumer-facing information.
The Toy Safety Regulation will apply from 1 August 2030, giving manufacturers a transition period to prepare for the new requirements, including the introduction of the Digital Product Passport. The Regulation also requires the European Commission to publish guidance for micro, small and medium-sized enterprises (SMEs) on how to set up and operate Toy Digital Product Passports by 1 August 2029.
While the compliance deadline is still years away, the technical foundations are already defined. Manufacturers will need to create Digital Product Passports, register products through the common EU Registry and manage structured product information using the common Digital Product Passport infrastructure established under the ESPR.
Organisations that begin preparing early can use this transition period to structure product information, review internal responsibilities and build implementation processes before the new requirements become mandatory.
Get in touch to explore how Renoon helps organisations build interoperable Digital Product Passports aligned with evolving European legislation across different product sectors.
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