What is changing in the ESPR this year
The ecodesign regulation (ESPR) is a framework regulation: the regulation itself sets out the rules of the game, but the specific requirements per product group are established separately through so-called delegated acts. For electronics and ICT, what is particularly relevant this year is which product groups are on the agenda in the 2025-2030 work plan and which phase their preparation is in, such as a consultation, a draft proposal or a first publication. There is therefore no separate annual amendment of 'the ESPR' that applies to all electronics at the same time; what changes depends on the product group in which your company operates.
For anyone importing, producing or purchasing electronics or ICT equipment, this means that 'this year' is in practice primarily a moment of preparation: following which step the European Commission takes for your product group, and checking which data will be needed once the requirements become concrete. For anyone wishing to monitor this per product group, an overview can be found in the knowledge base with the ecodesign regulation explained per subject.
How the work plan is developed
The European Commission periodically adopts a work plan setting out which product groups are prioritised. For electronics and ICT, the current work plan covers the period 2025-2030. Within that work plan, each product group goes through its own process: first a preparatory study, then consultation of stakeholders, followed by a draft proposal and eventually the adoption of the delegated act itself. That final step, the actual publication with concrete requirements, is expected at the earliest from 2027 for most sub-categories. This is an expectation based on the work plan, not a firm date.
Because this process runs separately for each product group, one category within electronics may be further advanced than another. Displays, servers or data storage, for example, may be at a different stage than mobile equipment or household appliances. Anyone wishing to know what stage their own product group is in can best do so by reference to the official texts; here you can read where the information on elektropas.com comes from and how we link it to the source.
What this means for electronics and ICT
As long as the delegated act for your product group has not yet been published, there are as yet no concrete obligations for the digital product passport itself. What may already be relevant are the broader rules from other regulations that already apply now, such as rules on product safety. The ESPR and the digital product passport will layer on top of those, but do not replace those earlier obligations.
For companies importing or placing electronics on the market, this year is therefore primarily a time to determine what role your company plays in the chain, what data you are already recording about your products, and whether that data will be usable for the passport later. There is no rush, but it is the time when preparation yields the most benefit, because the requirements are not yet finally set and there is therefore still room to gradually establish processes.
What is not yet settled
It is not yet firmly established when the delegated act for your specific product group will be published, what precise data will be requested in it, and what transition periods will apply. Reports of a 'definitive date' for electronics in general are not currently based on a published text. Once a delegated act for a sub-category is published, that information with its source will appear in the official text.
If you are unsure whether a particular development already applies to your products, you can enquire with your own competent authority or consult a legal advisor. Elektropas.com describes the current state of affairs, but makes no statement about the situation of an individual company.
What you can already do
Even without a fixed date, it is worthwhile to map out now which products your company places on the market, who acts as a supplier in the chain and which technical data are already available from the manufacturer or supplier. You won't need to repeat this work once the requirements become concrete; it will save time then. With a few short questions you will get in five questions a first indication of where your company stands, and frequently asked questions about the ESPR and the digital product passport are clearly collected together on the page with answers to the most frequently asked questions about the product passport.
Do you want to review this topic carefully without having to take action immediately? Take the free quick-scan or read through the other topics in the knowledge base; both take half an hour and immediately give you a picture of what is relevant for your company.