Toys Digital Product Passport: the Toy Safety Regulation and GPSR
What EU toy manufacturers need to know about the digital product passport under Toy Safety Regulation (EU) 2025/2509, and how the General Product Safety Regulation applies to toys today.
45 months until the toy digital product passport applies (1 August 2030)
Two EU regulations for toys
Applies since 13 December 2024
GPSR: Regulation (EU) 2023/988
The General Product Safety Regulation applies to toys only in part, because toys are covered by Union harmonisation legislation (Article 2(1)). Its economic operator obligations in Chapter III, Section 1 (Articles 9 to 18) do not apply to toys. Rules that do apply include the information an online or distance-sales offer must show (Article 19), accident notification through the Safety Business Gateway (Article 20), the duties of online marketplaces (Article 22) and product safety recalls (Articles 35 to 37).
Applies from 1 August 2030
Toy Safety Regulation (EU) 2025/2509
Adopted on 26 November 2025, it replaces the Toy Safety Directive 2009/48/EC. Before placing a toy on the market, the manufacturer must create a digital product passport for that toy model (Article 19). The passport uses the data carriers, unique identifiers and registry of the ESPR framework (Articles 21 and 22).
At a glance
Toys placed on the EU market will need a digital product passport under Toy Safety Regulation (EU) 2025/2509, which applies from 1 August 2030 and requires the manufacturer to create a passport for each toy model before placing it on the market (Article 19). The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024, but only in part for toys, which are covered by Union harmonisation legislation: its distance-sales, accident-notification, online-marketplace and recall rules apply, and its economic operator obligations in Chapter III, Section 1 (Articles 9 to 18) do not.
- Toy Safety Regulation (EU) 2025/2509 was adopted on 26 November 2025 and applies from 1 August 2030, when it repeals Directive 2009/48/EC.
- The manufacturer must create a digital product passport for each toy model before placing it on the market (Article 19).
- The toy passport uses ESPR data carriers, unique identifiers and the ESPR registry (Articles 21 and 22).
- GPSR (Regulation (EU) 2023/988) has applied since 13 December 2024; for toys its Chapter III, Section 1 obligations (Articles 9 to 18) do not apply (Article 2(1)).
- Toys are not in the ESPR working plan for 2025 to 2030 (COM(2025) 187).
What the toy passport must contain
Annex VI, Part I, of Regulation (EU) 2025/2509 lists the information every toy passport must include.
Identification
The unique product identifier, identification of the toy allowing traceability with a colour image, and the commodity code where applicable.
Responsible operators
Name, address and unique operator identifier of the manufacturer, any authorised representative and the operator responsible under Article 4 of Regulation (EU) 2019/1020, plus a statement that the passport is issued under the manufacturer's sole responsibility.
Conformity
References to all Union law the toy complies with, the harmonised standards or common specifications used, the notified body and certificate where one was involved, and the CE marking.
Other required content
Allergenic fragrances subject to labelling, the complaints channel required by Article 7(12), and the passport service provider holding the back-up copy. Safety information and instructions may be added.
Toy passport and GPSR: common questions
No. GPSR (Regulation (EU) 2023/988) applies to products only insofar as no specific Union provisions with the same objective regulate their safety (Article 2(1)). Toys are covered by the Toy Safety Directive 2009/48/EC, which Toy Safety Regulation (EU) 2025/2509 replaces from 1 August 2030. Because toys fall under Union harmonisation legislation, GPSR's economic operator obligations in Chapter III, Section 1 (Articles 9 to 18) do not apply to them, while other parts do, such as the distance-sales information in Article 19, accident notification in Article 20, online marketplace duties in Article 22 and the recall rules in Articles 35 to 37.
Not GPSR's. Article 2(1), third subparagraph, point (b), of GPSR disapplies its Chapter III, Section 1, including the Article 9 technical documentation duty, for products covered by Union harmonisation legislation such as toys. Toy manufacturers draw up technical documentation under Article 21 of the Toy Safety Directive 2009/48/EC and, from 1 August 2030, under Article 27 of Toy Safety Regulation (EU) 2025/2509.
The toy must bear a type, batch, serial or model number, and the manufacturer's and importer's names and contact addresses must appear on the toy or, where that is not possible, on its packaging or an accompanying document (Toy Safety Directive, Articles 4(5), 4(6) and 6(3); Toy Safety Regulation, Article 7(5) and (6), from 1 August 2030). For online and distance sales, GPSR Article 19 requires the offer to show the manufacturer's name and contact details, the responsible person where the manufacturer is outside the EU, information identifying the product including a picture, and the warnings and safety information.
GPSR (Regulation (EU) 2023/988) has applied since 13 December 2024 (Article 52), replacing the General Product Safety Directive 2001/95/EC. For toys it applies only in part, because toys are covered by Union harmonisation legislation (Article 2(1)). Under the transitional provision in Article 51, products placed on the market before 13 December 2024 in conformity with Directive 2001/95/EC may continue to be made available.
Not directly. The digital product passport for toys is created by Toy Safety Regulation (EU) 2025/2509 (Article 19), applicable from 1 August 2030, not by ESPR, and toys are not in the Commission's ESPR working plan for 2025 to 2030 (COM(2025) 187). The toy passport does build on ESPR: its data carriers and unique identifiers follow the ESPR standards, requirements for digital product passport service providers set in delegated acts under Article 11, third paragraph, of Regulation (EU) 2024/1781 also apply to it (Toy Safety Regulation, Article 21), and operators upload the toy's identifiers to the registry set up under Article 13(1) of Regulation (EU) 2024/1781 (Toy Safety Regulation, Article 22).
Further reading
Regulatory Guide
GPSR — General Product Safety
How GPSR 2023/988 applies to toys only in part: distance-sales information, accident notification, online marketplace duties and recalls.
Regulatory Guide
ESPR 2024/1781 — Complete Guide
How the ESPR framework works, including the identifiers and registry that the Toy Safety Regulation's passport relies on.
Regulatory Guide
EU Central DPP Registry
How the Commission's digital product passport registry works. For toys, Article 22 of Regulation (EU) 2025/2509 requires the product and operator identifiers to be uploaded to it before the toy is placed on the market.
Other industries: Building Materials DPP · Furniture DPP · GPSR Compliance