• • • EDITOR’S CHOICE • • •
ESPR COMPLIANCE IS AROUND THE CORNER: THE ELECTRONICS INDUSTRY MUST TAKE ACTION NOW AHEAD OF THE MANDATED DPPS
Checkpoint 1: The ESPR and its first Working BY MATTHEW EKHOLM,
DIGITAL PRODUCT PASSPORT AND CIRCULARITY SPECIALIST, PROTOKOL
W
hen we consider how the electronics industry has shifted over the last few years, the European Commission’s
Ecodesign for Sustainable Products Regulation (ESPR) and its effect on the industry have arguably had the most impact. Having evolved from a sustainability pledge to a governance framework, and now an imminent priority for the industry, many in the sector feel they might be left behind. For context, having come into play during mid-2024, with the ultimate goal to make sustainable products the baseline in modern Europe, many electronics companies are due to be impacted by the ESPR. In fact, any company (within the product groups specified) that sells or is based in the European marketplace is under the microscope.
Many businesses within the sector and others
are trying to get to grips with the regulation’s complexities, particularly its mandating of Digital Product Passports (DPPs). The electronics industry in particular faces a uniquely challenging path to compliance. Its complex supply chains, coupled with the vast amounts of e-waste it produces, put it under intense regulatory scrutiny.
This is perhaps unsurprising when we note that in 2022, out of the 14.4 million tonnes of electrical and electronic equipment placed on the market that year, only 5 million tonnes were collected as e-waste. With this in mind, for industry trailblazers who aim to stay ahead of the regulation and best position themselves for a new sustainable era, the following three regulatory checkpoints could prove pertinent to fueling the compliance journey.
Plan (Released in April 2025) With the EU’s ESPR entering into force mid-last year, it has been a complex road for those due to be affected, with many sectors requesting industry-focused clarity on the task ahead. Leap forward to April 2025 and the EU published the first Energy Labelling Working Plan, a framework outlining the regulation’s horizontal requirements, including repairability scoring (which likely applies to consumer electronics), recycled content and the recyclability of electronic equipment.
As part of these requirements, the Working Plan says that every product for which the ecodesign measures apply will have to adopt a DPP (a digital record of information about the product). A mandate set to open up data access for businesses, consumers and public authorities. With this in mind, taking the time to understand DPPs early on will allow electronics providers to start developing strategies for deploying DPPs, identifying where the necessary data resides and engaging with DPP providers coherently.
Checkpoint 2:
The Delegated Acts, Horizontal Requirements and Industry
Readiness (Starting in 2027) For the electronics industry, one of the ESPR’s priority sectors, the regulation is set to outline its first set of delegated acts in the coming years. This moment will provide guidelines detailing the exact requirements for the data needed in DPPs for each priority group. The delegated acts will set out requirements on durability, repairability, recycled content and resource efficiency for each product category. However, for this sector in particular, the regulations’ horizontal requirements and product-specific files are particularly relevant with their looming 2027 deadlines.
26 ELECTRICAL ENGINEERING • FEBRUARY 2026
The horizontal requirements are expected to include repairability scoring, recycled content and recyclability of electronic equipment (adoption in 2030), which shall have a direct impact on this industry, particularly. Moreover, this, alongside a range of the legislation’s product-specific files, such as mobile phones and tablets, highlights even more reasons to get prepared immediately.
Checkpoint 3: The Compliance Cut Off
(Expected 2027 to mid-2028) For electronics companies in particular, the compliance cut-off is likely to fall within 18 months of each delegated act being published. The European Commission retains the option to shorten this timeframe in cases of environmental urgency or where alignment with broader EU policy makes it necessary. For those aiming to succeed (rather than simply
survive) amidst this shifting landscape, this timeline should be viewed not as a grace period, but rather a final call to refine DPP strategies and tackle compliance effectively as the deadline nears. By this point, companies will be expected to move beyond pilot initiatives and roll out full-scale implementation plans with confidence. From a strategic point of view, electronics companies could look to sectors such as iron and steel (which are ahead in the compliance queue with delegated acts expected in 2026) to learn valuable lessons on effective compliance routes. By considering their journey, hurdles and solutions, electronics companies can better anticipate and prepare for their own obligations. While the compliance deadlines might not seem in the near future, this is likely to approach quickly (particularly when we consider the lengthy process of becoming DPP compliant). By considering the three checkpoints above, the electronics sector is given a vital chance to reduce risk ahead of time, adapt processes accordingly and build regulatory readiness well before these rules take effect.
https://www.protokol.com
electricalengineeringmagazine.co.uk
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