Toy and detergent schemas carry almost none of their mandated Annex VI content — and it is in the acts, not the pending implementing acts

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The toy and detergent schemas are placeholders — 8 and 9 fields — against annexes that mandate 14 and 9 specific items. Both product groups are marked provisional, and their manifests say the implementing acts are unpublished.

That last point is true but misleading, and it is why this is filed.

The content is in the acts, not in the pending implementing acts

Toy Safety Regulation (EU) 2025/2509 Art. 49(1) and Detergents Regulation (EU) 2026/405 Art. 21(10) empower implementing acts covering data carriers, layout and positioning, access rights, who may create or update data, and the arrangements for doing so.

Not the content. Content is Annex VI Part I (toys) and Annex VI Part A (detergents). Both are adopted, final, and law today.

So "a conformant data carrier cannot be generated today" is right, and "the passport content is unknown" is not. The content is knowable now, and the dates are fixed: detergents 23 September 2029, toys 1 August 2030.

Toys — Annex VI Part I, 14 mandatory items

	Requirement	State
(a)	unique product identifier of the toy	✅ envelope
(b)	name and address of the manufacturer and, where applicable, the authorised representative, as well as the unique operator identifier	🟡 envelope; contact completeness is #241
(c)	name and address of the economic operator responsible for the Art. 4 of (EU) 2019/1020 tasks, as well as the unique operator identifier	✅ ResponsibleOperator — the Annex III(k) class of #251
(d)	a statement that the passport is issued under the sole responsibility of the manufacturer	⬜
(e)	object of the passport — identification allowing traceability, including a colour image of sufficient clarity	⬜ image is its own issue
(f)	where applicable, the commodity code	🟡 carried on the registry payload, not as passport content
(g)	references to all Union law that the toy is in compliance with	⬜
(h)	where applicable, the mention that the passport replaces the EU declaration of conformity	⬜ see below
(i)	references to the harmonised standards used, or common specifications	⬜
(j)	where applicable, name and number of the notified body and the certificate reference	⬜
(k)	the CE marking	🟡 ceMarking: boolean
(l)	list of allergenic fragrances present in the toy subject to Annex II Appendix Part B point 1 labelling	⬜ svhcSubstances is a different list
(m)	the communication channel provided for in Art. 7(12)	⬜
(n)	reference of the DPP service provider hosting the back-up copy	⬜ same as #260

Part II is optional: safety information and warnings; instructions of use.

Current schema: gtin, ageGroup, primaryMaterial, ceMarking, countryOfOrigin, svhcSubstances, containsBattery, repairabilityInfo.

Art. 19(5) is the reason to care early

Where the passport contains everything the declaration of conformity needs, the manufacturer is deemed to comply with the obligation to draw up an EU declaration of conformity under Regulation (EU) 2024/1689 (AI Act), Regulation (EU) 2024/2847 (CRA), Directive 2011/65/EU (RoHS), 2014/30/EU (EMC), 2014/35/EU (LVD), 2014/53/EU (RED) or Delegated Regulation (EU) 2019/945. Annex VI point (h) is the flag that invokes it.

A passport replacing seven separate legal documents is a product capability, not a compliance chore. It is also the single clearest answer to "why would a manufacturer want this" that exists anywhere in the corpus.

Detergents — Annex VI Part A, 9 mandatory items

	Requirement	State
(a)	trade name, UPI, and a colour image of the packaging or label of sufficient clarity	⬜ image
(b)	manufacturer name, postal and electronic address and telephone number, and unique operator identifier; importer or authorised representative where applicable	🟡 same shape as #241
(c)	reference to the DPP service provider hosting the back-up	⬜ #260
(d)	identification allowing traceability	🟡
(e)	an indication that the passport is issued under the sole responsibility of the manufacturer	⬜
(f)	where applicable, commodity codes	🟡
(g)	a statement that compliance has been demonstrated, and where relevant references to other Union law complied with	⬜
(h)	full list of substances intentionally added, identified per Art. 18(3) of Regulation (EC) No 1272/2008; carry-over preservatives where label-required	🟡 surfactants only
(i)	list of all intentionally added micro-organisms with taxonomic classification — genus, species, and strain name or code	⬜

Current schema: gtin, productType, format, surfactants, countryOfOrigin, co2ePerUnitKg, packagingRecyclable, recommendedDosageMl, biodegradable.

⚠️ Point (h) carries a carve-out the schema cannot currently express: it does not apply to industrial and institutional detergents, or to surfactants, where the equivalent information is given by a safety data sheet under Art. 31 of Regulation (EC) No 1907/2006. That is a conditional obligation keyed on product sub-type — the same shape the per-category battery requirement table already solves, and the precedent to follow.

What this issue is asking for

Not fourteen field-add PRs. The useful first step is a decision on shape, because several items are not simple scalars:

1. The recurring trio — "issued under the sole responsibility of the manufacturer", "compliance has been demonstrated", "references to all Union law complied with" — appears in both acts and would appear again in the next one. It belongs on the envelope, not in two product-group schemas. The instrument catalogue can generate the Union-law references rather than having an operator retype them.
2. Notified body identity and certificate reference is a conformity-assessment block that toys needs and other regimes will.
3. The CE marking — decide whether a boolean is the honest representation of "the CE marking" or whether the annex wants the mark itself.
4. Only then the group-specific lists: allergenic fragrances, intentionally added substances, micro-organisms.

Filed as one issue rather than fourteen because the annexes are a single specification and splitting them would lose the shared structure — which is most of the value here.

No urgency label above backlog. Nothing binds for three years. What has changed is that the work is now specified rather than unknown.