Recycled Content in Electronics: The Horizontal Measure

The ESPR Working Plan contains two horizontal measures. The first is the repairability score; the second is recycled content and recyclability of electrical and electronic equipment (EEE). The delegated act for this second measure is expected, indicatively, in 2029, and it targets a broad slice of EEE rather than a single product group.

Where the repairability score is about design and service, this measure is about materials: what the housing is made of, which critical raw materials sit inside, whether the parts can be separated. Given that Türkiye is a significant supplier of household appliances and electronics to the EU, the measure touches the export line directly.

The measure's likely scope

There is no draft yet; the scope is read from the Working Plan's reasoning and the direction of existing legislation. Four headings stand out:

• Recycled plastic share: post-consumer recycled content in large plastic parts such as housings, covers and internal frames.
• Critical raw materials: presence and location of critical raw materials in motor magnets, circuit boards and batteries. The 2024 Critical Raw Materials Act set EU-level recycling benchmarks and introduced information duties for permanent magnets in certain products.
• Design rules for recyclability: marking plastic parts with their resin type, avoiding incompatible blends and inseparable metal inserts.
• The WEEE link: dismantling instructions for hazardous components and recovery information.

The measure's place in the plan is covered in the ESPR Working Plan; WEEE's current information duties in WEEE, RoHS and REACH.

Why per part?

A washing machine contains dozens of plastic parts, often from several moulders. The recycled share is determined not at product level but at resin-grade level: whatever post-consumer material the compounder put into a given lot is the share. The product-level percentage is a calculation weighted by part mass.

The evidence chain is therefore built per part: part number, resin grade, supplier, recycled share, certificate. The source of the calculation is the bill of materials; preparing the BOM explains how to set it up for this purpose. For certification schemes, mass balance and the pre-/post-consumer distinction see how to prove recycled content, and for lot-level polymer data see DPP for plastics and polymers.

Data points and evidence

Most rows in the table already exist somewhere: the certificate at the supplier, the dismantling guide in service, the magnet data at the motor maker. What is missing is that they are bound to a part number and versioned.

For appliance and electronics exporters

For an appliance exporter this measure adds a materials layer on top of the repair and energy data described in DPP for home appliances. The slowest task is obtaining certified, lot-level declarations from moulders and compounders, which is why the demand belongs in the contract. See DPP clauses for supplier contracts for what to include.

The Batteries Regulation shows how this path tends to run: a documentation duty first, minimum shares years later. The sequence in recycled content in batteries is a reasonable expectation for the EEE measure too.

Preparation steps

1. Tag every plastic part in the BOM with its resin grade and supplier.
2. Add a lot-level recycled-share declaration and certificate clause to supplier contracts.
3. Make part marking and disassembly information a mandatory output of the design process.
4. Version the mass-weighted share calculation; open a new version when a resin changes.
5. Collect supplier declarations for components containing critical raw materials (motors, PCBs, batteries).

For the passport's general structure see the DPP guide.

Frequently asked questions