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Digital Product Passport for Electronics — Requirements and Guide for Manufacturers

Digital Product Passport for electronics: What the EU ESPR means for electronics manufacturers. Repairability, spare parts availability, critical raw materials, and the timeline from 2027.

Author: myDPP Team

Digital Product Passport for Electronics — Requirements and Guide for Manufacturers

The electronics sector sits at the heart of the European circular economy strategy. Electronic devices have short use cycles, contain valuable and critical raw materials, and generate a growing mountain of e-waste. With the Digital Product Passport (DPP), the EU aims to create transparency on materials, repairability and recyclability — fundamentally changing how electronic devices are manufactured, used and disposed of.

This guide explains the regulatory requirements facing electronics manufacturers, what data the DPP will contain, when the obligation takes effect, and how companies can prepare.

For a general introduction to DPP: Digital Product Passport in 15 Minutes.

Why Electronics Is a Core DPP Topic

The EU generates over 16 million tonnes of electronic waste annually — and the trend is upward. At the same time, the electronics sector depends on critical raw materials (rare earths, cobalt, lithium, tantalum) whose extraction carries significant environmental and social risks.

  • Growing e-waste — The EU is one of the world’s largest producers of e-waste. Only around 40% is properly recycled.
  • Critical raw materials — Electronics contain dozens of strategically important materials. The EU Critical Raw Materials Act aims to reduce import dependency — recycling is essential for this.
  • Planned obsolescence — The debate around short-lived devices, non-replaceable batteries and missing software updates is driving regulatory pressure on manufacturers.
  • Right to Repair — The EU Right to Repair Directive (2024) strengthens consumer rights and demands access to spare parts and repair information. The DPP is the natural information vehicle for this.
  • Energy consumption — Electronic devices consume significant energy during use. Existing EU Energy Labels will likely be integrated into the DPP.

Regulatory Framework

ESPR as the Framework Law

The ESPR (Regulation (EU) 2024/1781) provides the overarching legal basis for the DPP. Electronics and ICT devices are planned for the second wave of delegated acts (from 2026/2027).

Existing Ecodesign Regulations

Many electronics categories already have ecodesign implementing regulations under the old directive (refrigerators, washing machines, displays, servers, smartphones). These will be gradually migrated under the ESPR and extended with DPP requirements.

EU Battery Passport

Devices with built-in rechargeable batteries are additionally subject to the Battery Regulation (2023/1542) and the battery passport. Manufacturers must ensure that the device DPP and battery passport are consistently linked.

Right to Repair

The Right to Repair Directive (2024) demands access to spare parts, repair manuals and diagnostic tools. The DPP will likely be the primary channel for this information.

WEEE and RoHS

The existing directives on electronic waste (WEEE) and hazardous substance restrictions (RoHS) already set requirements that will flow into the DPP.

What Data Will the Electronics DPP Contain?

Product Identification

  • Manufacturer, model designation, serial number
  • Unique product identifier (GS1-based)
  • Date of manufacture and manufacturing location
  • Product category and energy efficiency class

Material Composition

  • Complete material list with weight proportions
  • Presence of critical raw materials (rare earths, cobalt, lithium, tantalum)
  • Share of recycled materials
  • Information on substances of concern (RoHS-relevant substances, SVHC per REACH)

Repairability and Durability

  • Repairability index (following the French model, EU-wide planned)
  • Expected product lifespan
  • List of available spare parts and their availability period (at least 7–10 years)
  • Repair instructions and disassembly information
  • Information on software support (duration of update provision)
  • Battery replaceability (if applicable)

Energy Consumption

  • Energy efficiency class (EU Energy Label)
  • Annual energy consumption under standard conditions
  • Standby consumption
  • Power consumption during operation

Recyclability and End-of-Life

  • Disassembly instructions for recycling
  • Material separability
  • Disposal instructions per WEEE
  • Take-back and recycling options

Compliance

  • CE compliance
  • RoHS compliance
  • REACH compliance
  • Battery passport reference (if battery included)
  • EPEAT, TCO or other eco-labels

Timeline — When Will the Electronics DPP Arrive?

Electronics and ICT devices are planned for the second wave of ESPR delegated acts:

  • 2026–2027 — Development of delegated acts for electronics categories. Smartphones, tablets and laptops are expected to be among the first.
  • 2027–2028 — Expected publication of delegated acts.
  • 2029–2030 — Entry into force of the DPP obligation for the first electronics categories.

For devices with batteries, the Battery Regulation deadlines also apply: the battery passport becomes mandatory from February 2027 for certain battery categories. Manufacturers of devices with built-in batteries must factor this deadline in now.

Sector-Specific Considerations

Rapid Innovation Cycles

Electronics products have lifecycles of 1–3 years. Model changes and new product lines require a highly automated DPP creation process integrated into the product development workflow.

Global Supply Chains

Component manufacturing is distributed worldwide. A smartphone contains components from dozens of suppliers in numerous countries. Obtaining DPP-relevant data from the entire supply chain is the biggest challenge.

Embedded Software

Modern electronics are inseparable from software. The DPP will likely also contain information on software support (update period, security patches). This is new compared to traditional product data sheets.

Integration with Existing Energy Label

The EU Energy Label already exists for many electronics categories. The DPP will not replace it but extend it with additional dimensions (repairability, materials, recycling). Integrating both systems requires careful planning.

Preparation — 5 Steps for Electronics Manufacturers

1. Data inventory per product line

Systematically capture which DPP-relevant data is already available in your systems (PLM, ERP, quality management). Typical gaps: detailed material composition at component level, repairability metrics, carbon footprint.

2. Request supplier data

Define what data you need from component suppliers (material composition, origin of critical raw materials, RoHS/REACH compliance). Start with key suppliers and integrate data requirements into supplier contracts.

3. Assess and document repairability

Analyse the repairability of your products: which parts are replaceable? What tools are needed? How long are spare parts available? This data will be a central DPP component and influences product design.

4. Plan IT infrastructure

Evaluate how the DPP integrates into your product development and manufacturing processes. DPP platforms like myDPP offer interfaces to common PLM and ERP systems.

5. Pilot with 2–3 products

Create complete pilot DPPs for representative products. Identify data gaps, process bottlenecks and automation requirements.

Frequently Asked Questions

Does the DPP replace the existing EU Energy Label?

No. The EU Energy Label remains as a separate, visible labelling system. The DPP supplements it with additional dimensions (materials, repairability, recycling). Energy label data will likely also be included in the DPP to create a central digital information source.

Do B2B electronics (industrial electronics, controllers) also need a DPP?

This depends on the delegated acts. The initial focus categories are consumer electronics. Industrial electronics may follow in later waves, particularly where they fall under the Machinery Regulation.

How does the DPP relate to the battery passport for devices with batteries?

Devices with built-in batteries will likely have two linked digital passports: a device DPP and a battery passport. The technical linkage (e.g. via unique identifiers) is an open question that the delegated acts will clarify.

Further Reading

Sources

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