Every design decision has a downstream consequence. The Ecodesign for Sustainable Products Regulation (ESPR) formalises this principle at a regulatory level, requiring engineers to consider material removal, component replaceability, and end-of-life recyclability from the earliest stages of product development. Although ESPR builds on the older Ecodesign Directive, its scope is significantly broader, applying to almost any physical good, including electronics. Products must now be designed holistically, from the ground up, to encompass a total lifecycle approach – not just energy efficiency.
What ESPR means for engineers
ESPR mandates that products are designed to last longer, be repaired more easily, and be recycled more efficiently. For engineers, this means that granular design choices – fastener selection, material compatibility, PCB layering, connector standardisation, and the use of adhesives that prevent material separation – are no longer simply performance considerations; they are now compliance considerations.
If a product, such as a laptop, smartphone, or router, is designed with disassembly and material recovery in mind, the recycling process becomes more efficient and more traceable. ESPR pushes for fewer mixed-material parts, fewer bonding methods that prevent separation, and greater availability of repair information and spare parts. The combined effect is a smoother, more transparent path from initial design through to end-of-life material recovery, rather than a device that is difficult or hazardous to process.
But how does ESPR work in practice? This is where digital product passports come into play.
What is a Digital Product Passport?
A digital product passport (DPP) is a continuously updated digital record attached to a physical product – a structured data sheet that follows a device through its entire life, from manufacturing to end-of-life recovery. It holds product information, including the materials used, expected lifetime, repair options, spare parts availability, energy profile, and recommended recycling steps.
How DPPs work
The passport is created during manufacturing. As materials and components move through the supply chain, each organisation adds the information it is responsible for. When the product enters the market, the identifier on the device gives retailers, users, repairers, and recyclers access to the level of information they are permitted to see.
When a device reaches its end of life, recyclers can scan the product and immediately see which materials can be recovered, which components require careful handling, and the most efficient sequence for dismantling. This removes the need for manual testing or destructive processes to determine what is inside a sealed unit.
DPP data architecture
DPPs are structured as a collection of submodels, each tailored to a specific type of information. These consist of data carriers, unique identifiers (UID), data storage, and accessibility components, which together determine how data moves across systems and stakeholders. The architecture is designed to interact with different software systems across three layers.
Physical layer (Unique Product Identifier)
The unique product identifier (UPI) is physically attached to the product via a data carrier such as a QR code, NFC chip, or RFID tag. When scanned, it directs the user to a digital twin of that specific item.
Decentralised layer
This layer stores information on material composition, carbon footprint, and repairability, and sits with the manufacturer. It allows companies to retain control over proprietary data while making it accessible to those with the appropriate permissions.
EU Central Registry
The EU Central Registry manages a central database storing the metadata, maintaining a record of all active UPIs and linking them to the correct decentralised data source. Note that the Registry is still under development and its final technical specification has not yet been fully ratified; its implementation should be treated as subject to change.
What information does a DPP require?
The fields within a DPP are categorised based on the product lifecycle and include:
- Product information and origin: the unique identifier, manufacturer details, batch numbers, and place and date of manufacture
- Materials and composition: a list of materials, components, recycled content percentages, and substances of concern
- Durability and repairability: expected lifetime, maintenance instructions, repair guides, and spare parts availability
- Environmental footprint: carbon footprint, energy consumption, water consumption, and environmental product declarations (EPDs)
- End-of-life recyclability: disassembly, recycling, and recovery instructions
- Regulatory compliance: certifications and safety test results
It is the responsibility of the economic operator (manufacturer or importer) placing the product on the EU market to create the DPP. For engineers working within global supply chains, the obligation is triggered at the point of EU market entry, which has implications for how product data is captured and structured upstream.
How DPPs interface with PLM and MES
DPPs are designed to bridge existing, often siloed, industrial systems. Product lifecycle management (PLM) systems store the initial design data, bill of materials, and material compliance data that form the foundational layer of DPP content. Manufacturing execution systems (MES) contribute real-time data from the factory floor, including – but not limited to – energy consumption per machine, sensor data, actual batch material composition, traceability records, and quality data. Together, these systems provide the inputs that populate the DPP at each stage of the product’s life.
How DPPs support the ESPR mandate
DPPs make the broader aims of ESPR workable. ESPR sets the requirements for durability, repairability, recycled content, and design for disassembly. The DPP provides the evidence that those requirements have been met, and the practical data needed to act on them.
For electronics at end of life, DPPs mean that recyclers no longer have to guess what is inside a sealed unit. Instead of manually testing or shredding devices to identify their contents, they can follow accurate data. This reduces waste, increases the recovery of valuable materials, and improves safety by identifying batteries, magnets, PCBs, or hazardous substances before dismantling begins.
Design decisions upstream, consequences downstream
ESPR sets the rules for more sustainable electronics. DPPs provide the data trail that allows those rules to be enforced in practice. For engineers, the choices made at the schematic and BOM stage – material selection, fastener type, adhesive use, and connector standardisation – determine recyclability scores, repairability ratings, and ultimately regulatory approval. By embedding accurate data on material composition and environmental footprint at the design stage, the DPP transforms what was once waste management into measurable resource recovery. Teams that already design for serviceability and disassembly will find themselves ahead on compliance, supplier selection, and product certification as these requirements come into force.
