Electronics · ESPR
Indicative Commission timelineElectronics DPP: ICT, energy-related, repairability — without confusing batteries
ICT and energy-related manufacturers must structure repairability, spare parts and distinct timelines. The Commission targets an ICT delegated act in 2029 (indicative) and a separate 2026–2029 window for energy-related products — these are not fixed obligations, and they are not the battery passport of 18 February 2027.
Is the electronics DPP mandatory in 2027 like batteries?
No. 18 February 2027 concerns the battery passport (Regulation 2023/1542), not consumer electronics / ICT. For ICT, the Commission targets a delegated act in 2029 (indicative); for energy-related products, an indicative 2026–2029 window. In both cases: adoption + ≥ 18 months transition before obligation.
Stakes specific to electronics
Separate ICT and energy-related, then structure repairability and parts — without mixing in the battery timeline.
- 1
ICT vs energy-related
Two distinct indicative windows (ICT 2029; energy-related 2026–2029). Confusing them with the 2027 battery obligation creates false urgency.
- 2
Repairability & score
Repairability indices, technical documentation and tool access will be central — to confirm in delegated acts.
- 3
Spare parts
Availability, lead times and part IDs: without SKU → part links, the DPP fails after-sales and the right to repair.
What is confirmed — and what is not
Confirmed
- The DPP framework is set by ESPR (EU Regulation 2024/1781).
- Product-specific requirements will be set by a delegated act (or dedicated sectoral legislation).
- After adoption of an ESPR delegated act, operators have a transition period of at least 18 months.
- The only published fixed placing-on-the-market obligation to date: the battery passport (18 February 2027, Regulation 2023/1542).
Indicative (EU Commission)
- ICT delegated-act adoption: 2029 (indicative Commission timeline). Separate energy-related products window: 2026–2029 (indicative).
- Compliance obligation = adoption + transition (≥ 18 months) — distinct from the battery passport (18 February 2027).
- Exact fields (repairability, parts, access rights): to be set in the delegated acts.
Source: European Commission — Digital Product Passport page Commission UE
Legal framework for electronics
ESPR; distinct ICT / energy-related timelines; batteries = separate regulation.
ESPR 2024/1781
General DPP framework for most physical goods placed on the EU market. Product requirements are set via delegated acts.
Electronics delegated acts (forthcoming)
They will set ICT and/or energy-related scope, DPP data and access rights. Not enforceable until adopted. The battery passport falls under Regulation 2023/1542.
EU DPP registry
The European registry indexes passports (identifiers). Business data stays with the operator or their provider. Live since July 2026, per the Commission.
Who is in scope for electronics?
ICT and, on a distinct timeline, energy-related products — detail in the delegated acts.
ICT manufacturers & importers
EU placers of ICT products: repairability, parts, documentation.
Typical anticipated data
Product ID, repairability, spare parts, substances, end of life — to be confirmed officially.
Carrier & resolution
Resolvable identifier on product, packaging or documentation — format per final act.
Prepare electronics without confusing timelines
Four ICT / energy-related workstreams.
- 01
Classify ICT vs energy-related
Map the portfolio to know which indicative window applies to each product family.
- 02
Structure repairability & parts
Align scores, part nomenclatures and availability lead times across PLM, ERP and after-sales.
- 03
Pilot one SKU
Publish a pilot DPP (e.g. one ICT peripheral); test resolution and repairer access rights.
- 04
Separate the battery track
If you also sell covered batteries: treat 18 February 2027 as a distinct project, not as the electronics DPP timeline.
Verisav for electronics and after-sales
Living DPP: repairability, parts, no battery mix-up.
Repairability model
Structure built for scores, documentation and repair events.
Parts & Digital Link
Resolvable product / part IDs — workshop and marketplace interop.
Living passport
Repairs and replacements update the DPP after placing on the market.
Frequently asked questions
Structure ICT and parts without inventing a 2027 obligation
We clearly separate ICT DA 2029, energy-related window 2026–2029 and battery obligation 18 February 2027.