Electronics Delegated Act Tracker: ESPR Electronics DPP Status and Timeline

Q: When will the electronics DPP become mandatory?

The electronics delegated act is expected to be adopted in 2025–2026 for smartphones and tablets, with the DPP becoming mandatory approximately 18–24 months after adoption — likely 2027. Laptops and televisions are expected to follow in 2027–2028.

Q: Does the existing EU Ecodesign Regulation for smartphones already require a DPP?

EU Regulation 2023/1669 (the Ecodesign Regulation for smartphones and tablets) sets repairability and software update requirements but does not yet require a full DPP. The electronics ESPR delegated act will extend these requirements to include a full DPP with all Annex III data fields.

Q: What is the minimum repairability score for smartphones under ESPR?

The minimum repairability score for smartphones under EU 2023/1669 is 6.5 out of 10 from 20 June 2025. Under the ESPR electronics delegated act, this threshold may be raised. Products below the minimum score cannot be placed on the EU market.

Q: Will the electronics DPP require disclosure of conflict minerals?

The EU Conflict Minerals Regulation (EU 2017/821) already requires due diligence for tin, tantalum, tungsten, and gold from conflict-affected areas. The electronics DPP is expected to reference this regulation and require disclosure of responsible sourcing certifications for these minerals.

Q: How does the electronics DPP interact with the Battery Passport?

Electronics containing batteries above the Battery Regulation thresholds will need both an electronics DPP and a Battery Passport. The two DPPs may be linked — the electronics DPP may reference the Battery Passport identifier — but they are separate legal requirements under separate regulations.

EXPECTED 2025–2027

Electronics — including smartphones, laptops, tablets, televisions, and other consumer electronics — are a priority product category in the EU Commission's ESPR Working Plan. The electronics delegated act will establish Digital Product Passport requirements for electronics placed on the EU market. This page tracks the current status, expected timeline, and what electronics manufacturers need to know now.

Truth Anchor: ESPR Article 5(1) and the Commission Working Plan 2022–2024 identify electronics as a priority product group for delegated acts. The preparatory study for electronics ecodesign requirements was published in 2023. — EUR-Lex CELEX:32024R1781

Electronics Delegated Act: Current Status

Milestone	Expected Date	Status
ESPR Working Plan identifies electronics as priority	2022	Complete
Preparatory study for smartphones and tablets	2023	Complete
Ecodesign Regulation for smartphones/tablets (draft)	2024–2025	In Progress
Delegated act for smartphones/tablets adopted	2025–2026	Expected
Smartphones/tablets DPP mandatory	2027	Expected
Laptops and computers delegated act	2026–2027	Expected
Televisions and displays delegated act	2026–2027	Expected

What the Electronics DPP Is Expected to Contain

The electronics DPP is expected to build on the existing Ecodesign Regulation for smartphones and tablets (EU 2023/1669) and extend it with full DPP requirements. Based on the preparatory study and ESPR Annex III, the Electronics DPP is expected to contain: product identification (IMEI, serial number, model), battery capacity and replaceability rating, repairability score (1–10 scale), spare parts availability and pricing, software update support period, carbon footprint per device, recycled content of key materials (cobalt, lithium, gold, silver, palladium), hazardous substances, and end-of-life instructions.

Data Category	Expected Fields	Basis
Product identification	IMEI/serial number, model, SKU	ESPR Annex III
Repairability	Repairability score (1–10), battery replaceability rating	EU 2023/1669
Software support	Minimum software update period, security update period	EU 2023/1669
Carbon footprint	CO2e per device (lifecycle)	ESPR Annex III
Recycled content	% recycled cobalt, lithium, gold, silver, palladium	ESPR Annex III
Hazardous substances	REACH substances of concern	ESPR Annex III
Spare parts	Availability period, pricing, supplier information	EU 2023/1669
End-of-life	Disassembly instructions, recyclability rating	ESPR Annex III

Impact on Asian Electronics Manufacturers

China, South Korea, Vietnam, and Taiwan collectively manufacture the majority of electronics sold in the EU market. The electronics delegated act will require these manufacturers to collect and disclose supply chain data — including carbon footprint, recycled content, and hazardous substance use — that many currently do not track at the required level of granularity. The repairability score requirement will also require manufacturers to redesign products to achieve minimum scores, as products below the minimum repairability threshold will not be permitted on the EU market.

Electronics Delegated Act: Current Status and Priority Products

The ESPR electronics delegated act is being developed in parallel with the existing Ecodesign regulations for smartphones (EU 2023/1669) and laptops (EU 2023/2533), which already include DPP requirements. The ESPR delegated act will extend DPP requirements to additional electronics categories not currently covered by specific Ecodesign regulations. The EU Commission's ESPR work programme identifies the following electronics categories as priorities for the first electronics delegated act: desktop computers and workstations, gaming consoles, audio and video equipment, and professional displays. A second electronics delegated act is expected to cover industrial electronics, professional audio-visual equipment, and telecommunications infrastructure equipment.

Smartphones and Tablets: DPP Requirements Already in Force

The Ecodesign Regulation for smartphones and tablets (EU 2023/1669) entered into force in June 2023 and includes DPP requirements that will apply from June 2025. The DPP for smartphones must include: the product identifier (IMEI number or equivalent), the manufacturer's name and contact details, the battery capacity in mAh, the battery replaceability assessment, the minimum software support period, the repairability score (calculated using the methodology in Annex II of the regulation), the availability of spare parts and repair tools, and the end-of-life disassembly instructions. The regulation also requires that the DPP data be accessible via a QR code on the product packaging. Manufacturers of smartphones and tablets that have not yet implemented their DPP system should treat the June 2025 deadline as urgent.

Right to Repair Directive and Electronics DPP Interaction

The EU Right to Repair Directive (EU 2024/1799) entered into force in July 2024 and applies to washing machines, washer-dryers, dishwashers, refrigerators, televisions and displays, welding equipment, vacuum cleaners, smartphones, tablets, and cordless phones. The directive requires manufacturers to make spare parts, repair tools, and repair information available to independent repairers at reasonable prices for a minimum period after the product is placed on the market. The ESPR electronics DPP will serve as the technical vehicle for delivering this repair information — the DPP will contain links to repair manuals, spare parts catalogues, and disassembly instructions. Manufacturers that have already implemented the Right to Repair Directive requirements will have a significant head start on ESPR DPP compliance for the repair information data fields.

Electronics Delegated Act: Expected Scope and Timeline

The ESPR electronics delegated act is expected to cover electronic products not already covered by existing Ecodesign regulations — specifically, products such as desktop computers, servers, network equipment, audio-visual equipment, and consumer electronics not covered by the existing smartphone, laptop, and television regulations. The preparatory study for the electronics delegated act is currently underway, with publication expected in 2026. The delegated act is expected to require DPP compliance within 2 years of publication, giving manufacturers until approximately 2028 to implement DPP systems for their electronics products. The electronics delegated act will build on the framework established by the existing Ecodesign regulations for smartphones and laptops, including the repairability score methodology and the spare parts availability requirements.

What Electronics Manufacturers Should Do Now

Electronics manufacturers whose products are not yet covered by an existing Ecodesign regulation should use the time before the electronics delegated act is published to prepare their DPP infrastructure. Key preparation steps include: obtaining a GS1 Company Prefix and generating GTINs for all products, selecting a DPP platform or designing a self-hosted DPP system, implementing supply chain data collection systems, and conducting a repairability assessment of their product portfolio to identify design improvements that will improve their repairability score. Manufacturers should also monitor the EU Commission's preparatory study for the electronics delegated act and participate in stakeholder consultations to ensure their sector's specific concerns are addressed in the delegated act.

Frequently Asked Questions: Electronics Delegated Act and ESPR

When will the electronics DPP become mandatory?

Does the existing EU Ecodesign Regulation for smartphones already require a DPP?

What is the minimum repairability score for smartphones under ESPR?

Will the electronics DPP require disclosure of conflict minerals?

How does the electronics DPP interact with the Battery Passport?

Register Your Digital Product Passport

The EU DPP Registry goes live on 19 July 2026. Register now at Africa's first ESPR-compliant DPP registry.

ESPR Electronics Delegated Act: Scope and Timeline

The ESPR delegated act for electronics is one of the most complex and commercially significant under the ESPR Working Plan. Electronics is a broad category that encompasses smartphones, laptops, tablets, televisions, audio equipment, gaming consoles, wearables, and a wide range of other consumer and professional electronic devices. The Commission is expected to develop separate delegated acts for different electronics subcategories, rather than a single delegated act covering all electronics.

The preparatory studies for the electronics delegated acts are being conducted in parallel with the preparatory studies for other product categories. The Commission has published preparatory studies for smartphones and tablets (2021), laptops and computers (2021), and televisions (2021). These studies form the basis for the delegated acts that are expected to be adopted in 2025–2026. Electronics manufacturers should monitor the Commission's ESPR webpage for updates on the status of these delegated acts.

Key Requirements Expected in the Electronics Delegated Acts

Requirement	Smartphones	Laptops	TVs
Repairability score	Required	Required	Required
Spare parts availability	5+ years	5+ years	7+ years
Software updates	5 years security	5 years security	5 years
Battery replaceability	Required	Required	N/A
Recycled content	Disclosure required	Disclosure required	Disclosure required
DPP QR code	On device/packaging	On device/packaging	On device/packaging

Frequently Asked Questions

The ESPR delegated acts for smartphones, laptops, and televisions are expected to be adopted in 2025–2026, with compliance dates approximately 18–24 months after adoption. Electronics manufacturers should plan for compliance by 2027–2028. The exact timeline will be confirmed when the delegated acts are published in the Official Journal.

Gaming consoles are not currently listed as a priority product category in the ESPR Working Plan. However, they may be covered by a future delegated act or by the delegated act for computers and computer servers. Manufacturers of gaming consoles should monitor the ESPR Working Plan for updates on the scope of the electronics delegated acts.

The ESPR DPP for electronics will provide recyclers with detailed information on the materials and substances in each device, enabling more efficient and effective recycling. The DPP will also include disassembly instructions, which will help recyclers process devices more quickly and recover more valuable materials. This is expected to significantly improve the recycling rates for electronics in the EU.

The electronics delegated acts are expected to require disclosure of conflict mineral content (cobalt, tin, tungsten, tantalum, gold) in the DPP, consistent with the EU Conflict Minerals Regulation. Manufacturers who already comply with the Conflict Minerals Regulation will find that the ESPR requirements are broadly aligned, but the ESPR requirements extend to a wider range of materials and supply chain risks.

The WEEE Directive sets requirements for the collection, treatment, and recycling of waste electrical and electronic equipment. ESPR complements the WEEE Directive by requiring manufacturers to design electronics for easier disassembly and recycling, and by providing recyclers with DPP data on the materials and substances in each device. Both regulations apply to electronics manufacturers independently.