Toys are one of the clearest cases of the EU's move to product passports — but their passport comes from a dedicated law, not ESPR. The revised EU Toy Safety Regulation, which replaces the 2009 Toy Safety Directive, makes a Digital Product Passport mandatory for every toy placed on the EU market.
Toys take their passport from the recast EU Toy Safety Regulation (replacing Directive 2009/48/EC), politically agreed in 2025. It introduces a mandatory Digital Product Passport for toys — carrying safety, warning, conformity and traceability data, reachable through a carrier on the toy or its packaging. It sits alongside the horizontal ESPR DPP framework, but the Toy Safety Regulation is the specific instrument for toys.
Expect a unique product identifier, the EU declaration of conformity and CE marking, the safety standards assessed (the EN 71 series), chemical-safety and substances-of-concern data, age grading and warnings, the responsible economic operator, and a link to the technical documentation authorities can inspect.
Most electronic toys contain batteries — and batteries have their own regime. Portable batteries fall under the EU Battery Regulation (carbon footprint, recycled content, due diligence, labelling), and larger packs need a Battery Passport in their own right. So a single electronic toy can carry both a toy DPP and battery obligations.
The Toy Safety Regulation was agreed in 2025 and phases in after a transition period — the direction is fixed even as the exact application date is confirmed. The manufacturer, or the EU importer or authorised representative for toys made outside the EU, carries the obligation. Toy supply chains are heavily import-driven, so the importer angle here is acute.
The groundwork is the safety and conformity data you already generate — the declaration of conformity, EN 71 test reports, chemical declarations. PassPer builds the passport from those documents, generates the carrier, and hosts it for the long term. Start with the free readiness check to see exactly what applies to you.
Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.