Digital Product Passports Outside ESPR

Toys, construction products, and vehicles get their own Digital Product Passports, built on or aligned with ESPR infrastructure. The toy passport applies from 1 August 2030, one per toy model; the vehicle passport applies from 1 September 2032, one per vehicle; and the construction product passport applies 18 months after an Article 75(1) delegated act that has not yet been adopted.

Prepare now

Toy makers should plan one passport per toy model, registered in the ESPR Registry before the toy is placed on the market.

Locked Toys from 1 August 2030; vehicles from 1 September 2032; construction date not set

Who it covers

Toy and construction product makers, importers, and distributors selling in the EU, and vehicle manufacturers placing vehicles on the EU market.

In detail

Three regulations outside ESPR also require a DPP. Toy manufacturers must create one per toy model from 1 August 2030, replacing the EU declaration of conformity (Toy Safety Regulation (EU) 2025/2509, Articles 19 and 59). Construction products need one 18 months after a Commission delegated act that had not been adopted by 30 September 2026 (Regulation (EU) 2024/3110, Articles 22(7) and 75). From 1 September 2032 every vehicle placed on the market must have a Digital Circularity Vehicle Passport, aligned and interoperable with battery and ESPR passports (End-of-Life Vehicles Regulation (EU) 2026/1738, Article 13(1)).

What to do

  • Toy makers: one passport per toy model from 1 August 2030, registered in the ESPR registry before market placement
  • Construction product makers: no date runs yet; watch for the Article 75(1) delegated act
  • Vehicle manufacturers: from 1 September 2032, one Digital Circularity Vehicle Passport per vehicle placed on the market, kept accurate, complete, and current (Article 13(1) and (4))

Key dates

1 August 2030
Locked
Toy Safety Regulation applies; a passport is required for each toy model
1 September 2032
Locked
End-of-Life Vehicles Regulation requires a Digital Circularity Vehicle Passport per vehicle placed on the market
Not set
Signaled
Construction product passports, 18 months after the Article 75(1) delegated act enters into force

How it connects

  • Toy passports use the ESPR registry, identifiers, and data carriers; the construction system must be based on the ESPR passport
  • The vehicle passport must be aligned and interoperable with the battery passport (Batteries Regulation Article 77) and ESPR passports, without repeating information another passport carries (Article 13(1) and (3))

Sources

This page is the DPP Obligations Outside ESPR deep dive from the ESPR Atlas hub, where it sits with the other regulation deep dives.

Frequently Asked Questions

Which products need a Digital Product Passport under laws other than ESPR?
Toys, construction products, and vehicles get their own Digital Product Passports, built on or aligned with ESPR infrastructure. The toy passport applies from 1 August 2030, one per toy model; the vehicle passport applies from 1 September 2032, one per vehicle; and the construction product passport applies 18 months after an Article 75(1) delegated act that has not yet been adopted.
What should toy makers do now?
Toy makers should plan one passport per toy model, registered in the ESPR Registry before the toy is placed on the market.
How do these passports relate to the ESPR passport?
Toy passports use the ESPR registry, identifiers, and data carriers; the construction system must be based on the ESPR passport The vehicle passport must be aligned and interoperable with the battery passport (Batteries Regulation Article 77) and ESPR passports, without repeating information another passport carries (Article 13(1) and (3))