The DPP for Toys

Toys are among the most tightly regulated consumer products in the EU on safety grounds, and among the least regulated on circularity. The revision of the toy safety framework changes that by attaching a digital product passport to the safety regime.

The practical consequence is that toy manufacturers face a passport obligation grounded in legislation they already know intimately, which is a considerably gentler introduction than most sectors receive.

Safety data is the half that exists

A toy placed on the EU market already carries a substantial evidence trail: conformity assessment against harmonised standards, chemical testing, mechanical and physical property testing, and a technical file supporting the declaration of conformity.

Much of what a safety-oriented passport asks for is therefore a restructuring exercise rather than a new testing programme. The same qualification applies as in every other sector: the data exists as conclusions in documents rather than as values against a product identifier.

Circularity data is the half that does not

Toys are difficult products from a materials perspective, and the reasons are inherent to what makes them appealing rather than incidental.

The fourth row contains a genuine regulatory tension worth naming. Safety rules require that small parts cannot detach, which pushes designs toward permanent fixings, while circularity requires that components can be separated. These pull in opposite directions and safety wins, correctly.

Three regimes arrive with the battery

A large share of toys contain batteries, electronics or both, and each addition brings its own obligations that sit alongside the toy rules rather than replacing them.

• Regulation (EU) 2023/1542 — portable battery rules including removability, and a battery passport where thresholds are met.
• Directive 2012/19/EU — electrical and electronic toys are WEEE, with collection and treatment obligations.
• Directive 2011/65/EU — RoHS substance restrictions apply to the electronic content.
• Radio equipment rules — for connected toys, with cybersecurity requirements attached.

Battery removability is the requirement with the most visible design impact. A toy where the battery cannot be removed by the end user is straightforwardly non-compliant for portable batteries, and it also cannot be recycled properly, since the battery must be extracted before any other treatment.

Traceability and the counterfeit problem

Toys are among the most counterfeited product categories, and counterfeit toys are dangerous in a way counterfeit handbags are not. They fail exactly the tests that the genuine product passed.

The last node carries an important caveat. A passport does not prevent copying an identifier, and a counterfeiter can print a genuine code. What it does is make the absence of a record, or a code that resolves to something inconsistent, detectable without laboratory testing.

What a toy passport should carry

The audiences are unusually distinct here, and designing for the wrong one produces a record that serves nobody well.

A parent wants age suitability, allergen and material information, battery safety guidance and whether it can be repaired. A retailer wants conformity evidence and recall status. A recycler wants material composition, battery location and how to open the item. None of these is served by a single undifferentiated data dump.

Par où commencer

Structure the bill of materials by polymer and component before anything else, because it is the input every downstream obligation shares and the thing most manufacturers hold least precisely.

Toy bills of materials frequently describe parts commercially — a moulded body, a fabric cover — without recording which polymer or fibre each is. That single gap blocks recyclability assessment, packaging-style material reporting and any credible end-of-life instruction, and closing it requires asking suppliers rather than testing products.

It is also the work that transfers regardless of what arrives next. Should the Commission bring toys into scope under Regulation (EU) 2024/1781, a material-level bill of materials is the foundation any ecodesign parameter would be built on, and it is equally the foundation for packaging reporting and producer responsibility fees today.