Electronics and ICT equipment are a priority sector in the ESPR Work Plan 2024–2027. The delegated act is expected in 2026, with compliance requirements entering into force in 2027–2028. Electronics manufacturers must prepare for repairability scores, spare parts availability data, software update timelines, and recycled content declarations in the DPP.
The ESPR electronics delegated act is expected to cover: smartphones and mobile phones, laptops and tablets, desktop computers, monitors and displays, televisions, printers, and other ICT equipment. The Commission's preparatory study identified these as the highest environmental impact electronics categories.
| Data Category | Expected Requirement |
|---|---|
| Repairability score | 0–10 repairability score based on spare parts availability, disassembly ease, repair documentation, and software update availability |
| Spare parts availability | Minimum period of spare parts availability (years), list of available spare parts with part numbers and pricing |
| Software update availability | Minimum period of security updates and OS updates, end-of-software-support date |
| Battery replaceability | Whether the battery is user-replaceable, professional-replaceable, or non-replaceable; Battery Passport reference |
| Recycled content | Percentage of recycled materials by weight, particularly recycled plastics, recycled metals (gold, silver, copper, cobalt) |
| Critical raw materials | Content of critical raw materials (cobalt, lithium, rare earth elements) per unit |
| Energy consumption | Typical energy consumption (TEC) in kWh/year, energy efficiency class |
| Hazardous substances | SVHC declarations, RoHS compliance status, PFAS content |
The ESPR delegated act for electronics and ICT products will build on the existing Ecodesign Regulation for smartphones and tablets (EU 2023/1669) and extend DPP requirements to a broader range of electronic products. The DPP for electronics is expected to include: product identifier (model number, batch number, serial number), manufacturer identity and EU Authorised Representative details, bill of materials for critical raw materials including cobalt, lithium, tantalum, and rare earth elements, repairability score and spare parts availability commitment, software support end date, battery capacity and State of Health methodology, carbon footprint per unit, recycled content percentage for critical materials, and end-of-life disassembly instructions. The data carrier must be a QR code compliant with ISO/IEC 18004 and GS1 Digital Link standards.
The EU's Right to Repair Directive (EU 2024/1799), adopted in 2024, works in direct conjunction with the ESPR electronics delegated act. The Right to Repair Directive requires manufacturers of certain electronics categories to make spare parts, repair tools, and repair information available to independent repairers for a minimum period after the product is placed on the market. The ESPR DPP for electronics will serve as the technical vehicle for delivering this repair information — the DPP will contain links to repair manuals, spare parts catalogues, and disassembly instructions. Manufacturers that design products to be difficult to repair will face both ESPR non-compliance and Right to Repair Directive violations simultaneously.
The EU Critical Raw Materials Act (EU 2024/1252) intersects directly with the ESPR electronics delegated act. The Critical Raw Materials Act identifies 34 critical raw materials and 17 strategic raw materials that are essential for the EU's green and digital transitions. Electronics are the primary consumer of many of these materials — smartphones alone contain over 60 different elements from the periodic table. The ESPR electronics DPP will require manufacturers to disclose the quantity of critical raw materials used per unit, the country of origin of those materials, and the recycled content percentage. This data will feed directly into the EU's critical raw materials monitoring system and will be used to set future recycled content targets under the Critical Raw Materials Act.
| Electronics Category | Current Regulation | ESPR DPP Expected |
|---|---|---|
| Smartphones and tablets | EU 2023/1669 (Ecodesign) | 2025–2026 (DPP extension of existing regulation) |
| Laptops and notebooks | EU 2023/2533 (Ecodesign) | 2026–2027 |
| Servers and data storage | EU 2019/424 (Ecodesign) | 2027–2028 |
| Televisions and displays | EU 2019/2021 (Ecodesign) | 2026–2027 |
| Consumer electronics (audio, cameras) | No current Ecodesign regulation | 2027–2028 (new delegated act) |
The EU electronics sector is one of the most heavily regulated sectors in the EU. Electronics manufacturers must comply with a complex web of EU legislation: the RoHS Directive (restriction of hazardous substances), the WEEE Directive (waste electrical and electronic equipment), the Radio Equipment Directive (RED), the Low Voltage Directive (LVD), the Electromagnetic Compatibility Directive (EMCD), and the existing Ecodesign regulations for specific product categories (smartphones, laptops, washing machines, refrigerators, televisions, lighting). ESPR adds a new layer to this regulatory framework by introducing DPP requirements and expanding the ecodesign parameters beyond energy efficiency to include repairability, durability, recycled content, and chemical substance disclosure.
The repairability score for electronics is calculated using the methodology defined in the Ecodesign Regulation for the specific product category. For smartphones (EU 2023/1669), the repairability score is calculated based on five criteria: availability of spare parts (scored 0–10), availability of repair and maintenance information (scored 0–10), ease of disassembly (scored 0–10), availability of software updates (scored 0–10), and repairability assessment (scored 0–10). The overall repairability score is the weighted average of the five criteria scores. The score must be displayed on the product's DPP and, for consumer products, on the product label. Products with a repairability score below a minimum threshold specified in the delegated act cannot be placed on the EU market.
The WEEE Directive (EU 2012/19/EU) requires producers of electrical and electronic equipment to register with national WEEE schemes, fund the collection and recycling of WEEE, and report on the volumes of equipment placed on the market and collected for recycling. The ESPR electronics DPP will integrate with the WEEE reporting framework — the DPP will contain the WEEE category code, the producer registration number, and the end-of-life disassembly and recycling instructions. This integration will enable more accurate WEEE reporting and will help WEEE scheme operators to optimise their collection and recycling infrastructure. Electronics manufacturers that are already complying with WEEE will have a significant head start on the ESPR DPP end-of-life data requirements.
For electronics products with software (smartphones, laptops, televisions, smart appliances), the ESPR DPP must include information on the software update policy — specifically, the minimum period for which software updates will be provided and the end-of-support date. The existing Ecodesign regulations for smartphones (EU 2023/1669) and laptops (EU 2023/2533) already require manufacturers to provide security updates for a minimum of 5 years and operating system updates for a minimum of 3 years after the product is placed on the market. The ESPR electronics delegated act is expected to extend these requirements to other electronics product categories and to require disclosure of the software update policy in the DPP. Manufacturers that have already implemented software update policies for their smartphones and laptops should extend these policies to their other electronics products as part of their ESPR preparation.
The EU Right to Repair Directive (EU 2024/1799) requires manufacturers of certain consumer products (smartphones, tablets, laptops, vacuum cleaners, washing machines, dishwashers, refrigerators, televisions) to make spare parts and repair tools available to independent repairers at fair and non-discriminatory prices, and to provide repair information. The Right to Repair Directive and ESPR are complementary — ESPR's repairability score requirements incentivise manufacturers to design products that are easier to repair, while the Right to Repair Directive ensures that independent repairers have access to the parts and information needed to repair them. Electronics manufacturers should ensure that their ESPR compliance programme addresses both the ESPR repairability score requirements and the Right to Repair Directive spare parts availability requirements.
The Waste Electrical and Electronic Equipment (WEEE) Directive (EU 2012/19/EU) requires manufacturers of electrical and electronic equipment to fund the collection, treatment, and recycling of WEEE. ESPR and the WEEE Directive are complementary instruments — ESPR addresses the product design phase (making electronics more durable, repairable, and recyclable), while the WEEE Directive addresses the end-of-life phase (ensuring that electronics are collected and recycled rather than landfilled). The ESPR electronics DPP will include end-of-life information that supports WEEE compliance — specifically, the DPP will contain the WEEE producer registration number and the WEEE collection point locator URL. Electronics manufacturers that are already complying with the WEEE Directive will have a foundation for the ESPR DPP end-of-life information requirements.
The ESPR electronics delegated act is expected to be published in 2026, with compliance requirements entering into force in 2027–2028. The Commission's preparatory study covers smartphones, laptops, tablets, TVs, and other ICT equipment.
Yes. The EU Right to Repair Directive (Directive (EU) 2024/1799) requires repairability information for consumer electronics. ESPR will add DPP requirements that overlap with Right to Repair obligations — manufacturers who build Right to Repair compliance systems will find significant data reuse opportunities for the ESPR DPP.
The ESPR electronics delegated act is expected to require a repairability score (0–10 scale) based on criteria including: availability of spare parts, ease of disassembly, availability of repair documentation, and software update availability. The scoring methodology will be specified in the delegated act.
ESPR applies to products placed on the EU market for the first time. Refurbished electronics placed back on the market may be subject to ESPR requirements under the applicable delegated act. The delegated act will specify transitional provisions for refurbished products.
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Products without a valid DPP can be refused entry. Register now at Africa's first ESPR-compliant DPP registry.
Register Your Digital Product Passport →Non-EU electronics manufacturers that export to the EU market must comply with all ESPR requirements, including the DPP requirements. The key compliance obligations for non-EU electronics manufacturers are: appointing an authorised representative in the EU; preparing an EU Declaration of Conformity; preparing technical documentation; implementing the DPP data carrier on the product; registering the product in the EU product database; and ensuring that spare parts and repair documentation are available to EU consumers and independent repairers. Non-EU manufacturers should be aware that the EU's market surveillance authorities have the power to audit non-EU manufacturers' facilities and to request technical documentation from non-EU manufacturers — the ESPR compliance obligations are not limited to EU-based entities. Non-EU manufacturers that fail to comply with ESPR requirements face the same enforcement actions as EU manufacturers: market withdrawal, recall, and financial penalties.
Electronics manufacturers should note that ESPR's software update requirements — which require manufacturers to provide security and functionality updates for a minimum period after the product is placed on the market — interact with the EU Cyber Resilience Act (CRA, EU 2024/2847). The CRA requires manufacturers of products with digital elements to provide security updates for the expected product lifetime. Manufacturers of electronics products should develop a unified software update policy that meets both the ESPR and CRA requirements, and should include the software update policy in their ESPR DPP data.