DPP for Electronics & Electrical Equipment
How ESPR, the Right to Repair Directive, and repairability scoring obligations are converging to make Digital Product Passports mandatory for electronics — and what data will be required.
Electronics Under ESPR
Electronics and electrical equipment (EEE) are addressed through two distinct tracks within the ESPR framework — Regulation (EU) 2024/1781.
The first track covers energy-related products that were already subject to the predecessor Ecodesign Directive (2009/125/EC). Many existing measures — for washing machines, dishwashers, refrigerators, televisions, and similar appliances — are being revised under ESPR. The ESPR Working Plan 2025–2030 (COM(2025) 187 final) includes updated delegated act targets for washing machines and washer-dryers (2026), refrigerating appliances (2028), and EV chargers (2028).
The second track is a horizontal measure for electrical and electronic equipment covering repairability and recycled content. The Working Plan targets the delegated act for this horizontal EEE measure in 2027 to 2029. This measure will establish product-specific DPP requirements and ecodesign performance thresholds for the broader electronics category — including smartphones, tablets, laptops, and professional equipment not yet covered by energy-specific rules.
Mobile Phones and Tablets
Mobile phones and tablets are listed in the ESPR Working Plan as a standalone priority product category with a delegated act target of 2030. This reflects both the scale of the market and the complexity of the preparatory study required.
Once the delegated act is adopted, companies will have approximately 18 months to comply — placing the enforcement date for smartphone and tablet DPPs at approximately 2031 or later.
This does not mean electronics manufacturers have years before DPP obligations begin. Products subject to existing energy-related ecodesign measures (washing machines, televisions, etc.) will face DPP requirements much earlier, as their delegated acts are updated under ESPR's DPP architecture.
Right to Repair Directive
Directive (EU) 2024/1799 — the Right to Repair Directive — entered into force on 30 July 2024. Member States must transpose it by 31 July 2026.
The directive establishes an entitlement framework: consumers have the right to have covered products repaired, and manufacturers have corresponding obligations. The products currently listed in Annex II of the directive include:
- Household washing machines and washer-dryers
- Dishwashers
- Refrigerating appliances
- Electronic displays (televisions and monitors)
- Welding equipment
- Vacuum cleaners
- Servers and data storage products
- Mobile phones, cordless phones, and slate tablets
- LMT batteries (for e-bikes and e-scooters)
Manufacturers of these products must:
- Repair covered products within a reasonable time and at a reasonable price
- Provide access to spare parts, tools, and repair information at non-discriminatory prices — meaning they cannot charge independent repairers more than authorised service networks
- Not use hardware or software barriers to prevent third-party repair
- Provide a European Repair Information Form (ERIF) on request within five working days
Repairability Scoring
A repairability label for smartphones and tablets became effective from 20 June 2025 under existing ecodesign measures. The label grades products A through E based on assessed repairability — access to spare parts, ease of disassembly, software support lifetime, and availability of repair documentation.
This label is the consumer-facing expression of data that must also appear in the product's DPP once ESPR DPP requirements apply to smartphones and tablets.
The repairability score is not a voluntary certification. It is derived from mandatory data disclosures that manufacturers must be able to substantiate. The underlying data — spare parts availability timelines, disassembly scores, software update commitments — feeds directly into the repairability data field required by ESPR's Annex III.
ERIF: The European Repair Information Form
The European Repair Information Form (ERIF) is a standardised document that manufacturers of Right to Repair Directive products must provide on request. It summarises:
- What can be repaired and by whom
- Estimated repair costs (based on standard labour rates and spare part prices)
- Availability of spare parts and tools
- Whether repair is technically feasible
The ERIF must be provided within five working days of a request from any person — consumer, independent repairer, or business. Failure to provide it is a violation of the directive.
The ERIF is a precursor to what will become a mandatory DPP field. As ESPR delegated acts for electronics are adopted, the information currently provided on request via ERIF will become a standing disclosure obligation in the DPP, accessible without having to make a request.
What Data Will Electronics DPPs Require?
Based on ESPR's horizontal DPP framework (Annex III of Regulation (EU) 2024/1781) and the Right to Repair Directive, electronics DPPs will require:
- Product identification: manufacturer, model, batch or serial number
- Material composition: key materials by weight, recycled content percentages
- Substances of concern: SVHCs above 0.1% w/w (per REACH Article 33)
- Carbon footprint by lifecycle phase
- Repairability data: disassembly score, spare parts availability, software update commitment end date
- Recycled content for key materials (plastics, metals)
- End-of-life instructions: how to return the product for WEEE collection, which components are recoverable
- Repair instructions and links to service documentation
Implications for Developers and System Integrators
For companies building DPP systems for electronics, the architecture must support:
- Model-level vs item-level passports: ESPR allows DPPs at model, batch, or individual item level. For electronics, item-level serialisation (linking to individual IMEI or serial numbers) will be the expected standard for high-value devices
- Dynamic data updates: repairability data — particularly spare parts availability and software support dates — changes over time. The DPP data model must support updates without breaking the unique identifier linkage
- ERIF integration: the data pipeline from manufacturer repair systems to the DPP data carrier must be reliable and auditable
- QR code durability: the QR code must remain legible for the product's entire useful life — a meaningful design constraint for consumer electronics with short physical lifespans but long tail usage patterns
Sources
- Regulation (EU) 2024/1781 (ESPR), Articles 9–13, Annex III — EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng
- ESPR Working Plan 2025–2030, COM(2025) 187 final — EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52025DC0187
- Directive (EU) 2024/1799 (Right to Repair Directive), Articles 4–8, Annex II — EUR-Lex: https://eur-lex.europa.eu/eli/dir/2024/1799/oj
- European Commission — Right to Repair implementation page: https://commission.europa.eu/business-economy-euro/consumer-protection/single-market-consumer-protection/right-repair_en