Both the toy and detergent annexes require a colour image; the passport model has no image concept

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Two adopted regulations require a passport to carry a colour image. The passport model has no image, media or binary concept at all.

The requirement

Toy Safety Regulation (EU) 2025/2509, Annex VI Part I(e) — mandatory:

"object of the digital product passport (identification of toy allowing traceability, including a colour image of sufficient clarity to enable the identification of the toy)"

Detergents Regulation (EU) 2026/405, Annex VI Part A(a) — mandatory:

"the trade name, unique product identifier of the detergent or end-user surfactant and a colour image of the packaging or the label of the model of detergent or end-user surfactant of sufficient clarity to enable its identification"

Both are in Part I / Part A — the "shall include" lists, not the optional ones.

Current state

Searched dpp-core: no image, photo, media or thumbnail concept in the passport model, and no imageUrl field in any schema for any product group.

Why this is architectural, not a field

A passport that carries an image raises questions the model has never had to answer:

1. URL or bytes? A URL keeps the passport small and the signature cheap. Bytes make the passport self-contained and the back-up copy actually complete.

2. Who holds it for ten years? Both acts require the passport to remain available for 10 years after placing on the market, including in insolvency, liquidation or cessation of activity (toys Art. 19(2)(g), detergents Art. 21(2)(g)). An image referenced by URL is an availability obligation over an artefact stored somewhere else, and a link that rots in year seven is a passport that no longer satisfies the annex.

3. Does it travel in the back-up copy? Both acts require a back-up through a DPP service provider (toys Art. 19(13), detergents Art. 21(12)(c)). A back-up of a passport whose mandatory image lives at a URL the provider does not control is not a back-up of the passport.

4. 🚨 It reaches the seal. An image referenced by bare URL sits outside the signature over the body, so the visual identification of the product can be changed without breaking the seal. For a data point whose stated purpose is "to enable the identification of the toy", that is not a small hole.

The hash-pinning pattern already used for lineage edges is the obvious answer — reference plus content hash, so the link is external but the content is bound. Worth choosing deliberately now rather than patching later, because changing it afterwards is a persisted-shape change.

5. Size and content constraints. "Of sufficient clarity to enable identification" is a qualitative standard with no pixel count attached. Neither act gives one, and the pending implementing acts (toys Art. 49(1), detergents Art. 21(10)) cover carriers, layout, access rights and update arrangements — not this. So the standard will stay qualitative for now, which argues for storing provenance (dimensions, format, hash) alongside the reference so the judgement can be evidenced rather than asserted.

Timing

Detergents binds 23 September 2029, toys 1 August 2030. Nothing is due.

Filed now because it is a shape decision, and shape decisions are free exactly while nothing depends on them — the same reason the optional-GTIN question (#257) is worth settling early. Once a real operator has passports, adding an image to the signed body is a breaking change to a persisted shape.

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Widening this, from a later pass of the same audit.

The mandatory colour image is not the only external artefact with this problem — it is just the first one an adopted act makes mandatory. Every document a passport points at has the same five unanswered questions, and today they are all bare URL strings:

• disassemblyInstructionsUrl — Annex XIII point 2(c) of Regulation (EU) 2023/1542, mandatory for the restricted tier
• dueDiligenceUrl — Annex XIII point 1(d), public tier
• euDeclarationOfConformity — Annex XIII point 1(r), public tier
• and the toy and detergent annexes add more

Assessed against EN 18221 clause 4.4, which governs additional digital documentation carried by a passport:

Property the clause wants	State
Carried in the passport directly or by reference	✅ by reference
Reachable through the passport	✅
In a format the user can download and save to a device	⬜ unconstrained — nothing records or checks the format
Online for the passport's lifetime	⬜ nothing guarantees, monitors or evidences it
Stored and served by the back-up provider	⬜ the back-up carries the URL, never the document

⚠️ And the integrity point applies to all of them, not just the image. A declaration of conformity referenced by bare URL sits outside the signature over the body, so it can be swapped without breaking the seal. PassportRef already solves exactly this for lineage — URI plus a hash of the target — and external documents never inherited the pattern.

🚨 The sharpest case is the ten-year availability duty. Batteries Art. 78(e), ESPR Art. 11(e), toys Art. 19(2)(g) and detergents Art. 21(2)(g) all make the operator answerable for the passport remaining available, including after insolvency. A passport whose mandatory Annex XIII documents live at URLs nobody controls is not available in any sense an auditor would accept — and the failure is silent, years later, with no signal.

Suggested re-scope: treat this as "how does a passport reference an external artefact" rather than "where does the image go". One answer — reference plus content hash plus a recorded format, with a decision on whether the back-up carries bytes — covers the image, the three battery documents, and everything the next annex adds.

The image stays the forcing function, because it is the one the law makes mandatory with a date attached.