What Toy Manufacturers Need to Know About the Digital Product Passport

First published: September 2025

The toy industry is undergoing significant regulatory change with the forthcoming EU Toy Safety Regulation, expected to enter into force in late 2025. Among its key developments is the mandatory introduction of the Digital Product Passport (DPP), which will soon become a legal requirement for all toys sold in the EU.

This guide breaks down what the DPP is, how it applies to toys, the practical implications for manufacturers, and how to begin preparing for compliance.

The Digital Product Passport in the proposed Toy Safety Regulation

The proposed EU Toy Safety Regulation, which reached a provisional agreement in April 2025 and was approved by the EU Council in June 2025, puts the Digital Product Passport (DPP) centre stage as a compliance mechanism for all toys sold in the EU, regardless of whether they are sold in a physical store or via the internet.

The DPP goes further than conventional paper evidence and consists of a digital dataset, which can be accessed via a data carrier (e.g., a QR code) placed directly on the toy, its packaging, or accompanying documents.

Notably, the DPP will replace the EU Declaration of Conformity (DoC) as the primary proof of compliance.

What is a Digital Product Passport (DPP)?

A Digital Product Passport is a detailed digital file that contains all the relevant compliance, safety, and sustainability information about a product, including toys. To be accessible to consumers, customs, and market surveillance authorities, the information must be retrievable via the data carrier.

Main purposes of the toys DPP include:

• Central to ensuring traceability, compliance, and transparency
• Enhance the traceability of toys and make market surveillance and customs checks simpler and more efficient (border control authorities would be able to scan all digital passports using a new IT system)
• Market surveillance authorities, customs authorities, economic operators and consumers or other end-users should have immediate access to the information on the toy through the data carrier
• Aligns the provisions related to the Digital Product Passport with the Ecodesign for Sustainable Products Regulation (ESPR). Even if the current Toy safety regulation proposal does not include sustainability-related information inside the toys DPP, it is expected that the ESPR would include toys within its scope in the medium term, involving the inclusion of more precise information in the toys DPP related to environmental sustainability
• Mandatory for all toys: every individual toy model sold in the EU must have its own DPP
• By creating the digital product passport, the manufacturer shall assume responsibility for the compliance of the relevant Regulations and/or Directive(s)

Digital Product Passport Registry: The economic operator placing the toy on the market is required to submit the unique product identifier and the unique operator identifier to a central EU registry (established under ESPR) before a product is placed on the market. This establishes a clear link between the product and its operator.

Data carrier: This is the point of entrance to the DPP (e.g., a QR code). It must be physically present on the toy or on a label attached to the toy Where this is not possible on account of size or nature of the toy, it shall be affixed to the packaging, if any, or on documentation accompanying the toy. The data carrier must be visible to consumers before purchase.

The DPP data must be presented in the official language(s) of the Member State where the toy is sold and must remain available for a minimum of 10 years after the toy is placed on the market

The DPP shall be stored by the economic operator responsible for its creation or by DPP service providers.

The scope of the technical requirements relating to the digital product passport for toys will be determined by delegated acts adopted by the EU Commission.

How will the DPP affect the toy industry?

Manufacturers:

• They are required to generate a unique DPP for every toy model sold in the EU, including data on compliance, safety and traceability. Sustainability information regarding toys is also expected to be included in a near future under the umbrella of ESPR
• Non-EU manufacturers must also comply with DPP requirements to sell into the EU

Importers and distributors:

• They have an enhanced obligation to verify that the DPP and its data carrier are present and correct before placing toys on the market
• DPP must be submitted at the EU border, accelerating market surveillance and customs checks
• Non-compliant imports can quickly be detected and prevented, also for imports through online channels

Online marketplaces:

• Online sellers must provide the online marketplace with a digital copy of the data carrier
• Online marketplace platforms must design their interface to allow sellers to display the CE marking, any safety warning necessary for the consumer prior to purchase and the weblink or data carrier (e.g. QR code) which provides a link to the DPP

Entire toy supply chain:

• The DPP increases traceability, accountability, and transparency, benefiting compliant businesses but imposing serious penalties on those failing to adapt
• Over time, the DPP is expected to drive up standards for toy safety, particularly for new risks such as digital toys and chemical hazards

What information may be included in the DPP for toys?

The DPP must include the following information, where relevant:

• Unique product identifier: A code for the specific toy model
• Image of the toy: An image of the toy for easier identification. Additionally, and where applicable, Commodity code under which the toy is classified.
• Manufacturer/Operator details: Name, address, and electronic contact details, including unique operator identifiers
• Compliance information and Declaration: References to harmonised standards or common specifications used in conformity declaration, and all relevant EU safety legislation that the toy complies with. The DPP must explicitly state compliance with all applicable safety and chemical requirements outlined in the Regulation and include a statement that the passport is issued under the sole responsibility of the manufacturer.
• The CE marking
• Notified Body details: When applicable, details of notified bodies involved in conformity assessment (notified body name and number and reference to the certificate)
• Instructions & warnings: This information may be included in the DPP - Clear instructions for use and any safety information and warnings
• Allergenic fragrances: List of allergenic fragrances present in the toy subject to specific labelling.
• Communication channel: the communication channel as provided for in Article 7(11) of the Regulation should be included in the DPP. Manufacturers shall make publicly available communication channels such as a telephone number, an electronic address, a dedicated section of their website, allowing consumers or other end-users to submit complaints concerning the safety of toys and to inform the manufacturers of any accident or safety issue they have experienced with such toys.
• Details of the DPP service provider hosting the backup copy of the DPP
• Sustainability information and Ecodesign parameters: As commented, it is expected that sustainability-related obligations are increased in the near future. Even if the current Toy safety regulation proposal does not specifically include sustainability-related information inside the toys DPP, it is expected that the ESPR might include toys within its scope in the medium term. This would imply incorporating more detailed information in the toys DPP regarding environmental sustainability. This might involve including information such as:
• Use of sustainable materials: Including recycled content, recyclable materials, and sustainable renewable materials
• Ecodesign parameters: Including lifecycle waste and consumption, carbon footprint, reliability/ageing resistance, spare part availability and affordability, and product to packaging ratio

This information must be kept up-to-date and accessible throughout the toy’s lifecycle.

Regarding the technical design and operation of the product passport, additional information technology (IT) requirements is provided for such a tool, including ensuring data authentication, reliability and integrity and its interoperability with other product passports established under EU legislation (e.g., Ecodesign Regulation).

How should the toy industry prepare for the DPP?

The Toy Safety Regulation is expected to be published in the EU Official Journal in late 2025. After that, economic operators will have a 54-month transition period to comply with the new requirements. To be prepared, toy companies should start planning now.

• Assess your product data: Examine existing product data collection and traceability processes and identify where you may have gaps in documentation, particularly for legacy products.
• Invest in IT and data system infrastructure: Invest in digital infrastructure for securely storing and managing product compliance data, to have the ability to generate secure QR codes or electronic data carriers for each toy. Alternatively, partner with IT solution providers to streamline DPP creation and lifecycle management.
• Review and enhance supply chain management and transparency: Communicate DPP requirements with suppliers and contract manufacturers to ensure all parties in the supply chain know what their tasks and responsibilities are in gathering and transmitting the required data. Gain visibility beyond Tier 1 suppliers.
• Training and change management: Teach members of compliance teams, product designers and regulatory affairs staff about the new regulation. Incorporate DPP compliance throughout the product development process.
• Coordination with other DPP initiatives: Interoperability with other product passports established under EU legislation, such as batteries, etc.

How can Eurofins Softlines & Hardlines help?

The Eurofins Softlines & Hardlines network of laboratories combines toy safety expertise with chemical compliance and sustainability services to help companies prepare for the Digital Product Passport. From chemical smart testing (Eurofins Chem-ST™) to supply chain mapping and product performance validation, our teams work together to support your end-to-end compliance journey.

Contact us today to ensure your toys are ready for the next generation of EU safety regulation.