When we take a glance back at the last few years, the European Commission’s Ecodesign for Sustainable Products Regulation (ESPR) has shifted from an obscure governance exercise far on the horizon to a direct priority for the electronics industry – one which must be acted on imminently if companies don’t want to be left behind.
Having originally come into force during the summer of 2024, with the overarching goal of making sustainable products the norm in the EU, electronics companies that are due to be impacted (those who either sell or are based in the European market) have been getting to grips with the regulations’ varied intricacies. In particular, the regulation’s mandating of Digital Product Passports (DPPs).
With the electronics sector’s uniquely complex supply chain considerations and the 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.
Moreover, the EU’s particular focus on the industry is perhaps unsurprising when we note that, in Europe in 2022, the production of e-waste led to the emission of approximately 16.6 billion kilograms of CO₂-equivalent greenhouse gases – highlighting the substantial environmental impact of discarded electronics.
For electronics businesses aiming to stay ahead of the regulation, and best position themselves for an eco-compliant future, the following three milestones should be considered.
Milestone one: The ESPR and Energy Labelling Working Plan (Released in April 2025)
With the EU’s ESPR coming into force last year, it has been a long journey for those affected, with many seeking industry-specific clarity on the task ahead. In April this year, the EU published the first Energy Labelling Working Plan – a document outlining the regulation’s horizontal requirements. This includes repairability scoring (which likely applies to consumer electronics), recycled content, and the 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.
Milestone two: the release of the Delegated Acts (Expected by 2027)
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. The dates for the delegated acts will differ depending on the industry and product group, and for certain industries, these details aren’t expected until 2028 or later. The exact requirements for each industry are expected to include the specifications for the data to be collected and made available. For the electronics sector, this could be the carbon footprint of production and/or guidelines on how to recycle or dispose of hazardous elements of the product. For certain intermediate products in the electronics sector, these guidelines are likely to be as soon as 2027 to align with the horizontal requirements.
At this point, prepared businesses should already have a clear view of where any required data resides within the business or supply chain, an implementation strategy, and be in a position to begin piloting with a trusted partner.
Milestone 3: the deadline for compliance (Expected 2027 to mid-2028)
Electronics manufacturers can expect the compliance deadline to fall within 18 months of each delegated act being published. The European Commission retains the option to shorten this timeframe in cases of environmental urgency or where alignment with broader EU policy makes it necessary.
For the sector, this window should be viewed not as a grace period, but as the final stage in refining DPP strategies. By this point, companies will be expected to move beyond pilot initiatives and roll out full-scale implementation plans with confidence.
Other industries – such as iron and steel, which are further up the compliance queue with delegated acts anticipated in 2026 – offer useful future blueprints for electronics businesses. Observing their challenges and solutions will help electronics businesses prepare more effectively for their compliance obligations.
Although the compliance horizon may seem distant, it will arrive quickly. Each milestone along the way represents a critical chance for the electronics industry to de-risk, adapt, and secure regulatory readiness well in advance of the official deadline.
Author: Matthew Ekholm, Digital Product Passport and Circularity Specialist at Protokol
Matthew is responsible for Protokol’s DPP offering, understanding and translating customer needs into value-adding solutions. A former Director of Circular Services at a Multi-National Packaging company, and a former Operations Manager for Circular Economy Transformation, Matthew has years of experience helping companies develop new circular business models and unlock new opportunities through an increased focus on sustainability and circularity.
