which data must I fill in exactly for my type of device

What you must concretely do

What is expected of you

The ESPR operates with a framework structure: the regulation itself describes how the system works, but which data are precisely mandatory per product group is specified per sub-category in a delegated act. For electronics and ICT equipment, that specification has not yet been published. What is already established is the way in which that specification is developed and what types of data will be included in it.

The delegated act determines product-specific data

Articles 4 and 8 of the ESPR (Regulation (EU) 2024/1781) provide that the European Commission, through delegated acts, determines which information is mandatory for a specific product group. For a company with 10 to 100 employees, this means that the exact data list for, for example, a laptop, a washing machine or a smartphone cannot be derived from the ESPR itself, but from the act adopted for that sub-category. As long as that act does not exist, the only meaningful preparation work is: to know from which categories of data the act is likely to draw, and to align your own product data with them accordingly.

Articles 5 to 7 point the direction of the requirements

Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) describe the general types of ecodesign requirements: performance requirements (such as energy consumption, durability, recyclability) and information requirements (what must be disclosed about the product). These articles do not establish product-specific threshold values, but do determine the types of data that the subsequent delegated act will address. A company that now collects data on the energy consumption of a device, repairability or material composition, is thereby building a dataset that aligns with the direction already indicated by the legislator.

Article 10 describes the form, not the content per product group

Article 10 of the ESPR (Regulation (EU) 2024/1781) governs the general requirements for the digital product passport: how the passport must be accessible, what the data carrier must be capable of, and how long data must remain available. This article says nothing about which fields a specific device must contain — that remains the task of the delegated act. For practical purposes, the distinction is important: the structure of the passport (such as who may access it, and how the data is made accessible) is already established in the regulation, but the substantive data list per product category is not. More on that structure is described on the page on who may view which data from the product passport.

Article 18 determines the sequence and planning per product group

Article 18 of the ESPR (Regulation (EU) 2024/1781) regulates how the Commission prioritizes which product groups receive a delegated act first. Electronics and ICT equipment are on the work plan 2025-2030, with delegated acts expected from 2027 onwards — a date which is not yet fixed, moreover. For a company, this means above all that the planning can differ per subcategory: the act for, for example, appliances can appear at a different time than that for telecommunications equipment or computers.

Where things go wrong in practice

A few situations keep recurring at companies preparing themselves without the act already being published.

An importer bases itself on the data list of another product group (for example textiles, where more is already known) and applies it directly to electronics, without acknowledging that the requirements are set separately per subcategory.

A manufacturer collects only data that is already mandatory under existing regulation, such as RoHS, and assumes this is sufficient for the product passport. The relationship between these two frameworks is a separate point of attention, described on the page about how RoHS relates to the digital product passport.

A company waits with all preparation until the delegated act is published, and then discovers that data on repair options, software support or material origin are difficult to reconstruct retroactively because they have never been systematically recorded.

An importer of multiple product categories (for example both appliances and small ICT equipment) treats the product passport as a single uniform document, while the data requirements per subcategory can differ once the individual acts appear.

A company records data without taking into account whether that data on the repairability score or software updates will later become a mandatory passport field, and must revise the measurement method afterwards.

What you can document

• An overview per product category (for example: appliances, telecommunications equipment, computers) with the data that are already available now, such as energy consumption, material composition and warranty periods.
• A file with the origin of critical raw materials in the components used, even though it has not yet been established which substances must later be specifically reported — see the explanation about which critical raw materials must be reported in the passport.
• Internal agreements on who within the company is responsible for keeping product data up to date, so that when the delegated act is published, one does not start from scratch.
• Documentation of the measurement methods already used for performance values, so that it can later be traced whether these align with the prescribed measurement method for the passport.
• An overview of existing mandatory information (RoHS, energy label, warranty information) that can possibly be partially reused once the product-specific requirements are known.
• A list of product variants and models, with an indication of which data must be kept separately per variant — relevant once the question also arises whether the passport must be offered in multiple languages.