When does the toys DPP become mandatory?+
The revised Toy Safety Regulation is expected to be adopted during 2025, with a thirty-month transition period. The first DPP-linked requirements bite from H1 2027 (unique identifier, data carrier, EU Declaration of Conformity attached to DPP) and full applicability follows in Q1 2028, at which point Directive 2009/48/EC is repealed and the TSR governs every toy placed on the EU market.
Does the DPP replace the CE marking and the EU Declaration of Conformity?+
No. CE marking remains the visible conformity mark on the toy itself, and the EU Declaration of Conformity remains a legally signed document that the manufacturer or EU authorised representative must hold and provide on request. The DPP is the digital layer that exposes the EU DoC, the technical file and the underlying compliance data in a queryable, machine-readable form accessible to customs, market-surveillance authorities, distributors, retailers and the end-user parent.
Are imported toys and online-marketplace listings in scope?+
Yes. EU importers, fulfilment-service providers, online-marketplace operators and distributors who place toys on the EU market under their own brand are economic operators under the TSR and inherit DPP obligations even when the original manufacturer is non-EU. From TSR enforcement, marketplaces will be required to query the DPP before publishing any toy listing, and customs authorities will detain at port of entry any toy whose DPP fails resolution.
Can trade secrets and contract-factory identity be protected inside the DPP?+
Yes. The TSR provides for tiered access: public, authority-only and recycler-only fields. Commercially sensitive data such as detailed BOM, supplier identity, pigment-system formulation and process parameters can be restricted to designated parties (market surveillance authorities, notified bodies, customs) while the public DPP view surfaces only the safety-relevant fields a parent or retailer needs to see.
Does the DPP replace the printed warning label on the packaging?+
The revised TSR introduces a digital warning-label regime alongside, not instead of, the existing printed warnings. Safety-critical warnings (small parts, magnets, ride-on, suffocation-bag) remain printed on the packaging in line with TSD Annex V. The digital warning label is reachable through the DPP data carrier and provides the full set of warnings, instructions for use and safety information in every required Member-State language.
How does the toys DPP federate with the battery passport for battery-operated toys?+
Any toy containing one or more cells is subject to both the TSR and the Battery Regulation 2023/1542. The toy DPP cross-references one or more battery passports through a battery UPI, exposing cell chemistry (LiPo, LiCoO2, LiFePO4, NiMH, alkaline), capacity, voltage, securing-mechanism evidence under EN 62115 cl. 14.6, and end-of-life routing. The federation pattern is loosely coupled and cryptographically linked so a battery replacement does not invalidate the toy-level DPP.
What data carrier should we use on the toy — QR, NFC or both?+
The TSR permits the data carrier on the toy itself, on the packaging or on the instructions, and accepts QR code, NFC tag or equivalent machine-readable carrier. Printed QR is the universal default and survives most use scenarios. NFC tags survive washing and labels but require an NFC-enabled reader. Many manufacturers adopt a hybrid model with a printed QR on the packaging for retail-shelf scanning and a sewn-in NFC tag on the toy itself for the post-purchase parent-facing experience.
What happens to toys placed on the market before the TSR applicability date?+
Toys lawfully placed on the EU market before the TSR applicability milestone may continue to circulate under the previous TSD regime until exhaustion of stock. Importers and distributors moving new SKUs into warehousing after the deadline must onboard the DPP infrastructure; mixing pre-TSR and post-TSR stock under the same SKU without batch-level traceability is one of the highest enforcement risks the industry is currently underestimating.