Europe’s new product rules will not stop at manufacturing, and Matthew Ekholm, Digital Product Passport and Circularity Specialist at Provenant, explains why consultants, contractors, and project teams should be paying attention now – especially for what product-data requirements may mean for specification, procurement files, and handover packs.
The EU’s Ecodesign for Sustainable Products Regulation (ESPR) is quickly rising on the agenda. This is significant for businesses selling into the European marketplace because the regulation sets a range of complex requirements and each priority product group will have a unique set of guidance to follow. The regulation entered into force in July 2024, with further detail on timelines and priorities set out in the first Working Plan adopted in April 2025.
There’s no doubt that ESPR is set to make a huge impact on businesses selling into Europe. It’s a complex set of requirements and, as a result, many are keen to take steps now to set themselves up for the compliance process. Especially the mandated Digital Product Passports (DPPs) that will be required across products covered by future ecodesign measures, unless an equivalent digital system applies.
Those looking to stay ahead should pay close attention to the following three critical moments.
Moment One: The 2025–2030 ESPR and Energy Labelling Working Plan
The ESPR has been in the public domain for a while now after entering into force in 2024. However, while the regulation established the need for change, it left many of the practical details on how to comply still emerging. This has created a gap between regulatory ambition and operational clarity.
In April 2025, the regulation’s first Working Plan was published. This outlined a range of requirements across both vertical and horizontal categories relevant to businesses in the impacted sectors. For electronics businesses specifically, horizontal requirements such as repairability scoring, recycled content, and the recyclability of electrical and electronic equipment will stand as key focus points.
According to the new ESPR framework, every product subject to future ecodesign measures will need a DPP, unless an equivalent digital system provides the same information. A DPP is a digital passport that acts as a physical item’s digital record and provides essential product information. This has been put in place to improve data accessibility, transparency, and traceability for businesses, consumers, and public authorities to encourage more sustainable practices. As product-level sustainability, repairability, and lifecycle data, alongside other aspects, become mandatory, businesses will need to ensure that specified equipment can provide compliant DPP information and verifiable sustainability credentials.
Contractors and project teams might also need to verify and document DPP data during procurement and handover stages – ensuring that equipment meets regulatory requirements and that digital records are captured as part of project documentation.
By recognising in advance that DPP data will become mandatory, electronics businesses can get a head start by developing deployment strategies early, mapping where data is stored, and collaborating with their supply chains to ensure compliance. It is worth noting that the requirement for such DPP data is likely to influence specification writing, procurement criteria, and handover packs, with consultants increasingly required to assess product data transparency alongside tracking traditional performance metrics.
Moment two: The Delegated Acts
By 2027, the EU is expected to roll out its first delegated acts for initial priority industries, a series of formal guidelines that define exactly what data must be collected by economic operators and disclosed through their DPPs for specified product categories. There are some sectors, not yet determined, that may not receive these detailed requirements until later, but the mandate will eventually arrive, and businesses must comply when it does.
As we don’t yet know the specific details that will be required as yet, the best course of action in the electronics industry now, ahead of the horizontal deadlines, is to map where critical product and supply chain data currently resides, establish a clear roadmap for DPP implementation, and launch pilot programmes with trusted partners.
Starting this process of setting up DPPs provides electronics businesses with a significant advantage – this way, they can prepare methodically, engage with solution providers, and avoid facing last-minute, rushed compliance efforts.
Moment three: ESPR Compliance (approximately 18 months later)
Once a delegated act is published, manufacturers supplying to or operating in the EU will have up to 18 months before it applies. However, if the EU justifies it, this window can be shortened. Because of this, manufacturers should treat pilot programmes as more than test beds; instead, they’re an opportunity to refine and remove risk from their DPP implementation strategies.
Even if the formal deadlines appear distant for now, every step on the compliance roadmap is important. Electronics businesses have the chance to assess the supply chain early, gathering information about product composition that will most likely be required, enabling them to stay well ahead of the curve.
The ESPR will not simply reshape manufacturing processes but also introduce new expectations for data availability and compliance verification through the project delivery chain – especially in specification, procurement, and handover.
