You will have heard that the new EU Toy Safety Regulation (EUTSR), not yet published in the Official Journal, will introduce a requirement for toys to have a Digital Product Passport (DPP).
Each toy’s passport must include:
- a unique product identifier
- the name and address of the manufacturer (and authorised representative if applicable), plus the unique operator identifier
- the name and address of the economic operator responsible for ensuring compliance in the EU, plus the unique operator identifier
- a statement that the passport is issued under the sole responsibility of the manufacturer
- identification of the toy allowing traceability, including a clear colour image
- the customs commodity code where relevant
- references to all EU legislation with which the toy complies
- where applicable, a statement that the passport replaces the EU Declaration of Conformity required under other EU legislation (such as the AI Act, Cyber Resilience Act, EMC, Low Voltage, Radio Equipment, RoHS, or Delegated Regulation (EU) 2019/945)
- references to harmonised standards or common specifications applied
- where applicable, details of any notified body involved and reference to the certificate issued
- the CE marking
- a list of allergenic fragrances that require specific labelling
- the manufacturer’s public contact channel for consumers to report complaints, accidents or safety issues (for example a phone number, email or website form)
- the reference of the service provider hosting the back-up copy of the passport
Optional information may also be included, such as safety warnings and instructions for use.
In terms of the details about how this will work, the Commission will issue a delegated act setting out the technical rules for the Digital Product Passport, such as structure, format, access, and hosting. Note that a delegated act cannot change or add to the content of the passport – the list of required information is already fixed in the Regulation itself.
Once adopted, the delegated act cannot apply earlier than 18 months after its own entry into force. The Regulation as a whole will only apply 54 months after entry into force.
This means toys will not need a Digital Product Passport until around early 2030, assuming the Regulation is published in late 2025.
In the meantime, you may see testing labs, GS1 and IT providers promoting “DPP solutions” for toys. These should be ignored for now. Until the delegated act is adopted, there is no agreed system, and no provider can guarantee compliance.
