Electronics
Where WEEE, RoHS and REACH Meet the DPP
How WEEE, RoHS and REACH obligations for electrical and electronic equipment intersect with the Digital Product Passport, and how to manage shared data.
Compliance for electrical and electronic equipment (EEE) rested on three regimes long before the DPP: RoHS (restricted substances), REACH (chemical notification) and WEEE (waste management and recovery). The Digital Product Passport brings their data into a single record.
Three regimes, one data set
| Regime | What it requires | Passport equivalent |
|---|---|---|
| RoHS | Restricted substances below thresholds | Hazardous substance declaration |
| REACH / SCIP | SVHC notification and article registration | Substance presence and concentration |
| WEEE | Collection, recovery, information provision | Separation and recycling information |
See DPP for chemicals, REACH and SCIP and DPP data fields.
WEEE's information duty
WEEE requires producers to provide separation information for treatment facilities: where each component sits and how hazardous parts (batteries, capacitors, displays) are removed. Today that is usually shared as a PDF manual; a passport makes it structured and machine-readable.
See circularity and recyclability and extended producer responsibility.
ESPR's horizontal EEE measure
Listed with an indicative 2029 in the Working Plan, this measure introduces recycled content and recyclability requirements for EEE, adding material circularity on top of the substance focus of RoHS and REACH. See the ESPR working plan.
The repairability link
The horizontal repairability score (indicative 2027) hits electronics directly: spare parts, disassembly steps, software support duration. See the Right to Repair Directive and DPP for home appliances.
Preparation steps
- Consolidate your RoHS conformity file and SCIP records in one data source.
- Move the separation manual into structured fields.
- Build a module-level material breakdown. See preparing a bill of materials.
- Record software support duration and spare part availability periods.
Frequently asked questions
Is my RoHS declaration enough for the passport?
It covers a large part of the substance fields, but the passport also wants composition, circularity and repair data.
Will WEEE registrations appear in the passport?
Producer registration numbers and EPR information can be carried; separation information goes directly into circularity fields.
Electronics has thousands of components — must I declare them all?
No. A threshold-based declaration plus a focus on critical substances is the practical approach. See DPP for electronics.
