ESPR by product group

ESPR and Digital Product Passports for Electronics

Last updated · 2026-06-08Covered by horizontal measures and existing ecodesign rules; ESPR specifics still developing

Electronics sit at the intersection of several ESPR measures. Horizontal rules on repairability and recycled content target electrical and electronic equipment, and existing ecodesign and energy-label rules already cover products like smartphones and tablets. Together these point toward Digital Product Passports for electronics, though the precise scope and timing are still being worked out.

TL;DR

  • Electronics are targeted by ESPR horizontal measures on repairability and recycled content for electrical and electronic equipment.
  • Existing ecodesign and energy-label rules already cover products like smartphones and tablets - do not conflate these with new ESPR delegated acts still in preparation.
  • A repairability score framework (A-E) is among the horizontal measures expected.
  • CIRPASS-2 runs DPP pilots in electronics, indicating the direction of travel.
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Status and timing

Where electronics stands today

Delegated act: Covered by horizontal measures and existing ecodesign rules; ESPR specifics still developing

Digital Product Passport: DPP timing being developed; electronics is an active CIRPASS-2 pilot area (provisional)

  • Electrical and electronic equipment is targeted by ESPR horizontal measures on repairability and recycled content.
  • Some products, such as smartphones and tablets, are already covered by pre-existing ecodesign and energy-label rules in force since mid-2025.
  • New ESPR delegated acts for electronics are still in preparation, so treat their scope and timing as expected, not settled.

Be careful not to conflate the existing smartphone and tablet ecodesign rules with the new ESPR delegated acts still being prepared - they are different measures.

Priorities and indicative timing come from the first ESPR Working Plan (2025-2030), under the framework of Regulation (EU) 2024/1781.

The data you will need

What a DPP for electronics will likely carry

  • Material composition, including critical raw materials.
  • Recycled content and recyclability of the product.
  • Reparability information, including spare-part availability and a likely A-E repairability score.
  • Substances of concern present in the product.
  • Energy efficiency and end-of-life guidance, plus the identifiers behind the data carrier.

The exact fields are set per product group in its delegated act, so treat this list as the expected shape of the data, not the final requirement. See the DPP data requirements guide for the full picture.

What to do now

What to do for electronics

  1. Confirm which of your electronics are already covered by existing ecodesign and energy-label rules.
  2. Document repairability, spare-part availability and recycled content, since these are horizontal ESPR priorities.
  3. Watch the horizontal repairability-score framework and recycled-content measures as they develop.
  4. Follow the CIRPASS-2 electronics DPP pilots for a preview of likely DPP data and structure.
  5. Use the DPP Readiness Checklist to organise the data you will eventually publish.

FAQ

Electronics and ESPR: common questions

Does ESPR apply to electronics now?
Partly. Some electronics, such as smartphones and tablets, are already covered by pre-existing ecodesign and energy-label rules. New ESPR horizontal measures on repairability and recycled content target electrical and electronic equipment, but the new delegated acts are still in preparation.
When will electronics need a Digital Product Passport?
There is no firm date for an ESPR electronics DPP yet. Electronics is an active pilot area in the EU-funded CIRPASS-2 project, which signals the direction of travel, but treat any timing as expected rather than settled.
What is the repairability score?
It is an expected horizontal ESPR measure: an A-E rating based on factors like spare-part availability, documentation, ease of disassembly and software-update duration. It is part of the horizontal repairability framework rather than a single product delegated act.
Are smartphones covered by ESPR?
Smartphones and tablets are already covered by pre-existing ecodesign and energy-label rules in force since mid-2025, which include reparability and durability elements. These are separate from the new ESPR delegated acts still being prepared, so do not conflate the two.
What should electronics makers do now?
Document repairability, spare-part availability, recycled content and substances of concern, since these are horizontal ESPR priorities and likely DPP fields. Following the CIRPASS-2 electronics pilots is a useful preview of what a DPP will look like.

Related

Get ready for ESPR and the DPP

Work through the DPP Readiness Checklist, then explore the tools and guides built for your product group.

Get the DPP Readiness Checklist

This is guidance, not legal advice

This is guidance to help you understand how ESPR is expected to apply to electronics, not legal advice. ESPR is a framework law and most product rules arrive via delegated acts that are not yet adopted, so confirm with the official sources we link or a qualified adviser before acting.

Sources

  1. [1]Regulation (EU) 2024/1781 (ESPR), full text (EUR-Lex)retrieved 8 Jun 2026
  2. [2]European Commission: 2025-2030 ESPR Working Planretrieved 8 Jun 2026
  3. [3]Regulation (EU) 2023/1542 (EU Battery Regulation), full text (EUR-Lex)retrieved 8 Jun 2026
  4. [4]CIRPASS-2: EU Digital Product Passport pilotsretrieved 8 Jun 2026
  5. [5]JRC: Digital Product Passport data-requirements methodology (JRC145830)retrieved 8 Jun 2026

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