In just a few years, the European Commission's Ecodesign for Sustainable Products Regulation (ESPR) has gone from a distant policy discussion to an urgent priority for the electronics industry, one that companies must address now or risk falling behind.

Having originally come into play in mid-2024, with the ultimate goal of making sustainable and circular products the norm in the EU, electronics companies that are due to be impacted (those who either sell into or are based in the EU market) have been getting to grips with the regulations' varied intricacies. In particular, the regulation mandating Digital Product Passports (DPPs).

Given the electronics sector’s highly complex supply chains and the heightened scrutiny it faces due to the significant volume of e-waste it produces, achieving compliance represents a considerable challenge.

The EU’s strong focus on this industry is understandable when we realise that, in 2022 alone, Europeans generated, on average, 17.6 kg of e-waste per capita, and out of that, approximately 7.5 kg per person was formally collected and recycled. For electronics businesses looking to stay ahead of regulation and position themselves for a more sustainable future, three upcoming milestones are particularly important to track.

With the electronic sector’s uniquely complex supply chain considerations and added scrutiny it receives due to the amount of e-waste it generates, the sector has an extensive task ahead when it comes to compliance.

The EU’s circularity push and Energy Labelling Working Plan (Released in April 2025)

Since the EU’s ESPR came into force last year, affected industries have been navigating a complex path, seeking clarity on next steps. To address this, the EU released its first Energy Labelling Working Plan in April 2025, outlining horizontal requirements across sectors. Key areas include repairability scores (likely covering consumer electronics), recycled content, and recyclability of electronic equipment.

The Working Plan says that every product for which ecodesign measures will have to be adopted will have a DPP (a digital record of information about the product), to open up data access for businesses, consumers, and public authorities.

Knowing early on that this will be mandatory allows electronics providers to start developing strategies for deploying DPPs, identifying where the necessary data resides, and engaging with DPP solution providers.

The Delegated Acts and Horizontal Requirements  (Between 2027 and 2029)

By 2027, the EU is expected to have outlined its first set of delegated acts for certain product groups - these will provide guidelines detailing the exact requirements for the data needed in DPPs.  Timelines will vary by industry; some won’t see finalised details until 2028 or later. For electronics providers, it will be the horizontal requirements (due between 2027 and 2029) that will be the most relevant. These rules are expected to cover specifications such as product carbon footprints and instructions for recycling or safely disposing of hazardous components.

Companies that want to stay ahead should already be mapping where the necessary data sits within their business and supply chain, defining an implementation strategy, and preparing to run pilots with trusted partners.

Compliance deadlines are looming (Expected 18 months after the delegated acts)

Electronics manufacturers should anticipate that compliance will be required within roughly 18 months of the relevant delegated act being published. The European Commission may also choose to shorten this timeframe in cases of environmental urgency or to align with broader EU policy goals.

This period should not be seen as a grace window, but as the final phase for perfecting DPP strategies. By then, companies will be expected to move beyond pilots and deliver full-scale implementation with confidence.

Industries earlier in the queue, such as iron and steel, which are likely to see delegated acts in 2026, will serve as valuable case studies. Their experiences will provide useful lessons that electronics businesses can apply to strengthen their own compliance readiness.

Although the deadlines may seem distant, they are expected to take effect approximately 18 months following the adoption of the delegated acts. Each milestone presents an opportunity for the electronics sector to reduce risks, adapt proactively, and ensure regulatory compliance well ahead of the cutoff date.

 

 

 

 

 

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