At the time of writing, no date has been set for electronics on which the digital product passport becomes mandatory. The European regulation on ecodesign of sustainable products, in short ESPR, does form the overarching framework, but the regulation itself does not specify per product group when and which requirements will apply. This happens through separate delegated acts, and for electronics that act has not yet been established. This does not mean that nothing is happening, but it does mean that the concrete obligation is not yet fixed at this moment.
What does change this year is the pressure to be prepared. Manufacturers and importers of electronics are increasingly asked by customers, industry organisations and sometimes also by supervisory authorities about their progress. In addition, there are already obligations that could later serve as a basis for a passport, such as the energy label, the RoHS documentation on hazardous substances and registration under the WEEE rules for waste electrical equipment. Those who already check which data exists and where it is located will be better positioned once the obligation becomes concrete.
Why electronics follows a different route than textiles or furniture
The European Commission does not treat all product groups simultaneously. Batteries have their own regulation with their own timeline, separate from the ESPR. Textiles and furniture have been mentioned earlier by the Commission as groups for which work on delegated acts is further advanced than for other groups. Electronics are indeed being investigated and mentioned in working documents, but the formal step to an established act with requirements and deadlines has not yet taken place. This difference in pace says nothing about the importance of the product group; it mainly reflects the order in which the Commission is taking up the implementation.
For companies that market both electronics and, for example, textiles or furniture, this can be confusing: one product group already requires concrete action, the other does not yet. It is therefore wise to monitor per product group what the state of affairs is, rather than assume one moment when everything changes at once. In the knowledge base per product group clarified each situation is stated what is and is not established, with a reference to the official text.
What has been regulated for longer continues to apply
The uncertainty about the digital product passport does not change the obligations that already existed. Electronics already fall under rules for product safety, under the RoHS Directive for restricting hazardous substances, under WEEE for the handling of waste electrical equipment and, for many devices, under energy labelling. These rules exist independently of the ESPR and will continue to exist alongside any future passport. Moreover: the data you already collect for these obligations, such as material composition, energy consumption and origin of components, is precisely the type of information that appears in a digital product passport. Those who have this administration in order will not have to start from scratch when a future obligation comes into force.
What you can already prepare now, without waiting for a date
It is not necessary to wait for the delegated act for electronics to be in place before taking steps. A first step is to determine what role your company plays in the supply chain: are you a manufacturer, importer, authorised representative or merely a distributor of the product. That role will determine later who must provide which data and who is responsible for keeping it up to date. A second step is to take stock of existing documentation: what data is already recorded for energy labelling, RoHS or WEEE, and in which system is it stored. A third step is to discuss with your software supplier how this data can be linked to a passport system in the long term, so that you do not have to replace a system under time pressure later.
If you are in doubt whether this is already relevant for your own assortment, you can have this clarified with a few questions via the product scan that provides an indication in five questions. For questions about how prodpas.eu compiles the information and where it comes from, there is the page that explains how the data is generated.
Where you keep up to date with this
Since the delegated act for electronics has not yet been adopted, it is not possible to name a deadline or concrete requirement now without speculation. The official text of the ESPR and the associated delegated acts can be found on EUR-Lex, and for questions about supervision in the Netherlands, the competent supervisory authority is the appropriate point of contact. If you want to know what is already established and what is not, the collection of frequently asked questions about timing and obligations provides an overview of this.
Do you want to know where your products currently stand without immediately creating an account? The free quick scan provides an initial indication in a few questions, and the knowledge base shows per subject what is already established and what still needs to be worked out.