What does the ESPR change for the electronics industry?

From energy label to broad sustainability framework

The ESPR (Regulation (EU) 2024/1781) broadens ecodesign requirements for electronics and ICT equipment from energy consumption alone to the entire product lifecycle, and adds a mandatory digital product passport to this. Whereas the old ecodesign directive focused mainly on how much electricity a washing machine or laptop consumes, the ESPR regulates a much wider set of requirements: how long a product lasts, how well it can be repaired, what materials it contains, how easily parts can be replaced or recycled, and what environmental impact production has had. All this information must then be findable per product in a digital passport, which is accessible via a QR code or comparable data carrier on the product itself. For electronics importers and manufacturers of domestic appliances and ICT equipment, this means that the administration surrounding a product no longer stops at the energy label: there is a file that must remain available throughout the entire product lifecycle.

For almost all products, with exceptions

The ESPR is structured as a framework regulation and applies in principle to virtually any physical product placed on the market or put into service in the EU, as stated in Article 1 of the regulation. This is a deliberately broad approach: electronics, domestic appliances and ICT equipment fall squarely within its scope. A number of categories have been explicitly excluded from the scope, such as food, medicines, living plants and animals, and vehicles that already fall under their own type-approval framework. For the electronics industry, what is particularly important is that the ESPR itself does not set concrete requirements for a specific device. The regulation sets the framework and the authority, but the actual requirements — what information must be in the passport, what repair requirements apply, what threshold values exist — are worked out and established separately per product category. Until that elaboration exists, nothing changes for a specific product in terms of the obligations themselves.

No fixed date yet for electronics

When the requirements and mandatory passport for electronics and ICT equipment will come into force is not yet fixed at this time. This is because the ESPR works per product category: the Commission establishes an elaboration for each group of products separately, and only from the moment that elaboration is published do the concrete obligations for that category take effect. For electronics and ICT equipment, that elaboration does not yet exist. Until that time, the existing rules remain in force, such as the current energy labelling and the requirements that already applied under the old ecodesign directive, insofar as they are still applicable. As soon as an elaboration is published for a subcategory within electronics or ICT, it determines from which moment the digital product passport and the supplementary requirements actually become mandatory.

What the manufacturer can do now

If you are now importing or manufacturing electronics, household appliances or ICT equipment, you can already prepare a number of things without having to wait for the final implementation. A first step is to check whether your own assortment falls within the broad scope of Article 1 — for virtually all electrical and electronic equipment this is the case, unless a specific exemption applies. A second step is to map which product information is already available and which is still missing: material composition, origin of components, repair and maintenance data, warranty and service life information. This is precisely the type of data that will later be included in a digital product passport, and collecting it often takes more time than compiling the passport itself. A third step is to monitor the publication of the product category-specific implementation for your own product group, because this determines when the obligation actually takes effect and what exactly must be included in the passport. If you have these data in order once the implementation is published, you don't have to start from scratch with compiling the passport.

The basis: Article 1 of the ESPR

The fact that the ESPR has a broad scope of application and acts as a framework regulation follows from Article 1 of Regulation (EU) 2024/1781, which sets out the subject matter and scope of the regulation. The European Commission explains on its own page on the ecodesign regulation for sustainable products how this framework regulation replaces the old ecodesign directive and is further implemented per product group with concrete requirements.

If you want to get started now, it is advisable to begin by collecting the product information mentioned above and to keep an eye on the publication of the implementation for your own product category — as soon as it is known, the corresponding date will be listed here on this platform.

What this is based on

The regulation itself is on EUR-Lex. We provide references per statement; you do not have to take our word for it.

What you must concretely do

The ESPRR (Regulation (EU) 2024/1781) is the European framework regulation for ecodesign of products. For the electronics industry, the core is that products will in future have to comply not only with existing safety and energy requirements, but also with requirements on sustainability, repairability, recyclability and information provision — set out in a digital product passport. The regulation itself, Article 1, describes this as a framework that is filled in per product group. That "per product group" is precisely why this change still feels abstract: the framework law is in place, but the concrete requirements per device will follow. How that works is described on the page about why different rules apply for different types of equipment.

What is expected of you

Checking whether your products fall under the ESPRR

The regulation has a broad scope of application: Article 1 of the ESPRR mentions tangible products placed on the market or put into service. For a company with 10 to 100 employees, this means in practice an initial check per product line: which devices do you supply, and are they consumer devices, components, or accessories? Not every product receives the same requirements on the same timeline. An overview of what concretely falls under the rules is on the page about which products in the electronics sector fall under the ESPR. For companies that are uncertain whether their specific range is included, there is a separate test on the page does the digital product passport apply to my electrical and electronic equipment.

Waiting for the delegated act for your product group

The ESPRR works with delegated acts: separate decisions per product group in which the Commission sets out which requirements apply exactly and from when. For electronics and ICT equipment, those acts have not yet been published; the Commission's work plan provides for these from a later date. In practical terms, this means that a company cannot yet determine which data must be exactly in the passport, and when the obligation takes effect. What a delegated act entails and why it is decisive for what will have to happen in future is explained on the page what is a delegated act and why does it determine what I have to do. As soon as a date is known for electronics, it will be kept up to date on the page when the product passport becomes mandatory for electronics.

Recording and being able to supply product data structurally

Even though the exact content of the passport per product group has not yet been determined, the direction is clear: data on materials, origin, repair options and lifetime will become relevant. For a medium-sized company, this means that it is valuable to already inventory which data is already available (for example from procurement documentation or technical files) and which is still missing. An overview of what is likely to come in the passport is on the page which data will be in the passport for electronics.

Distinguishing between public and restricted data

Not all information in the passport is visible to everyone. For companies that are sensitive about sharing formulations, supplier information or technical specifications, it is relevant that the ESPRR allows for a distinction between what is publicly accessible and what is only visible to certain parties (such as supervisory authorities). This distinction is covered on the page who may view which data from the product passport, and specifically for business-sensitive information on the page or whether business-sensitive data on electronics must be public.

Taking account of composite products

Many electronic devices contain a battery, and for batteries there is already separate legislation with its own passport requirement. For manufacturers and importers of devices with integrated batteries, this is a practical point to note: it is not self-evident that one passport will suffice. This issue is explained on the page whether a device with a battery in it needs two digital product passports.

Where things go wrong in practice

A common assumption is that the ESPRR already imposes concrete obligations on electronics companies. The framework regulation is in place, but without a delegated act for the company's own product group, there are as yet no passport obligations that must be complied with. Companies that get ahead of this with expensive implementations run the risk of investing in a system that does not match the eventual requirements.

A second situation is the reverse: companies that think they still have years and therefore make no preparations, while data collection on materials and supply chains often has longer lead times than the ultimate statutory deadline.

A third recurring problem is unclear responsibility in a supply chain for submitting passport data — the manufacturer, the importer, or the party that applies the brand to the product. Without agreements on this, delays arise once the obligation takes effect.

Finally, smaller companies often overlook that the ESPR does not automatically make an exception for limited business size. Whether and how small-scale operations play a role can be read on the page whether the digital product passport also applies to small businesses.

What you can document

An overview per product line of which devices may possibly fall under the ESPR, and on the basis of which characteristics.
An inventory of which product data (materials, origin, repair information) already exist in technical files or purchasing documentation.
Internal agreements with suppliers and importers on who supplies which data once this becomes relevant.
A note of the source and publication date of the delegated act for the own product group, as soon as it appears.
An overview of which data are considered business-sensitive and why, in preparation for a possible later distinction between public and protected fields.
Documentation on any batteries in products, with a view to possible overlap between passport obligations.

This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections take priority.