According to which method must I measure the values for the passport?

What you must concretely do

What is expected of you

The values that will appear in a product passport — energy consumption, weight, share of recycled material, component lifespan — must come from somewhere. Article 39 of the ESPR (Regulation (EU) 2024/1781) stipulates that these values are determined according to established test, measurement and calculation methods. Not every manufacturer measures in their own way; for each product group a method will be established that prescribes how a value is derived.

Follow the method once it is available

For each product group falling under the ESPR, a delegated act will be issued containing the requirements from Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) — the ecodesign, performance and information requirements — and the corresponding measurement method from Article 39. For a company with 10 to 100 employees, this primarily means: waiting for the product-group-specific act and then applying it, not choosing or developing a measurement method on your own. As long as the act for a sub-category of electronics or ICT equipment has not yet been published, the method remains undefined.

Testing under standardised conditions

Where the method refers to a harmonised standard or a test protocol, in practice this means that a measurement is repeated under fixed conditions — fixed temperature, fixed load, fixed test duration — so that the result is comparable with that of a competitor. A company that is already having test reports prepared by a laboratory or testing facility is probably already doing so according to an existing standard; that test setup can form the basis once the ESPR method for its own product group becomes known.

Traceability of the measured value

A value in the passport does not stand alone: it must be possible to demonstrate how that value was obtained. This directly relates to which data will appear in the product passport for electronics? — the value that will eventually be there is the same value that was measured or calculated according to the prescribed method. For a company of this size, this means that the link between the test report and the passport text must remain intact, even if the passport is compiled by someone other than the person who commissioned the test.

Supporting calculated values

Not every value is measured in a lab; some are calculated, for example on the basis of material composition or data from suppliers. The calculation method for these must also follow from the delegated act, not from your own assessment. This is particularly relevant for reporting which critical raw materials must I report in the passport?, where the share of a raw material is often derived from a supplier's statement in the supply chain, and that statement in turn must have been determined according to a method.

Where things go wrong in practice

A number of situations come up relatively often when companies are preparing for measurement obligations:

• Outdated test reports are adopted without review. A test report from three years ago, prepared for a different purpose (for example an energy label), is automatically used as the basis for the passport, without checking whether the test conditions match what the ESPR method will require.
• Suppliers provide a figure without a method. A supplier in Asia provides a percentage of recycled material, but not how that percentage was determined. That figure then ends up in the passport without anything being known about its traceability.
• Different test facilities, different results. Two test reports for the same device — one from an internal lab, one from an external testing facility — give a slightly different value for energy consumption. No one has documented which method is authoritative and why.
• Calculated values are confused with measured values. A weight of critical raw materials is estimated on the basis of a technical drawing, when the intention is that this should be derived from a substantiated calculation or measurement.
• The method changes, the passport does not. A delegated act is updated or tightened, but the value in an already published product passport is not revised — whereas how often must I update the data in the product passport? becomes relevant only once the underlying measurement method changes.

What you can document

For companies that want to prepare now for the measurement obligation, it is practical to record or collect the following:

• Test reports per product group, together with the standard or test protocol used, the test conditions and the date of execution.
• Name and details of the test house or laboratory that carried out the measurement, including any accreditation.
• An overview of which values were measured and which were calculated, with the formula or assumption used for each calculated value.
• Correspondence with suppliers about supplied values, so that it remains traceable where a figure — for example for how do I record the energy consumption of an appliance? — comes from.
• A version history per product group, so that when a delegated act is amended, it is clear which values need to be remeasured or recalculated.
• A fixed contact point or process for correcting an incorrect value, in case a measured or calculated value later proves to be incorrect — see also I have discovered an error in the product passport, what now.

As long as the delegated act with the measurement method for a specific subcategory of electronic or ICT equipment has not yet been published, this is primarily a matter of organization: recording existing test data and supplier information in such a way that they can later easily be checked against the method that will then apply.