Whether a product falls under the heading 'electronics and ict' depends on the product group that the European Commission designates separately for it. There is no single list of devices that establishes all at once what counts and what does not; the ecodesign regulation (ESPR) works by subcategory, and each subcategory receives a delegated act with precise delimitation at its own time.
In practice, this means that smartphones, tablets, laptops and servers are typically mentioned under 'electronics and ict', while large household appliances such as washing machines and refrigerators often appear as a separate product group in the work plan. For your own product, that distinction can only be made with certainty once the delegated act for that specific group has been published.
Why the delimitation is not yet fixed everywhere
The ESPR is a framework regulation. It describes how the system works — who is responsible, what a digital product passport must contain, how enforcement is arranged — but only fills in later, by product group, which products precisely fall under that group. This happens via delegated acts, and according to the work plan 2025-2030, those for electronics and ict equipment are expected from 2027 onwards. As long as such an act does not exist, the exact boundary — for example between a tablet and an e-reader, or between a server and a network switch — remains a matter of interpretation.
This differs from what many entrepreneurs expect from EU rules: no fixed list in advance, but a phased rollout. Anyone who wants to know now whether an article in their assortment will fall under the digital product passport can see the direction, but not yet the exact boundary.
What the work plan already shows
The Commission's work plan indicates which product groups receive priority. For electronics and ict, these are often consumer electronics (phones, screens, peripherals) and ict infrastructure (servers, data storage, network equipment). These are categories, not product lists: a manufacturer of a specific device must therefore always refer back to the final delegated act to see whether its product falls precisely under it, including any exceptions.
Entrepreneurs who import both electronics and household appliances thus face a practical issue: their assortment may later fall under two different timelines, each with its own delegated act and its own moment of obligation. That is not an exception to the rule, but precisely how the ESPR is designed: by subcategory, with its own pace.
What this means for your own assortment
For most businesses, the question is not 'does electronics fall under the regulation', but 'does this specific model, with this specific use, fall under this specific product group'. That distinction is relevant because obligations, deadlines and required data may differ by product group once the delegated acts are in place. A general statement about 'electronics and ict' as a whole therefore says little about an individual product.
Anyone who wants to get an initial picture now of where a product is likely to be classified can have that worked out in a few questions. That is not a legal opinion, but an indication based on information currently available to the public.
Looking ahead without jumping ahead
Because the definitive demarcation per product group has yet to appear, it is advisable to use periods between delegated acts to put your own product administration in order: which models you carry, with which technical specifications, and via which supplier the data comes in. That work is never wasted, regardless of the exact product group an article ultimately falls under. More on how such a passport is compiled in practice can be read in the knowledge base with explanations for each situation.
For those who want to know how the information on elektropas.com is produced and which sources are used, there is a separate page that explains that step by step. For your own situation, and for the question of whether a specific product falls under a certain product group, the official text on EUR-Lex or the competent supervisory authority remains the starting point; a lawyer can translate that to your concrete assortment.
Would you like an indication for your own products? Do the free quick-scan or read the other topics in the frequently asked questions about the digital product passport.