Electronics Digital Product Passport: where EU law stands

Information and communication technology products and other electronics are a priority under the EU Ecodesign for Sustainable Products Regulation (ESPR). What is decided, what is not, and what already applies.

No ESPR delegated act for electronics has been adopted as of 26 September 2026.

Where the law stands

A priority under ESPR

Regulation (EU) 2024/1781 lists information and communication technology products and other electronics among the product groups the Commission had to prioritise in its first working plan (Article 18(5)(k)).

Working plan 2025 to 2030

The Commission's working plan (COM(2025) 187) covers ICT products through two horizontal measures: repairability, including scoring, with 2027 as the indicative adoption year, and recycled content and recyclability of electrical and electronic equipment, with 2029. Some ICT products are covered through the work on energy-related products.

Already in force for phones and tablets

Regulation (EU) 2023/1670 sets ecodesign requirements for smartphones, mobile phones other than smartphones, cordless phones and slate tablets, and Delegated Regulation (EU) 2023/1669 sets energy labelling for smartphones and slate tablets. Both apply from 20 June 2025. They were adopted before ESPR and do not create a digital product passport.

No passport date yet

As of 26 September 2026 the Commission has not adopted an ESPR delegated act for electronics, so no passport content or application date is set. Once an ESPR delegated act is adopted, Article 4(4) says it applies no earlier than 18 months after it enters into force, except in duly justified cases.

Electronics passport: common questions

No. As of 26 September 2026 no delegated act under Regulation (EU) 2024/1781 (ESPR) sets a digital product passport for electronics. ICT products and other electronics are a priority product group under ESPR Article 18(5)(k).

Regulation (EU) 2023/1670 sets ecodesign requirements for smartphones, mobile phones other than smartphones, cordless phones and slate tablets, and Delegated Regulation (EU) 2023/1669 sets energy labelling for smartphones and slate tablets. Both apply from 20 June 2025.

The working plan for 2025 to 2030 (COM(2025) 187) covers ICT products through two horizontal measures: repairability, including scoring (indicative adoption 2027), and recycled content and recyclability of electrical and electronic equipment (indicative adoption 2029). These are indicative adoption years, not compliance dates.

Further reading

Regulatory Guide

ESPR 2024/1781 — Complete Guide

The horizontal ESPR framework: scope, the working plan and how product-specific delegated acts set passport requirements.

Regulatory Guide

REACH SVHC & Chemicals in DPPs

How REACH hazardous-substance obligations map onto DPP composition fields — critical raw materials, RoHS data, and SCIP records for electronics.

Regulatory Guide

EU Central DPP Registry

How the EU Commission's central registry works and what data it holds.

Other industries: Battery Passport  ·  Textile DPP  ·  GPSR Compliance

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