The electronics industry is at the forefront of the EU's circular economy transformation. With e-waste being one of the fastest-growing waste streams globally—over 50 million tonnes annually—the EU has prioritized electronics for comprehensive Digital Product Passport requirements.
Under the Ecodesign for Sustainable Products Regulation (ESPR), electronics manufacturers must provide detailed information about product durability, repairability, recyclability, and environmental impact. This guide explains what you need to know and do to achieve compliance.
Why Electronics DPP Matters
- 53.6 million tonnes of e-waste generated globally in 2019
- Only 17.4% of e-waste is formally recycled
- €57 billion worth of raw materials in discarded electronics annually
- Extends product lifespans through repair and component reuse
Which Electronics Are Covered
The EU ESPR will require Digital Product Passports for most categories of Electrical and Electronic Equipment (EEE). Priority is given to products with significant environmental impact and potential for circularity improvements.
Priority Product Categories
📱 Mobile Devices
- • Smartphones
- • Tablets
- • E-readers
- • Smartwatches
- • Wireless earbuds
💻 Computing
- • Laptops
- • Desktop computers
- • Monitors and displays
- • Printers
- • External storage devices
📺 Entertainment
- • Televisions
- • Streaming devices
- • Gaming consoles
- • Audio systems
- • Smart speakers
🏠 Large Appliances
- • Washing machines
- • Dishwashers
- • Refrigerators/freezers
- • Air conditioners
- • Ovens and cooktops
🔌 Small Appliances
- • Vacuum cleaners
- • Coffee machines
- • Toasters and kettles
- • Hair dryers
- • Electric tools
💡 Lighting
- • LED bulbs
- • Smart lighting systems
- • Light fixtures
- • Outdoor lighting
- • Professional lighting
Note: Phased Implementation
Not all electronics will require DPPs simultaneously. The EU is implementing requirements through delegated acts for specific product categories. Check the DPP timeline for category-specific deadlines.
DPP Requirements for Electronics
Electronics Digital Product Passports must include comprehensive information across multiple categories. Beyond the standard DPP data fields, electronics have additional sector-specific requirements.
Core Data Requirements
| Category | Required Information | Purpose |
|---|---|---|
| Product Identity | Model, SKU, serial number, GTIN, manufacturer | Traceability |
| Materials | Component materials, hazardous substances, critical raw materials | Recycling |
| Repairability | Repair score, disassembly instructions, tool requirements | Repair enablement |
| Spare Parts | Available parts, pricing, availability period, delivery time | Maintenance |
| Software | Update support duration, firmware availability, compatibility | Longevity |
| Energy | Energy class, consumption, standby power, efficiency ratings | Consumer choice |
| Battery | Chemistry, capacity, cycle life, removability, disposal | Safety & recycling |
| End-of-Life | Recycling instructions, collection points, take-back programs | Waste management |
Repairability Index
The repairability index is a numerical score (typically 0-10) indicating how easily a product can be repaired by consumers or independent repair shops. France pioneered this with mandatory indices for smartphones, laptops, TVs, washing machines, and lawnmowers since January 2021.
Repairability Score Components
Documentation
Repair manuals, technical documents, spare parts diagrams
Disassembly
Ease of taking apart, tools needed, fastener types
Spare Parts Availability
Duration of availability, delivery time commitments
Spare Parts Pricing
Cost relative to product price, reasonableness
Product-Specific Criteria
Software support, reset capabilities, counter resets
Repairability Score Scale
0-2
Not repairable
2-4
Difficult
4-6
Moderate
6-8
Good
8-10
Excellent
The EU is working on harmonizing repairability indices across member states and integrating them into the Digital Product Passport framework. Expect mandatory repairability scores in electronics DPPs from 2027 onwards.
Spare Parts Requirements
The EU Right to Repair legislation mandates that manufacturers provide spare parts for extended periods. The DPP must include comprehensive spare parts information to enable repair by consumers, independent repairers, and professional services.
Minimum Spare Parts Availability Periods
| Product Category | Consumer Parts | Professional Parts |
|---|---|---|
| Smartphones & Tablets | 5 years | 7 years |
| Laptops | 7 years | 10 years |
| TVs & Displays | 7 years | 8 years |
| Washing Machines | 10 years | 10 years |
| Dishwashers | 10 years | 10 years |
| Refrigerators | 10 years | 10 years |
DPP Spare Parts Data Fields
- Parts catalog: Complete list of replaceable components with part numbers
- Pricing: Maximum prices for each spare part (reasonable relative to product cost)
- Ordering information: How to order parts (direct, authorized dealers, etc.)
- Delivery commitment: Maximum 15 working days from order
- Repair instructions: Step-by-step guides for part replacement
- Tools required: List of tools needed for each repair
Consumer vs. Professional Parts
Consumer parts are those safely replaceable by end users (batteries, screens, chargers).Professional parts require technical expertise or safety considerations (motherboards, power supplies). Both must be included in the DPP with appropriate access information.
Battery Requirements
Electronics containing batteries face dual requirements: the ESPR for the product and the EU Battery Regulation for the battery component. The DPP must include battery information alongside product data.
For comprehensive battery requirements, see our EU Battery Passport guide.
Battery Data in Electronics DPP
Technical Specifications
- • Battery chemistry (Li-ion, LiPo, etc.)
- • Nominal capacity (mAh/Wh)
- • Rated voltage
- • Expected cycle life
- • Fast charging specifications
- • Operating temperature range
Sustainability Data
- • Carbon footprint (kg CO2e)
- • Recycled content percentage
- • Cobalt and lithium sources
- • Due diligence information
- • Recycling instructions
- • Collection point information
Battery Replaceability Requirements
From 2027, the EU requires that portable batteries in consumer electronics must be replaceable by the end user. The DPP must include:
- Step-by-step battery replacement instructions
- Compatible replacement battery part numbers
- Safety precautions for battery handling
- Old battery disposal/recycling guidance
Energy Efficiency Data
Energy efficiency information in the DPP complements the existing EU Energy Labelsystem. While energy labels provide at-a-glance information, the DPP includes detailed energy data for informed decision-making and comparison.
Required Energy Information
Energy Efficiency Class
Rating from A to G based on the EU energy labeling system
Annual Energy Consumption
kWh per year based on standard usage patterns
Standby Power
Watts consumed in standby/off modes
Operational Power
Power consumption during typical use scenarios
The DPP enables consumers to make informed purchasing decisions and helps businesses and organizations track the energy efficiency of their electronics inventory.
Implementation Timeline
Electronics DPP requirements are being phased in through delegated acts for specific product categories. Here's the expected timeline for key electronics categories:
Preparation Phase
ESPR enters force, delegated acts being developed for electronics
First Electronics Delegated Acts
Expected adoption of delegated acts for smartphones, tablets
Smartphones & Tablets
DPP requirements likely to apply for mobile devices
Laptops & Computing
Expected DPP requirements for computing devices
Large & Small Appliances
Washing machines, refrigerators, TVs, and other appliances
Note: Timeline Subject to Change
Exact dates depend on the adoption of delegated acts by the European Commission. Monitor official EU sources and check our DPP timeline for updates.
Compliance Checklist
Use this checklist to prepare your electronics products for DPP compliance:
📋 Product Information
- Unique product identifiers (GTIN, serial numbers)
- Manufacturer and brand information
- Model name and variant details
- Country of manufacture
🔧 Repairability
- Repairability index calculated and documented
- Disassembly instructions prepared
- Required tools documented
- Repair manuals available
🔩 Spare Parts
- Complete spare parts catalog created
- Pricing established and documented
- Ordering process defined
- Availability period commitments made
🔋 Battery (if applicable)
- Battery specifications documented
- Replacement instructions prepared
- Recycling information included
- Battery Passport link (if required)
⚡ Energy & Environment
- Energy efficiency data prepared
- Carbon footprint calculated (if required)
- Material composition documented
- Recycling instructions included
📲 DPP Implementation
- QR code/data carrier integrated on product
- DPP platform selected and configured
- Data accuracy verified
- Update process established
Frequently Asked Questions
Which electronic products need a Digital Product Passport?
The EU ESPR will require DPPs for consumer electronics including smartphones, tablets, laptops, TVs, washing machines, refrigerators, dishwashers, and other electrical and electronic equipment (EEE). Priority categories include products with significant environmental impact and repairability potential.
What is the repairability index for electronics DPP?
The repairability index is a score (typically 0-10) that indicates how easily a product can be repaired. It considers factors like disassembly ease, spare parts availability and pricing, repair documentation access, and software support duration. France pioneered this with mandatory indices for smartphones, laptops, and TVs since 2021.
How long must spare parts be available for electronics under EU law?
Under EU ecodesign regulations, manufacturers must provide spare parts for: smartphones and tablets (5-7 years), laptops (7-10 years), washing machines and dishwashers (10 years), refrigerators (10 years), and TVs (7-8 years). Parts must be delivered within 15 working days of order.
When do electronics DPP requirements start?
Electronics DPP requirements are being phased in from 2025-2030. Smartphones and tablets are expected to require DPPs from 2027-2028, with other consumer electronics following. Specific delegated acts are being developed for each product category.
What battery information must be included in an electronics DPP?
Electronics with batteries must include: battery chemistry and composition, capacity and expected lifespan, charging cycle specifications, removability/replaceability information, safe disposal instructions, and links to the battery's own passport if applicable under the Battery Regulation.
Conclusion
The electronics industry faces comprehensive Digital Product Passport requirements that go beyond simple product identification. Repairability, spare parts availability, energy efficiency, and battery management are all critical components of electronics DPP compliance.
Starting preparation now—even before delegated acts are finalized—will give your business a competitive advantage. Companies that embrace these requirements will be better positioned for the circular economy while meeting increasing consumer demand for sustainable, repairable products.
Key Action Items
- Audit your product data: Identify gaps in repairability, spare parts, and materials information
- Develop spare parts strategy: Plan for long-term parts availability and pricing
- Create repair documentation: Prepare manuals and disassembly guides
- Select a DPP platform: Choose a solution that can scale with your products
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