Electronics and ICT DPP: Existing Product Rules and the Next Data Layer

Electronics already has substantial product-data obligations

For electronics manufacturers, the starting point is not an empty regulatory landscape awaiting a digital product passport. Smartphones and slate tablets already face ecodesign and energy-labelling requirements, while repair, waste, chemicals and consumer-law obligations operate alongside them.

The key distinction is between rules already applying and expected ESPR measures. A product’s EPREL entry, energy-label QR code, service portal and future DPP may connect to overlapping evidence, but they are not interchangeable legal instruments.

The Commission’s ESPR working plan addresses electronics through existing energy-related-product work and expected horizontal measures, including repairability and recyclability. It does not establish one immediate, universal DPP deadline for every ICT product. 1

Regulation 2023/1670: what has applied since June 2025

Commission Regulation (EU) 2023/1670 applies from 20 June 2025 to covered smartphones, other mobile phones, cordless phones and slate tablets placed on the EU market. Energy labelling applies from the same date to smartphones and slate tablets, under the separate labelling measure. Product definitions and exclusions matter: a slate tablet is not automatically the same regulatory category as a tablet computer running a desktop-style operating system. 1

The regulation addresses durability, battery endurance, disassembly, spare parts, repair information and software support. These are market-access requirements, not optional features that manufacturers can replace with a sustainability statement.

The Commission summarises the principal requirements as follows. Exact application depends on the product category and detailed annex provisions. 3

Area	Main requirement or regulatory direction	Evidence to retain
Battery durability	At least 800 charge cycles with at least 80% remaining capacity for covered smartphones and slate tablets	Test reports and conditions
Physical durability	Requirements addressing drops, scratches, dust and water	Category-specific test evidence
Spare parts	Specified parts available for at least seven years after model sales end	Parts catalogue and availability records
Delivery	Relevant parts supplied within five to ten working days, as applicable	Order and delivery performance
Software	Operating-system support requirements extending beyond model market availability	Support policy and release records
Repair access	Non-discriminatory access to necessary software or firmware for professional repairers	Access process and technical documentation

Seven years does not mean “seven years from launch”

The spare-parts clock is linked to the end of placing the model on the market, not simply the product announcement. A model sold for several years can therefore create a service obligation extending substantially beyond its launch anniversary.

Manufacturers should establish a controlled “end of placement on the market” date and identify who can approve it. Procurement, service and compliance teams need the same reference date; otherwise spare-parts contracts may expire before the legal obligation does.

Software commitments need precise wording

The regulation’s software provisions should not be simplified into a promise that every device receives every future operating-system feature. The relevant obligations distinguish update types and prescribe conditions and time periods.

For passport readiness, record update availability, support endpoints, relevant compatibility restrictions and the applicable policy version. Avoid a single unsupported “supported until” field that merges security updates, corrective updates and major feature upgrades.

Energy labels and EPREL

The smartphone and slate-tablet energy label adds more than an electricity-efficiency class. It communicates battery endurance per cycle, battery endurance in cycles, repeated-free-fall reliability, ingress protection and a repairability class. Its QR code links to the product’s information in EPREL, the European Product Registry for Energy Labelling. 1

Suppliers must manage model registration and the required product information; dealers have display duties for physical and online sales. An energy label is therefore part of a regulated information chain from manufacturer or importer through retail presentation.

EPREL is principally model-level infrastructure. A future DPP may need different granularity and lifecycle information. An individual handset’s replacement battery, repair history or refurbished status is not automatically captured by its model’s energy-label entry.

The practical objective should be consistent identifiers and evidence reuse, not an assumption that an EPREL registration already constitutes a DPP.

Understanding the EU repairability index

The repairability class uses an A–E scale, distinct from the energy-efficiency scale. Its calculation considers factors such as disassembly, fasteners, tools, spare parts, software support and repair information. The result is a regulated model assessment, not a consumer satisfaction rating or a guarantee of a particular repair price. 1

A strong compliance file should allow an assessor to reconstruct the result:

Which priority parts were evaluated?
What disassembly sequence and tools were assumed?
Which fasteners are reusable?
What repair information was available?
What spare-parts and software commitments support the score?

Do not substitute a national repairability index or a private platform score for the EU class. Different methods can produce different outcomes without either result being arithmetically wrong.

For DPP planning, store the score’s inputs, method version and evidence links. A letter alone is not sufficient for future verification or product redesign.

Right to repair: the consumer-service layer

Directive (EU) 2024/1799 had to be transposed and applied by Member States from 31 July 2026. It complements ecodesign: product rules determine relevant repairability requirements, while the directive creates consumer-facing repair obligations for covered goods listed in its Annex II. It is not an unconditional right to repair every electronic device indefinitely. 1

For covered products, manufacturers must provide repair within a reasonable time and at a reasonable price, subject to the directive’s conditions. Rules also address unjustified contractual, hardware and software barriers to repair, and access to reasonably priced spare parts.

Within the legal guarantee framework, choosing repair rather than replacement triggers an extension of the seller’s liability period by at least 12 months, under the applicable national implementation. This should not be described as a universal new manufacturer warranty on every out-of-warranty repair. 2

A manufacturer therefore needs more than downloadable repair manuals. It needs an operational service route: responsibility allocation, diagnosis, quotations, parts logistics, repair completion and consumer communication.

WEEE remains a separate compliance system

The Waste Electrical and Electronic Equipment Directive governs collection and treatment responsibilities, producer registration, financing, reporting and relevant information and marking requirements. It remains separate from ecodesign, energy labelling and any expected DPP obligation.

A passport could help treatment operators identify components and disassembly steps. It does not replace national producer registrations or prove that required collection and recycling finance has been provided.

Companies should distinguish three records:

Product design evidence: what the equipment contains and how it can be dismantled.
Market-placement records: what quantities were supplied in each jurisdiction.
Waste-management evidence: what collection and treatment obligations were fulfilled.

These records can connect through identifiers, but their quantities, responsible entities and legal retention requirements are not necessarily identical. The governing WEEE framework is Directive 2012/19/EU.

Expected ESPR horizontal measures

The working plan schedules horizontal repairability work, including scoring, indicatively for 2027, and recyclability and recycled-content work for electrical and electronic equipment indicatively for 2029. These are expected adoption milestones, not application dates or final technical requirements. 1

Future measures must interact with existing product rules. A business should not assume that a horizontal score will automatically replace smartphone-specific requirements, or that every electronics category will need identical passport attributes.

The most robust preparation is modular: maintain shared identity and evidence infrastructure, while allowing different product categories to expose different mandatory information.

Expected electronics DPP data and access

The following is a recommended preparation structure, not an adopted universal electronics field list.

Expected data area	Practical content
Product identity	Model, variant, responsible operator and relevant identifiers
Compliance	Declarations, regulated classes and evidence references
Repair	Parts compatibility, disassembly steps, tools and service routes
Software	Update policy, support dates and necessary repair software access
Materials	Relevant material and substance information
Circularity	Reuse, refurbishment, dismantling and recycling guidance
Lifecycle events	Repairs and component changes where appropriate
Environmental evidence	Method-specific footprint or resource information where required

Public information should be separated from restricted repair or authority evidence. Device user data should not become passport content by default. Ownership changes, repair records and data-erasure confirmation require careful privacy and security design.

CIRPASS-2’s electronics pilots test precisely these operational questions, including repair, second-hand IT, maintenance and end-of-use recovery. They are demonstrations, not legal certification schemes. 2

Implementation checklist

Classify products using the exact regulatory definitions.
Maintain evidence for the ecodesign requirements already applying.
Reconcile energy-label values with EPREL and technical files.
Document repairability calculations and inputs.
Track the correct spare-parts and software-support reference dates.
Review national implementation of the right-to-repair directive.
Keep WEEE registration and reporting separate from passport development.
Pilot a repairer retrieving information without manufacturer intervention.
Design lifecycle records without exposing personal device data.
Label unadopted ESPR requirements as expected.
Require persistent access, versioning and export from DPP providers.

Sources

Last reviewed 2 November 2026. Guidance only — not legal advice. View as Markdown