The electronics sector — covering smartphones, tablets, laptops, monitors, TVs, and data centre equipment — is one of the highest-priority ESPR product groups. Electronics represent significant embedded carbon, use critical raw materials (cobalt, rare earth elements), and have historically short lifespans driven by planned obsolescence.
Required DPP Data for Electronics
- Critical raw materials: content of cobalt, lithium, tantalum, tungsten, tin, gold in key components (PCBs, batteries, screens). Must reference conflict minerals compliance (Dodd-Frank, EU Conflict Minerals Regulation).
- Repairability score: standardised score (1–10) based on disassembly ease, spare parts availability, repair documentation access. France's Repairability Index is the current model.
- Software support commitment: how many years of OS updates and security patches the manufacturer commits to providing.
- Battery health data: for devices with embedded batteries — rated capacity, cycle count at time of manufacture, replaceability rating.
- Energy consumption: standby power, typical annual energy consumption (kWh/year).
- Recycled content: percentage of recycled plastic, aluminium, and recovered rare earth elements.
- Packaging: packaging material composition and recycled content.
Repairability: The Key Differentiator
The ESPR Right to Repair provisions (Directive (EU) 2024/1799) require manufacturers to make spare parts available for at least 7 years after product launch, provide repair manuals to independent repair shops, and not use software locks to prevent third-party repairs. These obligations must be documented and accessible via the DPP.
Data Carrier Placement
For ICT products, the QR code is typically placed on: the device's outer packaging box, the device's settings menu (a software-generated QR), and/or the device's regulatory label. The regulation allows multiple data carrier placements to accommodate different use cases.
Timeline
ICT products are in the ESPR 2022–2025 working plan. Delegated acts for smartphones and tablets are expected 2026–2027, with mandatory DPPs from 2028. Laptops and monitors follow closely behind.