Matthew Ekholm, Digital Product Passport and Circularity Specialist at Protokol, discusses three important milestone businesses that need to be considered to advance ESPR and DDP legislation.
Over the past few years, eco-design in the EU’s Sustainable Product Regulation (ESPR) has shifted from ambiguous governance exercises on the horizon to concrete priorities in the technology sector.
With sustainable products being implemented in mid-2024 to make EU standard, companies around the world have been knowing their past compliance (DPPS) for compliance, including who it will affect (the person placing products from priority sectors within the EU market), for compliance such as digital product passport implementation.
Unique, complex supply chain considerations and the additional scrutiny received for the amount of e-waste generated, the electronics sector and the technology sector more broadly present a wide range of challenges when it comes to compliance. This eco-focus from the EU showed that as of 2022, around 62 million tons of e-waste had been produced worldwide, but only about 22.3% were officially collected and recycled.
If you are aiming to be optimally positioned for an environmentally compliant future to support your electronics business that wants to go ahead of regulations, the following three milestones are key to maintaining your radar.
Milestone 1: EU ESPR and Energy Labeling Work Plan (April 2025)
After the ESPR came into effect in July 2024, it has been a long wait to make it clearer for companies’ tasks across the priority sector. Finally, the work plan was published in April this year, providing an overview of horizontal requirements such as repairability scoring (probably including home appliances), recycled content, and electronics recyclability.
In the work plan, all products in which EcoDesig materials are used have a DPP (Digital Record of Product Information), enabling the release of product data for businesses, consumers and public agencies.
Knowing this early on is a must, electronics providers can begin developing strategies for deploying DPP, identify where the required data resides, and begin engagement with DPP solution providers.
Milestone 2: Release of Delegated Acts (Expected by 2027)
By 2027, the EU is expected to outline a set of first acts delegated. This provides guidelines detailing the exact requirements for the data required for DPPs for each priority group. Release dates vary by industry and product group, with some such as the Steel Act being expected to be announced earlier, and furniture like that is expected to be in a few years (2026-2028, respectively).
In broad terms, the delegated law outlines requirements that provide transparent data on the durability, repairability, recycled content, and resource efficiency of products within each particular group. Specifically, for the electronics industry, this could be a guideline on the carbon footprint of production and how to recycle or dispose of dangerous components of the product. By this time, businesses need to be in a position to clearly see the data they need in their business or supply chain and start piloting with trusted partners.
Milestone 3: Compliance deadline (predicted from 2027 to mid-2028)
Compliance deadlines are expected to be up to 18 months from the issuance of each delegated act. However, for example, the EU can shorten this period if it is justified due to environmental urgency and alignment with other policies.
Following the announcement of the delegated law, the electronics business must be well positioned to learn from pilots and gain confidence in the DPP implementation plan to achieve compliance. They can also look at industries that are at the top of the priorities list (such as iron and steel, where it is expected that the publication of delegated acts will be seen in 2026 rather than 2027).
Compliance deadlines are several years away, but each milestone provides an important opportunity for electronics companies to consider securing a path to regulatory compliance earlier than planned.
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