Digital Product Passport for Electronics: EU Compliance Guide 2028
EU ESPR will require a Digital Product Passport for electronics and ICT equipment from 2028. This guide covers the data requirements, repairability rules and how electronics brands must prepare.
The Digital Product Passport for electronics, mandated by EU ESPR, will require electronics and ICT equipment sold in the EU from 2028 to have a digital record. This record will include data on material composition, repairability (score, spare parts), software support, hazardous
What is the Digital Product Passport for electronics?
The Digital Product Passport for electronics is a mandatory digital record that electronics manufacturers and brands must provide for ICT equipment and consumer electronics sold in the EU under the Ecodesign for Sustainable Products Regulation (ESPR). It contains verified data about material composition, repairability, spare parts availability, hazardous substances and end-of-life handling, accessible via a QR code or digital link on the product or packaging.
EU electronics DPP timeline
2024-2026 — ESPR electronics delegated act consultation and preparation
2026-2027 — Electronics delegated act published with final requirements
2028 — DPP mandatory for electronics and ICT equipment sold in the EU
What data will the electronics DPP require?
Material composition — critical raw materials (cobalt, lithium, rare earths), recycled content percentages, plastic types
Repairability score — standardised repairability index covering spare parts availability, repair documentation, software support duration
Spare parts — availability of key spare parts (batteries, screens, connectors) for minimum 5-7 years post-sale
Software support — minimum software and security update commitment period
Hazardous substances — SCIP database declarations, RoHS compliance, restricted substance list
Energy performance — energy efficiency class, power consumption in use and standby
End-of-life — disassembly instructions, WEEE take-back scheme information, battery removal instructions
Right to repair requirements for electronics
ESPR electronics requirements are closely aligned with the EU Right to Repair Directive. Electronics manufacturers must ensure spare parts and repair tools are available to independent repairers — not just authorised service centres — at reasonable prices. The DPP serves as the digital record linking consumers and repairers to repair documentation and spare parts ordering.
Critical raw materials and supply chain transparency
Electronics DPPs must include data on critical raw materials (CRMs) — cobalt, lithium, tantalum, rare earth elements — used in components. This data must be traceable to the supplier level and verified. Companies sourcing from complex multi-tier supply chains in Asia face significant data collection challenges and should begin supplier engagement programmes immediately.
How to prepare your electronics DPP programme
Map your bill of materials (BOM) against anticipated DPP data fields for your product categories
Engage component suppliers (battery cells, displays, PCBs) to begin CRM and substance data collection
Calculate your current repairability score against the EU methodology
Review your spare parts policy and software support commitments against ESPR minimums
Select a DPP platform with electronics sector experience and SCIP database integration
Browse electronics DPP solution providers in our directory or use our Compliance Navigator to assess your requirements.
Frequently Asked Questions
When will electronics DPP be mandatory in the EU?
Electronics and ICT equipment DPP requirements are expected to apply from 2028, following publication of the ESPR delegated act. Companies should begin preparation by 2026 to allow sufficient time for supplier data collection and system implementation.
Does the electronics DPP replace RoHS and WEEE compliance?
No — RoHS (hazardous substances) and WEEE (waste electronics) requirements remain in force. The DPP complements these obligations by providing a digital record of substance declarations and end-of-life information, but does not replace existing reporting requirements.
How does the electronics DPP affect smartphone manufacturers?
Smartphone manufacturers face some of the most demanding DPP requirements — repairability scores, spare parts obligations (batteries, screens), software support commitments and CRM declarations. The EU has already established repairability requirements for smartphones under earlier ESPR measures, which the full DPP will build upon.