Last updated: 7 July 2026
Digital Product Passport for toys
The Toy Safety Regulation makes the Digital Product Passport mandatory for every toy placed on the EU market from 1 August 2030. This is confirmed law, not a proposal. OriginPass helps toy manufacturers, importers and own-brand operators structure models, safety files and chemical evidence now, and publish the passport well before the deadline.
Where toy DPP rules stand today
Regulation (EU) 2025/2509 is in force since 1 January 2026. The DPP becomes mandatory for toys placed on the EU market from 1 August 2030.
Delegated acts under Article 49 will detail identifiers, data carriers, registry connections and access rules between 2026 and 2029.
The passport does not replace physical warnings and instructions on the toy, label or packaging. That layer stays.
What is a toy Digital Product Passport?
A toy Digital Product Passport (DPP) is a structured digital record required by the Toy Safety Regulation (EU) 2025/2509 for every toy placed on the EU market from 1 August 2030. The manufacturer creates it before placing the toy on the market and links it through a data carrier such as a QR code to a persistent unique product identifier. The passport contains at least the data listed in Annex VI Part I, corresponds by default to a specific toy model, must be available in the languages required on each market and has to remain accessible for 10 years.
Confirmed law, implementation details and important limits
For toys the legal question is settled. What remains open are technical details, and a few limits that are easy to get wrong in both directions.
What is already fixed
- Regulation (EU) 2025/2509 on toy safety is in force since 1 January 2026
- Article 19: the manufacturer creates a DPP before placing a toy on the market, mandatory from 1 August 2030
- Annex VI Part I defines the minimum data set; the data carrier (such as a QR code) links to a persistent unique product identifier
- The passport must stay available for 10 years and in the languages required on each market
What is still being detailed
- Delegated acts under Article 49: technical rules for identifiers, data carriers, registry connections and access layers
- The operational workflow for market surveillance, customs checks and data exchange between operators
- Interoperability details shared with the ESPR registry architecture
What the passport does not change
- Warnings must stay visible on the toy, a label or the packaging, and before purchase in distance sales
- Instructions and safety information still accompany the toy in the required languages
- Most laboratory evidence and supplier documentation stays in the technical file; the DPP is not a fully public safety dossier
Presenting toy DPP as a scenario to monitor is now too weak. The legal basis, the application date and the minimum passport logic are fixed. The remaining work is data, process and system preparation.
Toy DPP timeline: confirmed dates and the preparation window
Every entry is labelled by its legal status. For toys, both key dates are already law.
- Confirmed
ESPR enters into force
Regulation (EU) 2024/1781 establishes the technical framework for Digital Product Passports: identifiers, data carriers and the registry logic the toy passport builds on.
- Confirmed
Toy Safety Regulation in force
Regulation (EU) 2025/2509 replaces the old toy safety framework and brings its own DPP chapter. The legal trigger for the toy passport is this regulation, not a future ESPR delegated act.
- In preparation
Article 49 delegated acts and technical preparation
The Commission details identifiers, data carriers, registry connections and access rules. Manufacturers use this window to prepare product data, documents and conformity processes.
- Confirmed
DPP mandatory for toys
Every toy placed on the EU market needs a Digital Product Passport, created by the manufacturer before placing it on the market and linked to a QR code or similar data carrier.
What data will a toy DPP contain?
The minimum passport layer is already written into the regulation. The harder part is the evidence behind it, which must be structured even where it never becomes public.
The Annex VI Part I minimum data set
The mandatory passport layer is defined in the regulation. At minimum, the toy DPP identifies:
- Unique product identifier of the toy
- Manufacturer and, where relevant, the authorised representative, with unique operator identifiers
- Economic operator responsible for the EU market (Article 4 of Regulation (EU) 2019/1020)
- Object of the passport, including a colour image sufficient to identify the toy
- Applicable Union legislation, harmonised standards and, where relevant, the notified body and certificate
- CE marking and fragrance allergens subject to labelling duties
The evidence behind the passport
Not all of this becomes public, but it must be structured and linked to the right product record:
- Chemical compliance: the PFAS ban, restricted bisphenols and the bisphenol A migration limit of 0.005 mg/l
- Fragrance allergens above 10 mg/kg, named on the toy or packaging and in the DPP
- REACH communication for SVHCs above 0.1%, where applicable
- Test reports, supplier declarations and safety-assessment records
- Safety information, warnings and instructions for use (Annex VI Part II)
- Registry uploads: unique product identifier, operator identifier and, for customs-relevant toys, the commodity code
The real difficulty is rarely the QR code. It is the product-data and document-governance layer behind the passport, and that layer takes the longest to clean up.
Who should prepare for the toy DPP
The obligation lands on everyone who places toys on the EU market or sells them to EU consumers.
Toy manufacturers
Multi-component products with many materials in one toy. The passport corresponds to a specific toy model by default, so a clean model and variant structure is the foundation.
Importers and own-brand operators
Managing third-party factories outside the EU. Importers carry economic-operator duties for the EU market and usually face the biggest supplier-evidence gaps.
Brands with heavy safety documentation
Test reports, declarations and certificates across many SKUs and suppliers. The passport only works when each document is linked to the right product record.
Distributors and online marketplaces
Customers must be able to reach the passport before purchase, including in distance sales. Marketplaces need a digital copy of the data carrier or the product identifier.
How OriginPass supports toy DPP readiness
One structured system for toy product data: from a clean model structure and linked safety files today to a published passport before the 2030 deadline.
Structured toy product records
Families, models, variants, packaging versions, batches and items in one hierarchy. The regulation starts from the toy model; deeper levels are there when another law requires them.
QR codes & identifiers
Generate QR codes based on GS1 Digital Link or a temporary internal identifier. The persistent link layer keeps the printed code connected to the passport for years.
Documents linked to the record
Test reports, declarations and supplier evidence stored with the exact product they prove. The public passport layer stays separate from the authority-facing technical file.
Passport change history
Every change recorded with timestamp and author. The toy passport must stay available for 10 years, so being able to show its state on any past date matters.
One passport, 24 EU languages
The regulation requires the languages of each market where the toy is sold. Passport fields render in 24 EU languages from maintained terminology dictionaries, with no surcharges.
Scan reports
See where your toys get scanned: country, device type and timestamp. Minimal telemetry, no IP addresses, and early sight of markets you do not sell in yet.
Your toy DPP readiness plan
Four workstreams turn a confirmed 2030 obligation into a manageable programme instead of a late scramble.
- 01
Clean the product master
One view of toy families, models, variants, packaging versions and identifiers. This is the level the passport will attach to.
- 02
Audit the safety files
Locate the gaps between test reports, declarations and the actual product records they are supposed to prove.
- 03
Review supplier data quality
Materials, origin and factory-level evidence, especially for imported lines. Supplier gaps take the longest to close.
- 04
Pilot one toy line
Publish a pilot passport page for one toy line, link its documents and test the QR journey end to end.
Four years sounds like a lot. For catalogues with hundreds of SKUs and scattered supplier evidence, it is not. Early structure beats a 2029 scramble.
See what a finished product passport looks like
This is a real toy demo passport published on OriginPass production infrastructure. Scan the code with your phone or open the preview.
Scan with your phone to open the passport
Open the passport in a new tabA real demo passport published in the OriginPass system.
Plans matched to the scale of your DPP rollout
Net prices per month, billed monthly.
Sandbox
A free plan to launch your first public model-level DPPs. Good for learning the system, pilot rollouts, and very small producers with a limited catalog.
- up to 10 live DPPs (model level only)
- 500 MB file storage
- 1 brand, 1 user
- preview of all features in limited scope
- public DPP pages on the OriginPass domain with an OriginPass watermark
Starter
For a single manufacturer with one brand entering the first ESPR wave.
- Everything in Sandbox, plus:
- up to 250 active DPPs
- 12 GB file storage
- 1 brand, 1 user
- GS1 Digital Link or internal identifier
- Passport change history
Growth
For SMEs with multiple brands and an approval workflow.
- Everything in Starter, plus:
- up to 1,500 active DPPs
- 75 GB file storage
- 3 brands, 5 users
- Company & brand change history (audit)
- Approval workflow and branded domain
- Video asset hosting for DPP pages
- Geo heatmap and 12-month scan data retention
Scale
For larger organizations with multiple brands and teams.
- Everything in Growth, plus:
- up to 5,000 active DPPs
- 250 GB file storage
- 5 brands, 10 users
- Roles & permissions (RBAC), basic SLA
- Priority email support
Enterprise
For large brands and corporate groups with in-house IT.
- Everything in Scale, plus:
- unlimited DPPs and brands
- SSO and root domain
- Dedicated contract and SLA
- Asynchronous rollout support
- Custom integrations via API
All plans include EU hosting, backups and regulatory updates. DPP Pack, Storage Pack and Brand Slot are available separately.
* For detergents, scan-analytics features, including the heatmap and scan-data retention, remain disabled on every plan under Regulation (EU) 2026/405.
Add-ons for any plan
Buy only what you're missing — no need to upgrade the whole plan.
DPP Pack
€49 / mo+250 active DPPs. Available from the Starter plan.
Storage Pack
€19 / mo+50 GB of file storage. Available from the Starter plan.
Brand Slot
€49 / mo+1 brand. Available from the Growth plan.
Add-ons are billed monthly and can be cancelled at any time. Once cancelled, slots return to the base limit from the next billing cycle. Battery live data*, BMS/ERP integrations and advanced API workflows are priced individually based on scope. *Standard battery DPP templates are available in standard plans; live data is custom.
Submit your company for the first rollout wave
We're opening the first rollout wave for companies that want an early start on practical DPP rollout and a say in first-release priorities. In exchange for product feedback and a short letter of intent, we offer 6 months of the system at €0.
- 6 months of the full system at €0 in the first rollout wave
- Direct influence on first-release priorities and industry templates
- Ongoing contact with the product team via email and backlog, with no mandatory calls
- No marketing newsletter: we contact you only about OriginPass and your access
Submission for the first rollout wave
By submitting this form, you agree to be contacted about the OriginPass pilot program. We do not send a marketing newsletter. Privacy policy
Toy DPP: frequently asked questions
Is a Digital Product Passport mandatory for toys?
Yes. Regulation (EU) 2025/2509 on toy safety, in force since 1 January 2026, makes the Digital Product Passport mandatory for every toy placed on the EU market from 1 August 2030. This is confirmed law, not a scenario to monitor under the ESPR.
When does the toy DPP become mandatory?
From 1 August 2030 for toys placed on the EU market. The manufacturer must create the passport before placing the toy on the market, so the data and document preparation has to happen earlier.
What data must a toy DPP contain?
Annex VI Part I sets the minimum: the toy's unique product identifier, manufacturer and responsible economic operator details with operator identifiers, a colour image sufficient to identify the toy, the applicable Union legislation and harmonised standards, the CE marking and fragrance allergens subject to labelling duties. Part II can additionally carry safety information, warnings and instructions for use.
Does the toy DPP replace the EU Declaration of Conformity?
It can, in specific cases. For toys also covered by the acts listed in Article 19(5), such as the AI Act, the Cyber Resilience Act, RoHS or the Radio Equipment Directive, the passport may replace the separate declaration if it contains all elements those acts require. The full declaration text remains part of the technical documentation.
Does the DPP replace warnings on the toy or packaging?
No. Warnings must stay on the toy, an affixed label or the packaging and be visible before purchase, including in distance sales. Instructions and safety information still accompany the toy in the required languages. The passport adds a digital layer; it does not remove the physical one.
Is the toy DPP an ESPR delegated act?
No. The obligation comes from the Toy Safety Regulation itself, a standalone sector law with its own DPP chapter. The ESPR matters on the technical side: the toy passport uses the same logic for identifiers, data carriers and registry connections.
At which level is the toy passport issued: model, batch or item?
By default the passport corresponds to a specific toy model (Article 19(2)(a)). Article 19(9) leaves room for a different level where another Union act requires it. OriginPass supports model, batch and item levels in one hierarchy, with data inherited from the model down.
Can I pilot a toy DPP before the technical details are final?
Yes. You can structure one toy line, link its test reports and declarations, and publish a pilot passport page with a QR code. The free Sandbox plan supports model-level passports at €0, and the first rollout wave offers 6 months of the full system at no cost.
Sources and further reading
Everything above is grounded in official EU sources. For the editorial deep dives, see InfoDPP.eu, the independent ESPR & DPP knowledge hub.