Industry · Electronics & ICT
The product passport for electronics: the industry with the most precursors.
Hardly any industry knows product-data obligations as well as electronics: energy label, ecodesign requirements, RoHS, REACH, SCIP, WEEE – and since June 2025 the repairability index for smartphones and tablets. The ESPR act for electronics/ICT is expected 2028–2029, the DPP obligation ~2030. Consolidate your existing compliance data now and half the passport is already done.
- 2028–2029ESPR act for electronics/ICT expected
- ~2030DPP obligation realistic (act + ~18 months)
- Since 06/2025Ecodesign & repairability index for smartphones/tablets in force
- 18 Feb 2027Battery passport – the interface for devices with batteries (fixed)
01 — Situation
Electronics has long had the DPP in precursors – now it all comes together.
For electronics manufacturers the Digital Product Passport is less uncharted territory than for most industries: the EU energy label with EPREL registration, ecodesign requirements, RoHS conformity, REACH information duties and SCIP notifications of substances of concern have existed for years. Since June 2025, ecodesign requirements for smartphones and tablets have also applied – including a repairability index, spare-part and software-update obligations – a foretaste of the DPP logic.
The difference from the coming product passport: today this data sits in separate silos – EPREL here, SCIP there, declarations of conformity in the document archive. The DPP under the ESPR merges them into one machine-readable, product-specific data record with a unique identifier. The delegated act for electronics/ICT is realistically expected 2028–2029, making the obligation ~2030 – all dates in the DPP timeline.
Affected are manufacturers, importers and companies placing products on the market alike – including hardware start-ups that manufacture in Asia. And anyone building devices with batteries already has a fixed date at the interface: the battery passport from 18 Feb 2027.
02 — Requirements
What data the electronics DPP is likely to require.
The delegated act will settle the details – but from the ESPR, the smartphone/tablet rules and existing electronics compliance, the categories are already clear:
Repairability & spare parts
Repairability scoring, disassembly information, spare-part availability and delivery times – reality for smartphones/tablets since 2025, foreseeable for further device categories.
Critical raw materials
Information on strategic raw materials such as rare earths, cobalt or gallium in assemblies – relevant for recyclers and EU raw-materials policy.
Substances of concern
Substances of concern beyond RoHS limits – your REACH/SVHC and SCIP data become the DPP data source, but need component-level linkage.
Energy & environmental data
Energy efficiency, lifetime parameters, possibly carbon footprint – compatible with EPREL and existing ecodesign measurements.
Battery data (interface)
Devices with LMT, industrial or traction batteries touch the battery passport from 2027 – device passport and battery passport must be cleanly linked.
Unique identifier + QR
Product identifier under EN 18219 with a data carrier on the device – granularity (model/batch/serial number) is set by the delegated act.
EPREL, SCIP, RoHS, declarations of conformity – but all in separate systems?
That is exactly where electronics readiness begins: taking stock of existing compliance data and transferring it into a product-specific data model. In a short call we will show you what the path looks like.
03 — Approach
Electronics readiness in five steps.
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1
Applicability check
Check the portfolio against the ESPR working plan, the Battery Regulation and existing ecodesign rules: which device categories are hit by what – and when?
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2
Compliance data audit
Take stock of EPREL, SCIP, RoHS/REACH and WEEE data: what exists, in which system, linked to which product – and where are the gaps?
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3
Bills of materials & suppliers
Deepen BOM data to material and substance level: structured supplier requests (full material declaration), prioritised by volume and risk.
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4
Data model & systems
DPP data model for your device families, identifier logic down to serial-number level, connection to ERP/PLM/PIM – including the battery passport interface where relevant.
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5
Pilot product passport
A real device with a QR identifier, machine-readable data and a registration dummy – as the blueprint for rollout before the delegated act takes effect.
04 — FAQ
Frequently asked questions from the electronics industry.
When does the Digital Product Passport become mandatory for electronics?
The delegated act for electronics/ICT is realistically expected 2028–2029; with the typical transition period of ~18 months, the obligation would land around 2030. These dates are indicative. Fixed, by contrast, are the battery passport from 18 Feb 2027 (for devices with affected batteries) and the ecodesign requirements for smartphones and tablets in force since June 2025.
We comply with RoHS, REACH and SCIP – is that not enough?
It is a very good basis, but not a substitute. The DPP requires a coherent, machine-readable data record per product with a standardised identifier, registry connection and tiered access rights. Your existing notifications and dossiers become data sources – the work lies in merging them on a product-by-product basis.
What does the battery passport mean for our devices?
The battery passport from 18 Feb 2027 applies to traction/EV batteries, LMT batteries and industrial batteries above 2 kWh – not to every button cell. If your products contain affected batteries, you need the passport data from your cell/pack supplier and a clean link between device and battery data. We check this in the applicability check.
We are an importer and do not manufacture ourselves – does the DPP still affect us?
Yes. Responsibility lies with whoever places the product on the EU market – for imported goods, that is regularly you. The data must come from the manufacturing chain: the earlier data requirements (full material declaration, repairability data) enter contracts and ordering processes, the cheaper implementation becomes.
What should we do now, concretely?
Three things: (1) take stock of compliance data and establish product linkage, (2) deepen BOM and supplier data to material/substance level, (3) prepare the identifier and system concept – including the battery passport if 2027 is relevant for you. That way you are ready to go as soon as the delegated act fixes the details.
Contact
Your compliance data is half the passport – the other half needs lead time.
Tell us briefly which device categories you manufacture or import – you will get an honest assessment of what the DPP means for you and what makes sense now.
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