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Laptops and Tablets Under ESPR
Laptops and tablets are covered by the Ecodesign for Sustainable Products Regulation (EU 2024/1781) and are among the first product categories for which a delegated act is expected. Manufacturers and importers placing laptops and tablets on the EU market must prepare for Digital Product Passport requirements, repairability mandates, and minimum software support obligations.
Truth Anchor: ESPR Article 4 and Recital 18 identify computers and computer servers as priority product categories. The Commission's working plan for 2022–2024 includes laptops and tablets as a priority for early delegated act adoption. Source: EUR-Lex CELEX:32024R1781
Current Regulatory Status for Laptops and Tablets
Laptops are currently subject to the Energy-related Products (ErP) Directive and the EU Energy Labelling Regulation, which set energy efficiency requirements and labelling obligations. ESPR will expand these requirements significantly by adding repairability, durability, recycled content, and Digital Product Passport obligations. The existing ErP regulations for computers (Commission Regulation EU 2019/1782) will be superseded by the ESPR delegated act for laptops and tablets.
The Commission's preparatory study for laptops and tablets (the Lot 3 study under the ErP framework) has been completed and provides the technical basis for the delegated act. The study identified repairability, battery durability, and software support as the most significant environmental improvement opportunities. The delegated act is expected to be adopted in 2025–2026.
Expected ESPR Requirements for Laptops
Repairability requirements: Laptops must be designed so that common components — batteries, screens, keyboards, RAM, storage — can be replaced by the user or an independent repairer without specialised tools. The use of non-standard screws, excessive adhesive, or soldering to attach replaceable components will be restricted. Manufacturers must make spare parts available for a minimum of five years after the last unit of a model is placed on the EU market. Repair manuals must be provided to independent repairers.
Battery requirements: Laptop batteries must retain a minimum percentage of their original capacity after a specified number of charge cycles. The expected requirement is 80% capacity retention after 1,000 charge cycles. Batteries must be replaceable without specialised tools. Battery data — chemistry, capacity, rated cycles, State of Health — must be included in the DPP.
Software support: Manufacturers must provide security updates for a minimum of five years and functional software updates for a minimum of three years after the product is placed on the EU market. Manufacturers must not use software updates to degrade the performance of older devices. Operating system compatibility must be maintained for the minimum software support period.
Recycled content: The delegated act is expected to set minimum recycled content requirements for plastics and metals used in laptop casings and internal components. The exact percentages are under development.
Energy efficiency: Laptops must meet minimum energy efficiency standards in active mode, sleep mode, and off mode. The existing ErP energy efficiency requirements will be updated and strengthened under the ESPR delegated act.
Digital Product Passport for Laptops and Tablets
Every laptop and tablet placed on the EU market after the delegated act compliance date must have a Digital Product Passport accessible via a QR code on the product or its packaging. The DPP must contain the following data:
| Data Category | Required Data Fields | Access Level |
|---|---|---|
| Product identification | Model name, model number, manufacturer, country of manufacture, date of manufacture | Public |
| Battery | Chemistry, capacity (Wh), rated cycles, State of Health threshold, replacement procedure | Public |
| Repairability | Repairability score, spare parts list, availability period, repair manual URL | Public |
| Software support | Security update end date, OS compatibility, functional update end date | Public |
| Materials | Recycled plastics %, recycled aluminium %, total weight, packaging materials | Public |
| Energy efficiency | Energy consumption (active, sleep, off), energy efficiency class | Public |
| Substances of concern | Hazardous substances, CAS numbers, concentrations, locations | Authorised access |
| End-of-life | Disassembly instructions, material recovery rates, take-back scheme | Public |
Tablets: Specific Considerations
Tablets are covered by the same delegated act as laptops. However, tablets present specific repairability challenges because they typically use more adhesive and have fewer user-serviceable components than laptops. The delegated act is expected to set tablet-specific repairability requirements that acknowledge these design constraints while still requiring meaningful repairability improvements. Screen replacement — the most common tablet repair — must be possible without specialised tools.
Tablets used in commercial and industrial applications — point-of-sale terminals, medical devices, industrial control panels — may be subject to different requirements under the delegated act, reflecting their different use patterns and longer expected service lives.
Interaction with Existing EU Regulations
Laptops and tablets are currently subject to multiple EU regulations that will interact with ESPR. The RoHS Directive (2011/65/EU) restricts hazardous substances in electronic equipment. The WEEE Directive (2012/19/EU) sets collection and recycling targets for waste electrical and electronic equipment. The Radio Equipment Directive (2014/53/EU) sets requirements for wireless communication equipment. The ESPR DPP will complement these regulations by providing a single, machine-readable record of a product's compliance status and material composition.
What Laptop Manufacturers Must Do Now
Manufacturers and importers of laptops and tablets should begin ESPR preparation immediately. The delegated act is expected in 2025–2026, and the transition period will be 18–24 months. Key preparation steps include: conducting a repairability audit of current product designs to identify components that do not meet the expected repairability requirements; establishing supplier data collection processes for recycled content and substance of concern data; selecting a DPP registry provider and beginning integration work; and reviewing software support policies to ensure they meet the minimum support period requirements.
Frequently Asked Questions
The ESPR delegated act for laptops and tablets is expected in 2025–2026, with mandatory compliance likely from 2027–2028 following an 18–24 month transition period.
Laptops must be designed so batteries, screens, keyboards, RAM, and storage can be replaced without specialised tools. Spare parts must be available for five years. Repair manuals must be provided to independent repairers.
Yes. Tablets are covered by the same ESPR delegated act as laptops. Tablet-specific repairability requirements will acknowledge design constraints while requiring meaningful improvements, particularly for screen replacement.
Security updates must be provided for a minimum of five years. Functional software updates must be provided for a minimum of three years. Manufacturers must not use updates to degrade performance of older devices.
A laptop DPP must contain product identification, battery data, repairability score and spare parts availability, software support end dates, energy efficiency data, recycled content percentages, substances of concern, and end-of-life instructions.
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Energy Efficiency Requirements for Laptops Under ESPR
Laptops and tablets are already subject to energy efficiency requirements under the Ecodesign Regulation for computers and computer servers (EU 2019/1782), which sets minimum energy efficiency requirements and energy labelling requirements. The ESPR delegated act for laptops is expected to build on these existing requirements and add new requirements for repairability, recyclability, and DPP data disclosure. The energy efficiency requirements are likely to be tightened, with a focus on reducing standby power consumption and improving the efficiency of the power supply unit.
The repairability requirements for laptops are expected to be more stringent than for smartphones, given that laptops are larger devices with more components that can be replaced. The delegated act is expected to require manufacturers to ensure that the battery, RAM, storage, and keyboard are user-replaceable or at least repairable by authorised repair technicians. Manufacturers who have moved to soldered RAM and non-replaceable batteries in recent years may need to redesign their products to comply with these requirements.
DPP Data Requirements for Laptops and Tablets
The DPP for laptops and tablets is expected to include: the device's carbon footprint across its full lifecycle; the percentage of recycled content in key materials (aluminium, copper, rare earth elements); the device's repairability score; the availability and pricing of spare parts (battery, keyboard, screen, RAM, storage); the software update commitment period; the device's energy efficiency rating; information on substances of concern; and instructions for disassembly at end-of-life. For tablets, the requirements are expected to be similar to smartphones, given the similar form factor and component set.
The carbon footprint calculation for laptops is particularly complex because laptops are used for long periods (typically 3–5 years) and the use-phase energy consumption is a significant portion of the total lifecycle carbon footprint. Manufacturers will need to calculate the carbon footprint of their devices using a standardised methodology — the Commission is expected to reference the Product Environmental Footprint (PEF) methodology for laptops. The PEF methodology requires manufacturers to collect data on energy consumption during use, which requires testing under standardised conditions.
Frequently Asked Questions
The delegated act for laptops and tablets is expected to be adopted in 2025–2026, with a compliance date approximately 18–24 months after adoption. Manufacturers should plan for compliance by 2027–2028. The existing Ecodesign Regulation for computers (EU 2019/1782) remains in force until superseded by the ESPR delegated act.
Yes. When the ESPR delegated act for laptops is adopted, it will repeal and replace the existing Ecodesign Regulation for computers (EU 2019/1782). The new delegated act will incorporate the existing energy efficiency requirements and add new requirements for repairability, recyclability, and DPP data disclosure.
The ESPR delegated act is expected to cover both laptops and tablets in a single regulation, with requirements tailored to each product type. Tablets are expected to face similar requirements to smartphones for repairability and DPP data, while laptops are expected to face additional requirements related to component replaceability and energy efficiency.
Business laptops are typically designed with repairability in mind (user-replaceable batteries, RAM, and storage) and are already better positioned for ESPR compliance than consumer laptops. The main compliance challenge for business laptop manufacturers will be the DPP data disclosure requirements and the carbon footprint calculation methodology.
The delegated act is expected to require manufacturers to make available, for a minimum period after last sale, spare parts including: battery, keyboard, screen assembly, power supply unit, RAM modules (if not soldered), and storage modules (if not soldered). The minimum availability period has not yet been confirmed but is expected to be 5–7 years.