Smartphones and Tablets: Ecodesign and the DPP

Two regulations have applied to smartphones, cordless phones and slate tablets since 20 June 2025: (EU) 2023/1670 sets the ecodesign requirements and (EU) 2023/1669 the energy label. Both were adopted under the old Ecodesign Directive and the Energy Labelling Regulation, so neither contains a Digital Product Passport obligation.

Even so, this product group holds one of the most passport-ready data sets anywhere. Durability, spare parts, software support and the repairability class are already measured, documented and registered in EPREL. What is missing is carrying that data into a passport structure.

Two regulations, one data set

Every field in the right-hand column falls into a category that the core passport data model already defines. See DPP data fields for the general list.

Why the old framework matters

These two regulations were written with the tools of the 2009 Ecodesign Directive: performance requirements, information requirements and an energy label. The directive is being folded into ESPR, but that transfer does not automatically give existing measures a passport. A product group only acquires a DPP duty through a new delegated act under ESPR. The distinction is explained in from the Ecodesign Directive to ESPR and in ESPR Articles 9–13, the legal basis of the passport provisions.

What the passport still lacks

The ecodesign data set covers identity, durability and repair well. For the rest of the passport, the gaps are:

• Material composition: critical raw materials in the housing, display and printed circuit board (cobalt, tantalum, rare earth elements).
• Substances of concern: RoHS and REACH declarations in structured form.
• Carbon footprint: dominated by the manufacturing stage and dependent on supplier data.
• End-of-life information: how the battery and display are removed, WEEE dismantling instructions.

For how the substance and waste regimes intersect with the passport, see WEEE, RoHS and REACH. The phone battery is a portable battery and sits outside the scope of the battery passport that starts in 2027; its cycle life is therefore carried in the durability section of the product passport instead.

Model or item?

The energy label and the EPREL record are model-level. Phones, meanwhile, are among the best-serialised products in the world: every device has an IMEI and a serial number. That makes a two-layer passport straightforward: label data, repairability class and the parts list at model level; service history, battery replacements and update status at item level. Choosing granularity covers the decision logic, and EPREL and the DPP covers EPREL's role in that structure. How the repairability class is calculated and versioned in the passport is the subject of the EU repairability score.

Preparing as a manufacturer or importer

1. Map the parameters of the EPREL product information sheet onto the passport's model layer.
2. Turn the spare-parts list, prices and the 7-year availability commitment into structured data.
3. Publish the software support end date per model and keep an update history.
4. Bind the IMEI or serial number to the passport identity as the unique identifier.
5. Add the missing fields (materials, substances, carbon) to the supplier data-collection plan.

For the cross-sector calendar see the DPP timeline by sector; for the passport's basic structure, the DPP guide.

Frequently asked questions