Understanding the EU Toy Digital Product Passport (DPP)

What is a toy Digital Product Passport (DPP)?

The toy DPP is a requirement under the EU Toy Safety Regulation (EU) 2025/2509. It is intended to replace the current EU Declaration of Conformity (DoC) for toys and serve as a digital equivalent. It will be accessible via a data carrier (e.g. QR code) affixed to the toy or its packaging.

When is the toy DPP required?

The toy DPP is expected to become mandatory from August 1, 2030.

What information is required in the toy DPP?

The toy DPP will include all information currently required in the EU DoC, as well as additional mandatory information. The list below sets out the mandatory content of the toy DPP. New or additional requirements compared to the current DoC are shown in italics.

The DPP shall include the following information:

1. Type or model number: a unique product identifier of the toy
2. Manufacturer: name and address of the manufacturer and, where applicable, of the manufacturer's authorized representative, as well as the unique operator identifier
3. Importer, authorized representative or fulfillment service provider: name and address of the economic operator responsible for carrying out the tasks set out in Article 4 of Regulation (EU) 2019/1020, as well as the unique operator identifier
4. Statement of responsibility: a statement declaring that the DPP is issued under the sole responsibility of the manufacturer
5. Object of the DPP: identification of the toy, allowing traceability, including a color image of sufficient clarity to enable the identification of the toy
6. Commodity code (where applicable): the commodity code, as defined in Regulation (EEC) No 2658/87, under which the toy is classified at the time the DPP is created
7. Union legislation: references to all applicable Union legislation with which the toy complies
8. Replacement of the EU DoC (where applicable): a statement indicating that the DPP replaces the EU DoC in accordance with Regulation (EU) 2024/1689 or (EU) 2024/2847, Directives 2011/65/EU, 2014/30/EU, 2014/35/EU or 2014/53/EU or Delegated Regulation (EU) 2019/945
9. References to the relevant harmonized standards applied, or references to common specifications in relation to which conformity is declared
10. Where applicable, the name and identification number of the notified body involved in the conformity assessment procedure, the certificate issued and a reference to that certificate
11. The CE marking: confirming the CE mark has been affixed
12. A list of allergenic fragrances that are present in the toy and that are subject to specific labeling requirements as set out in Part B, point 1, of the Appendix to Annex II of Regulation (EU) 2025/2509
13. The communication channel (e.g. email address or web form) allowing consumers or other end users to submit complaints, as provided for in Article 7(12) of Regulation (EU) 2025/2509
14. Reference to the DPP service provider hosting the back-up copy of the DPP

The DPP may also include the following information:

1. Safety information and warnings
2. Instructions for use

How and when can I apply for a toy DPP?

Currently, it is not possible to request or generate a data carrier (such as a QR code) for the toy DPP. The European Commission must still publish implementing acts defining the technical and procedural requirements. No implementation date has yet been announced.

What can I do to prepare for a toy DPP?

Companies should begin collecting and harmonizing product compliance data, ensuring that it is accurate, retrievable and digitally available.

Are there other areas where a DPP is required?

Yes. DPPs are required or planned in several other product areas, although the scope and required information may differ significantly. Regulation (EU) 2025/2509 is one of the first sector-specific regulations to explicitly link the DPP to the replacement of the DoC.

Other regulatory areas include:

• Ecodesign for Sustainable Products Regulation (ESPR) (priority industries include textiles, furniture, mattresses, tires, steel and aluminum)
• Battery Regulation
• Detergents Regulation
• Construction Products Regulation

For more information, please contact your local SGS expert:

Chris Walker (UK)
t: +44 127 430 3080

Laurent Suisse (France)
t: +33 6 16 39 09 29

Thomas Ziegler (Germany)
t: +49 6128 8724753

Sanda Stefanovic (Netherlands/Global)
t: +31 6 51542190

Piyush Shah (US)
t: +1 (973) 461-7953

Julian Kwok (China/Hong Kong)
t: +852 6018 5919

Raymond Cheng (China/Hong Kong/France)
t: +852 2204 8358 (ext. 1358)