EU ESPR: Application to Electronics and ICT Products (Horizontal Requirements)
ENFORCEMENT TIMELINE
No dedicated delegated act. Indicative adoption of horizontal requirements in 2027 (reparability) and 2029 (recycled content)
Overview
The first ESPR Working Plan (published April 2025) does not set a dedicated delegated act for electronics and ICT products. Instead, they are to be covered in stages through two horizontal requirements that cut across product groups: (1) a reparability scoring framework and (2) recycled content and recyclability requirements for electrical and electronic equipment. Smartphones and tablets are handled separately under the energy-related products track.
Enforcement Timeline
April 2025: The first ESPR and Energy Labelling Working Plan is published (no dedicated delegated act for electronics; ICT products are covered in the preparation of two horizontal requirements).
Until December 31, 2026: For 19 of the 35 products in the 2022–2024 Working Plan, the ESPR provides a transition period during which measures under the previous Ecodesign Directive continue to apply.
2027 (indicative): Adoption of the reparability scoring framework.
2028: Mid-term review of the Working Plan.
2029 (indicative): Adoption of recycled content and recyclability requirements for electrical and electronic equipment.
End of 2030 (indicative): Adoption of revised ecodesign and energy labelling requirements for smartphones and tablets (Working Plan).
Business Impact
No specific obligations have yet been set for electronics manufacturers. The Working Plan gives 2027 as the indicative adoption year for the horizontal repairability requirements and 2029 for the requirements on recycled content and recyclability of electrical and electronic equipment. Design for easier disassembly and component data management are among the preparations to consider. The Working Plan provides for a mid-term review in 2028, so the timing may change.