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 horizontal requirements. The Working Plan lists two horizontal measures: repairability (including scoring), with indicative adoption in 2027, and recycled content and recyclability of electrical and electronic equipment, with indicative adoption in 2029. ICT products are covered through the work on these two measures, and some specific ICT products through the revision of energy-related product rules (COM(2025) 187). A delegated act with horizontal requirements does not have to include DPP requirements (ESPR, Art. 7(2)).

Mobile Phones and Tablets

Mobile phones and tablets are among the 16 energy-related products carried over into the ESPR Working Plan, with indicative adoption of ecodesign and energy labelling requirements by end 2030.

ESPR requirements normally apply no earlier than 18 months after the delegated act enters into force (Art. 4(4)) (Regulation (EU) 2024/1781), so on this indicative timeline any DPP requirement for smartphones and tablets would apply in 2032 or later.

This does not mean electronics manufacturers have years before DPP obligations begin. Other energy-related products are scheduled for revision under the ESPR sooner, such as household washing machines and dishwashers (indicative adoption 2026) and displays (2027), so they may face DPP requirements earlier.

Right to Repair Directive

Directive (EU) 2024/1799, the Right to Repair Directive, entered into force on 30 July 2024. Member States had to transpose it by 31 July 2026 and apply their national rules from that date (Art. 22).

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 are:

• Household washing machines and household washer-dryers
• Household dishwashers
• Refrigerating appliances
• Electronic displays, such as televisions and monitors
• Welding equipment
• Vacuum cleaners
• Servers and data storage products
• Mobile phones, cordless phones and slate tablets
• Household tumble dryers
• Goods incorporating light means of transport (LMT) batteries, such as e-bikes and e-scooters
• Domestic local space heaters, added by Delegated Directive (EU) 2026/74, which Member States apply from 31 July 2026

The obligation to repair covers these products to the extent that the EU acts listed in Annex II set repairability requirements for them (Art. 5(1)) (consolidated text, EUR-Lex).

Manufacturers of these products must:

• Repair covered products within a reasonable time and at a reasonable price
• Offer spare parts and tools at a reasonable price that does not deter repair, where they make them available (Art. 5(4)), and publish indicative prices for typical repairs on a free access website (Art. 5(5))
• Not use contractual clauses, hardware or software techniques that impede repair, unless justified by legitimate and objective factors such as protecting intellectual property (Art. 5(6))

Repairability Scoring

A repairability class for smartphones and tablets has been shown on their EU energy label since 20 June 2025 (Delegated Regulation (EU) 2023/1669). 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.

Whether the same data must also appear in a DPP will depend on the future ESPR delegated act for 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. ESPR Annex III does not itself require a repairability field. Each delegated act selects the DPP data from the elements listed there, which can include information on a product's repairability score (Art. 7(2)(b)(i), Art. 9(2)(a) and Annex III).

ERIF: The European Repair Information Form

The European Repair Information Form (ERIF) is a standard form that repairers may provide to a consumer before the consumer is bound by a repair contract. Providing it is optional. A repairer that provides it must do so free of charge (a diagnostic fee may be charged where needed), on a durable medium and within a reasonable time after the request (Art. 4(1) to (3)). It sets out:

• The repairer's identity and contact details
• The good to be repaired, the nature of the defect and the type of repair suggested
• The price, or how it will be calculated and the maximum price
• The time needed to complete the repair
• The availability and cost of temporary replacement goods and of any ancillary services
• Where the consumer hands over the good, and how long the form is valid

The repairer may not change the conditions in the form for 30 calendar days from when it is provided, and the repairer and consumer can agree a longer validity period. If the consumer accepts the conditions within the validity period, the repairer must carry out the repair on those terms (Art. 4(5)) (consolidated text, EUR-Lex).

The ERIF is an offer for a specific repair, not product data. Neither the Right to Repair Directive nor the ESPR makes it part of the DPP. Any repair information in an electronics DPP will depend on what the relevant ESPR delegated act requires.

What Data Will Electronics DPPs Require?

The data an electronics DPP must contain will be set by the relevant ESPR delegated act, which selects them from the elements listed in Annex III (Art. 9(2)(a)). Based on those elements and the information requirements in Article 7, an electronics DPP could include:

• Product identification: manufacturer, model, batch or serial number
• Material composition: key materials by weight, recycled content percentages
• Substances of concern: their names, location and concentration in the product (Art. 7(5)), with any threshold set in the delegated act
• 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
• Repair data integration: where a delegated act requires repair information in the DPP, the data pipeline from manufacturer repair systems to the DPP must be reliable and auditable
• QR code durability: the DPP must remain available for at least the product's expected lifetime (Art. 9(2)(i)), so the QR code should remain legible for that long, 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
• Directive (EU) 2024/1799, consolidated text of 31 July 2026 including Delegated Directive (EU) 2026/74, EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02024L1799-20260731
• Commission Delegated Regulation (EU) 2023/1669 (energy labelling of smartphones and slate tablets), EUR-Lex: https://eur-lex.europa.eu/eli/reg_del/2023/1669/oj/eng
• European Commission — Right to Repair implementation page: https://commission.europa.eu/business-economy-euro/consumer-protection/single-market-consumer-protection/right-repair_en