Digital Product Passport

Sectors and timing

Toys need a digital product passport from 1 August 2030

The EU toy regulation sets that date, and the ecodesign programme never names toys. Watch the toy law, and not the ecodesign work plan.

Published . Updated . Checked . Due for review .

A toy that you sell into the European Union (EU) needs a digital product passport from 1 August 2030. The EU toy regulation is adopted, and it sets that date. The ecodesign regulation does not set it.

The published ecodesign programme does not name toys. If you read only that programme, you can conclude incorrectly that no passport rule reaches your toy.

The ecodesign programme does not name toys

The Ecodesign for Sustainable Products Regulation (ESPR) creates the digital product passport. ESPR has been in force since 18 July 2024. ESPR reaches a product group only through a separate rule for that group, called a delegated act. No delegated act is adopted for any product group yet.

The European Commission publishes a programme of the groups it plans to cover. That programme names iron and steel, textiles, aluminium, tyres, furniture and information and communication technology products. It does not name toys.

Toys get a passport from a sector regulation instead. Detergents and construction products also get a passport from their own regulation. See which products need a passport, and when, detergents and construction products.

A sector regulation sets the toy date

A passport duty that arrives through a sector regulation does not use the ecodesign process. No delegated act sets your date. The scrutiny period that the European Parliament and the Council get for a delegated act does not apply. The ecodesign transition period of at least 18 months does not apply either.

Monitor the toy regulation. A new adoption year for textiles or furniture does not move the toy date. See what is a delegated act and how to read the timeline.

For an ecodesign product group, a published year is the year the Commission adopts the rule. Compliance starts later, after the scrutiny period and a transition period of at least 18 months. Do not apply that arithmetic to your toy, because 1 August 2030 is the date the duty starts.

The date is 1 August 2030, and it is an application date

ItemDetailStatus
Application date1 August 2030The date the toy passport duty starts
InstrumentThe EU toy regulationAdopted. It is a sector regulation.
Entry into forceNot given on this pageThe sources disagree
Ecodesign delegated act for toysNoneToys are absent from the published programme

Every source checked gives the same application date. That agreement is why this page states it plainly. See every dated milestone for the other dates on this subject.

This page gives no entry into force date, because the sources disagree

Three sources give three different dates for the start of the toy regulation. A Commission news page gives one date. The address of that same page gives another. Intertek gives a different date for the publication in the Official Journal.

This site does not publish a date that its sources dispute. So you get the application date and nothing else. If you find an entry into force date somewhere else, this paragraph is why this page omits it.

The application date is the date that decides what you must do. The missing date does not change your work.

Do not buy a passport system for a 2030 date

The date is about four years away, and the detail is not settled yet.

The standards work is not finished. Six European passport standards are published, and two more are still under approval. This site does not confirm which of them a toy passport will use. See which standards apply.

This site also holds no verified detail about what a toy passport must contain. No source checked lists the data fields for a toy.

If you buy a system today, you buy it before the requirements are clear. Spend the time on your product data instead. Find out where you store that data and who owns it, because that work helps under any rule.

The toy safety directive binds you today, and the passport does not

The passport is not your current requirement. A toy placed on the EU market must meet the toy safety directive, Directive 2009/48/EC.

That directive requires each of these:

  • the essential safety requirements
  • the CE mark
  • an EU declaration of conformity
  • technical documentation
  • warnings preceded by the word "Warning"

Analyse the hazards of a wooden pull-along toy or a soft toy first. Do this before you place the toy on the EU market. The directive names chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazards. You must also assess the exposure that the toy creates.

Your warnings must state each of these:

  • the minimum or maximum age of the user
  • the abilities of the user, where relevant
  • the maximum or minimum weight
  • the need for adult supervision

Keep the technical documentation and the declaration of conformity for 10 years after you place the toy on the market.

RequirementWhere it is written
Hazard analysis, conformity assessment and technical documentationDirective 2009/48/EC, Article 4(3), Article 18, Article 19, Article 21 and Annex IV
Warnings, and what each warning must sayDirective 2009/48/EC, Article 11 and Annex V
Content of the declaration of conformityDirective 2009/48/EC, Annex III

Two other EU rules reach a toy before 2030

Packaging. The box and the wrapping are a separate product in EU law. That product has its own rule, Regulation (EU) 2025/40, which applies from August 2026 with phased implementation. See packaging.

Batteries. The battery regulation, Regulation (EU) 2023/1542, is in force. Check the battery inside a ride-on toy or a remote-control car. Article 77 sets a passport duty. It applies from 18 February 2027 to each of these:

  • each light means of transport (LMT) battery, such as an e-bike battery
  • each industrial battery with a capacity greater than 2 kilowatt hours
  • each electric vehicle battery

Every other battery carries a QR code that leads to other information, and that code is not a passport. See batteries.

Your EU importer usually carries the duty, and you still supply the documents

Your company probably has no office in the EU. An EU-funded consortium paper states that the passport duty falls on the operator that places the product on the EU market. If you have no EU establishment, that operator is your EU importer.

The same paper states that a non-EU manufacturer stays a duty holder whatever its establishment. So the importer does not remove your responsibility. The importer can pass on only what you send.

Agree in writing who supplies each document, who approves it, and who updates it. See what a non-EU exporter must supply and who is the economic operator.

If you sell other products as well, read what this means for New Zealand exporters.