Toy Safety Regulation: the digital passport from 2030

From directive to regulation

The old toy rules were contained in Directive 2009/48/EC, which each member state had to transpose into national law. Consequently, interpretation and enforcement varied by country. The new rules are set out in a regulation and therefore apply directly and equally in all member states.

That difference is greater than it sounds. A regulation leaves less room for interpretation and places more emphasis on demonstrability. For you, this primarily means that regulators and trading platforms will apply the same requirements, regardless of where you sell within the EU.

The reason is well-known. Toys are a category in which safety issues are identified relatively frequently. Furthermore, the market has changed significantly. Consumers more often buy directly from suppliers outside the EU, the number of sellers via platforms has grown, and dropshipping has made the supply chain less transparent.

The digital product passport

From August 1, 2030, all toys on the European market must have a digital product passport. This is accessed via a scannable data carrier, in practice a QR code on the product, the packaging, or the accompanying documentation. The passport provides access to the product’s identification and safety information.

The goal is for core information to be digitally accessible to consumers, regulators, and customs. This includes identification, traceability, and the safety information associated with the product. This allows for faster and more consistent inspections.

A passport is not a technical file

The two are often confused. The technical file remains the substantiation with which you demonstrate that your product complies. The passport is the digital access to core information and product identification. One does not replace the other.

Are you unsure what this means for your toys?

Let us know briefly what kind of toys are involved. We will contact you regarding what we can do and the costs involved.

What is changing for online sales

The regulation sets requirements for the information that must be available before purchase. This includes CE information, safety warnings, and access to the digital passport. Compliance is therefore not just about what is on the product, but also about what is on your product page.

If you sell the same products through multiple channels, that information must be the same everywhere. A warning that appears on your own webshop but not in your listing on a trading platform is a gap that will be noticed during an inspection.

For webshops with many variants, bundles, or private labels, this requires tight variant management. A small difference in material, age indication, or warning determines which information you must display and what substantiation you need.

Stricter chemical requirements

The regulation prohibits more substances than the old directive and broadens the focus to substance groups with additional risks for children. This includes PFAS, endocrine disruptors, skin sensitizers, and certain bisphenols. Allergenic fragrances are also prohibited in toys for young children.

This fragrance ban applies to toys for children under three years of age and to toys intended to be placed in the mouth.

This affects your purchasing. A supplier stating that the product complies with the old directive says nothing about these substances. You need test reports or signed supplier declarations that specifically address the new requirements.

When it takes effect

The regulation was adopted on November 26, 2025, and has applied since January 1, 2026. Most obligations, including the digital product passport, will take effect on August 1, 2030. A transition period runs until that date, during which toys complying with the old directive may remain on the market.

The pitfall is that 2030 seems far away. If you depend on supplier data, test cycles, labeling, and listing processes, it almost always takes more time than you think. The bottleneck is rarely in creating a QR code, but in the product data and the documentation behind it.

What you should arrange now

Start with your suppliers and your product data. Establish who provides which documentation, map out your variants, and ensure that the information on your own channels and on trading platforms is identical. This work is necessary, regardless of exactly when the passport arrives.

Determine for each product who the manufacturer is and who the responsible party in the EU is.
Request test reports that address the new substance requirements, not the old directive.
Map out your variants: material, age indication, and warning per variant.
Check whether your product pages display the same information as your listings elsewhere.
Organize your documentation so that you can provide it within a reasonable timeframe.