ICT and Electronics Digital Product Passport Requirements

Current regulatory status

Why ICT and electronics cannot be treated as one product category

"Electronics" is a market label, not one legal product specification.

A smartphone, server, monitor, router, laptop and industrial drive can have very different:

• energy profiles
• repair and spare-part requirements
• material and component structures
• product lifecycles
• safety and conformity regimes
• energy-labelling status
• existing registry obligations
• end-of-life duties.

The Working Plan therefore uses a combination of horizontal requirements and product-specific energy-related measures rather than announcing one single "electronics delegated act" with one uniform passport.

This architecture is a feature, not a gap.

Which ICT and electronics product groups are currently prioritised?

The first Working Plan identifies two horizontal measures relevant to ICT and EEE:

Repairability, including scoring — 2027 track

The Commission says the scope will be refined through preparatory work and may include products such as consumer electronics and small household appliances.²

This is In official development. It does not establish that every electronic product will receive a repairability score, or that a repairability score will necessarily be a universal DPP field.

Recycled content and recyclability of EEE — 2029 track

The Working Plan identifies a horizontal measure on recycled content and recyclability of electrical and electronic equipment, with potential benefits for raw materials, climate and waste prevention.²

Again, the exact product scope and information architecture are not final.

Specific energy-related products

The Working Plan separately carries forward many energy-related product groups. ICT-relevant examples include:

• electronic displays
• mobile phones and tablets
• servers and data storage products through existing/reviewing ecodesign architecture
• computers through existing ecodesign architecture
• other equipment depending on the final product measure.²¹⁰¹¹

The roadmap for individual energy-related product rules runs across 2026-2030.

That means an ICT manufacturer must start from its actual product group, not from the word "electronics".

What role does ESPR play?

ESPR is the horizontal framework for future ecodesign and DPP requirements.¹

It can support:

• product-specific ecodesign requirements
• horizontal requirements for groups of products
• product information made available through a DPP
• interaction with existing Union digital systems where duplication should be avoided.

The Working Plan says product information will mainly be made available through the DPP or, for products with energy labels, via EPREL.²

The Commission's FAQ also explains that a product group can be exempted from a separate DPP where another EU law already provides a digital information system that achieves the same goals.⁴

The critical qualifier is product-specific decision. The existence of EPREL does not automatically remove a DPP for every energy-labelled product, and the existence of ESPR does not automatically create a separate passport for every electronic product.

What is EPREL?

EPREL is the European Product Registry for Energy Labelling.

It contains product models within the scope of EU energy-labelling legislation. Since 1 January 2019, suppliers must register covered models in EPREL before they start placing them on the Union market.⁷

EPREL includes:

• a supplier compliance environment
• public model information
• product information sheets
• energy-label data
• authority-oriented technical information
• model registration numbers
• in newer energy labels, QR links to the registered model.

The public EPREL interface lets users search by product group and model. Product-group data can be detailed and can include links to repair instructions, spare parts or dismantling information where the relevant legislation provides for them.⁷

EPREL is therefore not just a hypothetical precedent. It is a live, mandatory Union product-information system for defined product groups.

Existing Knowledge: EPREL: What a Mandatory EU Product Register Produced.

Can EPREL be used instead of a separate DPP?

Potentially, for a defined product group where the legal conditions are met and the relevant measure says so. Not universally.

The Working Plan explicitly says product information will mainly be available through the DPP or, for products with energy labels, through EPREL.²

The Commission's DPP FAQ explains the anti-duplication principle: a product group can avoid a separate DPP where another Union digital system already achieves the relevant objectives.⁴

That means the correct architecture question is:

For this product group, does the final ESPR measure use a DPP, EPREL as an equivalent system, or a defined interaction between them?

Do not turn that into "EPREL replaces DPP for electronics".

What data is already structured today?

A great deal, but it varies sharply by product.

Smartphones and slate tablets

EU energy-labelling rules for smartphones and slate tablets already require a label containing:

• a QR code
• trade mark
• supplier model identifier
• energy-efficiency class
• battery endurance per charge
• repeated free-fall reliability class
• repairability class
• battery endurance in cycles
• ingress-protection rating.⁸

The QR links into the energy-labelling/EPREL system. These are current energy-labelling requirements, not evidence that every future electronics DPP must contain those fields.

Smartphones and tablets also have current ecodesign requirements under Regulation (EU) 2023/1670, including repair, spare-part, battery and durability-related obligations.⁹

Electronic displays

Electronic displays are already subject to ecodesign and energy-labelling measures and are registered in EPREL. The current review also considers further product-information and substances-of-concern tracking questions.¹⁰

Again, that is a product-specific energy-related architecture.

Servers and data storage products

Servers and online data storage products have ecodesign requirements under Regulation (EU) 2019/424. The rules include energy-efficiency information and circular-economy aspects such as component extraction, critical raw materials, secure data deletion and firmware availability.¹¹

Many server products do not sit inside the same energy-label/EPREL model as consumer devices. That alone demonstrates why "electronics DPP" is too broad a concept.

RoHS

The Restriction of Hazardous Substances Directive applies to EEE within its scope. It restricts specified hazardous substances and requires conformity processes, technical documentation, EU declarations of conformity and CE marking.¹²

This is structured compliance information under other law. It is not a generic DPP dataset.

WEEE

The Waste Electrical and Electronic Equipment Directive creates producer registration, marking and end-of-life information obligations. It also requires producers to provide treatment facilities with information needed for reuse and treatment, including components/materials and the location of dangerous substances and mixtures where needed.¹³

This is particularly relevant to future circularity data design. It remains WEEE information unless the future DPP measure incorporates it.

Current versus future information

The lesson is not "electronics already has a DPP". It is:

Electronics already has multiple structured regulatory data systems. Future DPP design should reuse them where the law allows rather than pretending the category starts from zero.

Identifiers

There is no single universal electronics DPP identifier established.

ESPR uses the horizontal concept of a persistent unique product identifier (UPI) where a DPP applies.¹

Existing systems already use other identities:

• EPREL model registration number
• supplier model identifier
• product/model identifiers in ecodesign and energy labelling
• manufacturer/operator identifiers
• serial numbers in commercial or safety contexts
• GTIN where businesses choose to use it.

EPREL now supports GTIN search, but the Commission notes that for many products GTIN is not provided.⁷

That is a useful real-world warning against treating GTIN as the universal legal identity for every regulated product.

Prepare: maintain mappings between internal product IDs, model identifiers, EPREL registration numbers, serials and any commercial GTINs.

Do not assume: GTIN, GS1 Digital Link or one external identifier scheme is the universal electronics DPP requirement.

See Barcodes and Product Identifiers: What You Need.

Data carrier

Carrier architecture is product-specific.

Smartphone and tablet energy labels already use a QR code that links to EPREL.⁸ Other energy labels also use QR/EPREL patterns.

That does not establish QR as the universal carrier for all future electronics DPPs.

ESPR requires the applicable product rules to settle the DPP carrier details. If EPREL is used as an equivalent digital system for a particular product group, the access mechanism may follow the energy-labelling architecture instead.

See QR, Data Matrix or NFC: Choosing a Lasting Carrier.

Granularity

There is no universal electronics DPP granularity.

EPREL is fundamentally model-oriented. Smartphone and tablet energy labels refer to a supplier's model identifier and registered model information.⁷⁸

Other electronics regulation can operate at:

• model level
• type level
• product family
• individual serial number
• component or battery level
• producer registration level.

Future ESPR rules can select model, batch or item level for a DPP. An equivalent digital system can also produce a different architecture.

Therefore:

Do not assume that electronics will become item-level simply because some digital-product use cases benefit from serialisation.

See Model, Batch or Item Level for a Digital Product Passport.

Access rights

Access is also fragmented.

EPREL already contains:

• public consumer-facing model information
• supplier/compliance data
• technical information for market-surveillance authorities.⁷

RoHS technical documentation is primarily compliance/authority evidence. WEEE treatment information is for actors carrying out reuse and treatment. A future DPP may create its own public and restricted classes.

Do not assume that every electronics DPP field will be public or that EPREL's current access model will be copied unchanged.

See Who Can See What in a Digital Product Passport.

DPP Registry and existing-system interaction

The EU DPP Registry became operational on 20 July 2026.³¹⁴

For products using an ESPR DPP, it provides the horizontal registration and identifier infrastructure. Full product data remain decentralised.

EPREL is a separate existing Union product-information system.

The key unresolved architecture question is not which database "wins". It is how each future product-specific measure will allocate:

• identifiers
• registration
• public information
• authority information
• product-information sheets
• physical/digital carriers
• DPP Registry interaction
• EPREL interaction
• duplicate-data avoidance.

That is precisely why a generic "electronics passport" architecture should not be hard-coded.

What manufacturers can prepare now

Prepare

Map products to actual regulatory groups Know which models are smartphones/tablets, displays, computers, servers, energy-labelled products, radio equipment or other EEE. "Electronics" is too broad for compliance architecture.

Model identity and hierarchy Control model identifiers, variants, commercial identifiers, serials and component/battery relationships.

EPREL data where applicable Treat EPREL registration numbers, labels, product information sheets and underlying parameter evidence as governed regulatory records.

Current ecodesign evidence Structure spare-parts, repair, durability, battery and resource-efficiency evidence where existing product measures require it.

RoHS conformity Maintain material/substance evidence, declarations of conformity, CE information and technical documentation with stable provenance.

WEEE information Maintain producer-registration information, markings and treatment/recycling information.

Evidence provenance For every value, know the regulation, source, model scope, test method, version, owner and confidentiality class.

Role-based data design Separate consumer information from authority-only, repairer, recycler and business-sensitive data.

Machine-readable interoperability Make existing regulated data reusable without assuming one future DPP schema.

Watch

• final scope of the 2027 horizontal repairability measure
• final scope of the 2029 recycled-content/recyclability measure for EEE
• 2029 Commission ICT programme milestone
• product-specific energy-related delegated acts and reviews
• whether particular product groups use DPP, EPREL or an equivalent-system route
• final DPP Registry interaction
• access and carrier requirements
• product-specific granularity and identifiers.

Do not build around yet

• one universal electronics DPP
• a universal 2029 electronics compliance date
• repairability score for every electronic product
• carbon footprint for every electronic product
• item-level serialisation for every product
• universal component-level disclosure
• mandatory battery information in every electronics passport
• EPREL automatically replacing the DPP
• every electronics DPP using QR
• every electronics DPP using GTIN or GS1 Digital Link.

ICT digital-system map: the practical picture

Open questions and regulatory dependencies

1. Which ICT and EEE products fall inside the final horizontal repairability measure?
2. Which products fall inside the recycled-content/recyclability measure?
3. Will those horizontal measures require DPP delivery, EPREL delivery or another mechanism?
4. Which energy-related product groups will rely on EPREL as an equivalent digital system?
5. Which product groups will need a separate DPP and DPP Registry registration?
6. How will existing EPREL model identifiers map to ESPR UPI requirements where both systems interact?
7. Will final rules remain model-level for energy-labelled products or introduce batch/item data for particular use cases?
8. What data will be public versus authority, repairer, recycler or legitimate-interest access?
9. How will RoHS substance information and WEEE treatment information be reused without unnecessary duplication?
10. What will the 2029 ICT programme milestone actually deliver at product level?

How we know

This dossier deliberately avoids turning a broad market category into a fake universal rule.

The evidence hierarchy is:

1. ESPR
2. the first ESPR and Energy Labelling Working Plan
3. current Commission DPP implementation/FAQ material
4. current Energy Labelling and EPREL sources
5. current product-specific ecodesign and energy-labelling law
6. RoHS and WEEE as adjacent law.

Existing digital systems are described as what they legally are today. Future DPP interaction is labelled as development or unresolved architecture.

Direct answers

Is there one EU Digital Product Passport for all electronics?

No. Current evidence supports multiple product-specific and horizontal regulatory routes.

Which ICT/electronics products are prioritised?

ICT products are included through 2027 repairability work, 2029 EEE recycled-content/recyclability work and specific energy-related product measures.²

What role does ESPR play?

It is the framework for future ecodesign and DPP requirements and allows product-specific or horizontal measures.

What is EPREL?

The EU registry for models in scope of energy-labelling legislation. Covered suppliers register models before placing them on the EU market.⁷

Can EPREL replace a separate DPP?

For a defined product group, the final legal measure may use an equivalent Union digital system to avoid duplication. That does not create a universal EPREL replacement rule.

What data is already structured today?

Depending on the product: model identity, energy efficiency, repairability, battery endurance, durability, spare-part/repair information, substance/conformity data and waste-treatment information.

What future DPP data is actually established?

No universal ICT/electronics DPP field list is established.

Are identifiers settled?

No universal electronics DPP identifier scheme is settled. Existing systems have model IDs and registration numbers; ESPR uses the UPI concept where a DPP applies.

Is the carrier settled?

No. QR is established for defined energy labels such as smartphones/tablets, not universally for future electronics DPPs.

Is granularity settled?

No. EPREL is model-oriented, while other product and lifecycle systems can use other levels.

Are access rules settled?

No universal future access model. EPREL already separates public and compliance/authority information.

What should manufacturers prepare?

Map products to their real legal regimes, govern product/model identity, preserve EPREL and ecodesign evidence, structure RoHS/WEEE information, version data and support role-based machine-readable exchange.

Primary sources

• Regulation (EU) 2024/1781 (ESPR), especially Articles 9-13 and Annex III.

  View official source

• Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187 final.

  View official source

• European Commission, Digital Product Passport implementation hub.

  View official source

• European Commission, DPP FAQs.

  View official source

• European Commission, DPP for Economic Operators.

  View official source

• Regulation (EU) 2017/1369 setting a framework for energy labelling.

  View official source

• European Commission, EPREL.

  View official source

• Commission Delegated Regulation (EU) 2023/1669 on energy labelling of smartphones and slate tablets, current consolidated text.

  View official source

• Commission Regulation (EU) 2023/1670 on ecodesign for smartphones, mobile phones and slate tablets, current consolidated text.

  View official source

• European Commission, Ecodesign/Energy Labelling review for electronic displays.

  View official source

• European Commission, Servers and Data Storage Products.

  View official source

• Directive 2011/65/EU (RoHS), current consolidated text.

  View official source

• Directive 2012/19/EU on WEEE.

  View official source

• European Commission, DPP Registry operational announcement, 20 July 2026. This is a regulatory information resource, not personalised legal advice. Scope and obligations should be checked against the law applying to the specific product and operator.

  View official source

This is a regulatory information resource, not personalised legal advice. Scope and obligations should be checked against the law applying to the specific product and operator.