Redesigning electronics for traceability and compliance
The EU’s new Ecodesign rules are reshaping electronics. Digital Product Passports will force traceability and repairability into every design.
IN Brief:
ESPR came into force in July 2024, with Digital Product Passports (DPPs) central to the regulation.
Electronics and ICT products face phased-in DPP obligations between 2028 and 2029, with mobiles and tablets by 2030.
Manufacturers must embed lifecycle, repairability, and recycling data into products — seen by some as burden, others as opportunity.
The Ecodesign for Sustainable Products Regulation (ESPR) entered EU law in July 2024, replacing the long-standing Ecodesign Directive. It marks a decisive shift away from narrow energy-efficiency requirements and towards a comprehensive framework governing how products are designed, documented, and disposed of.
At the centre of this shift is the Digital Product Passport (DPP), a digital identity that will follow physical goods through their lifecycle. For electronics manufacturers, it will mean embedding traceability and repairability obligations into devices that have historically prioritised form factor and cost over long-term sustainability.
The European Commission’s first ESPR Working Plan, published in April 2025, confirmed electronics and ICT as priority categories. A central EU registry for DPP data is due online by mid‑2026, with technical standards expected from CEN and CENELEC by the end of this year. Delegated acts will then trigger specific requirements, generally allowing 18 months before obligations bite. Deadlines for electronics fall between 2028 and 2029, with mobile phones and tablets included by 2030.
The impact is likely to be felt most acutely at the design stage. Engineers will need to consider how lifecycle data is captured, stored, and shared. Repairability, recycled content, and modular construction will no longer be optional features but regulated requirements. That creates practical headaches for an industry heavily reliant on complex global supply chains.
Dunstan Power, Director at ByteSnap Design, sees this as the central challenge: “The main challenge lies in integrating systems and standardising data throughout the supply chain. A typical electronic device is made up of components sourced from numerous suppliers worldwide. Coordinating all these diverse systems to communicate and exchange data in a standardised and verifiable way poses a substantial challenge. The expenses and intricacies associated with establishing a robust, traceable data infrastructure capable of monitoring a product from its raw materials to its end-of-life stage will be the key hurdle for many manufacturers.”
Power’s assessment highlights a problem regulators have long understood: sustainability requirements cannot be met at the level of the finished product alone. They demand upstream data integration, pulling in everything from raw materials and sub‑assemblies to logistics footprints. For large OEMs this may be a solvable systems challenge, but for SMEs in the electronics sector, it risks creating barriers to entry.
Despite the complexity, some companies are already embedding DPP preparation into their design workflows. “At ByteSnap Design, we're helping electronics manufacturers prepare for DPP regulations by incorporating forward-looking design principles right from project start,” Power says.
“We are educating clients on the importance of designing products with traceability and repairability in mind to align with the EU's Ecodesign for Sustainable Products Regulation. Our main emphasis is on integrating the essential data structure and hardware capabilities into new electronic products, streamlining the process for manufacturers to gather, handle, and exchange the necessary lifecycle information.”
Where ByteSnap focuses on design integration, TSC Auto ID sees compliance pressures converging with advances in labelling and identification technologies.
Bob Vines, the company’s Country Manager for the UK, Ireland and Nordics, points to the wider compliance environment:
“There are a number of digital compliance initiatives on the horizon and, if we just look at Sunrise 2027 where, by the end of 2027, retailers globally need to ensure their POS systems are equipped with scanners able to read both traditional and 2D barcodes, then the latest we understand about firms transitioning to GS1 Digital Link barcodes is that Unilever, Procter and Gamble and L’Oreal all have large scale roll-outs, while Tesco is piloting the technology in the UK on some of its own fresh label lines. One thing that is becoming apparent in meeting regulations like Sunrise 2027 is the importance of barcode readability, there’s no tolerance for errors, which is driving an increase in sales of verification systems.”
For Vines, the connection to ESPR is clear. “With requirements for the Digital Product Passport (DPP) expected as early as 2027, and compliance due in 2028 to the US’s Food Traceability Rule, only item-level identification such as that offered by smart labels like 2D barcodes and RFID will enable businesses to efficiently fulfil their new traceability obligations.”
This is not just about compliance. As Vines notes, “Automatic identification and data capture (AIDC) technologies are becoming key enablers of both digital compliance and the green transition. From reducing consumable waste to embedding compliance and lifecycle transparency into every label, scanning and labelling now sits at the heart of smarter, more compliant and sustainable businesses.”
The contrast between ByteSnap’s design focus and TSC’s labelling perspective underscores the breadth of the challenge. Designers must build the data hooks in from the outset, while supply-chain technology providers must deliver the infrastructure to make that data usable and verifiable across borders. Both ends of the electronics lifecycle are being forced to converge around traceability.
The next milestones come quickly. Harmonised technical standards are due before the end of 2025, the EU registry must be live by 2026, and delegated acts for electronics could appear soon after. That leaves little margin for businesses waiting to see the final detail before acting.
For Power, the question of whether DPPs prove a benefit or a burden is still open. “While there is potential for gaining a competitive edge, our view is that DPPs will initially present a significant compliance challenge for many industry players. Setting up the necessary data collection and integration systems will take considerable effort. For smaller firms, this could become a market entry barrier. The anticipated benefits of enhanced customer trust and repairability will only materialise if the framework is smoothly implemented and if customers actively engage with the provided data. The interim focus will be on meeting the regulatory standards rather than exploiting them for business advantages.”
The European Commission’s intention is to hard-wire circular economy principles into electronics and other product categories. Whether businesses view this as a costly compliance exercise or a chance to differentiate on repairability and lifecycle transparency remains to be seen. But with the registry countdown already ticking, inaction is not an option. Electronics companies that wait risk finding themselves cornered by deadlines that arrive faster than anticipated.