Digital product passport for electronics: what applies to devices and built-in batteries?

Legal basis: ecodesign by product group

Article 18(5) ESPR names energy-related products as well as information and communication technology products and other electronics as priorities. The working plan COM(2025) 187 implements this in two ways: with horizontal rules for many devices and with acts for individual energy-related products.

The working plan also says that for products with an energy label, the product database EPREL can take the place of the passport (section 3.2). Article 9(4)(b) ESPR allows this exemption where other Union law includes an equivalent digital system. For 19 product groups, such as computers, servers and external power supplies, provisions of the old Directive 2009/125/EC continue to apply instead of the corresponding ESPR articles until 31 December 2026 (Art. 79(1)(a)(i) ESPR). Existing implementing measures stay in force until a delegated act under the ESPR repeals them (recital 121).

Timeline with status

The years from the working plan are provisional years of adoption. A duty as a rule starts no earlier than 18 months after the act enters into force (Art. 4(4) ESPR).

The battery inside the device

The Battery Regulation also covers batteries incorporated into appliances (Art. 1(3)). From 18 February 2027 every battery carries a QR code. For portable batteries it leads to the label information, the declaration of conformity and waste battery information, not to a passport. Only LMT batteries, electric vehicle batteries and industrial batteries with a capacity above 2 kWh need a battery passport (Art. 77(1)).

Whoever places appliances with an incorporated portable battery on the market has to make it removable and replaceable by the end-user from 18 February 2027, with the exceptions in Article 11(2). What has to be behind the code is covered in the guide Battery QR code from 18 February 2027.

Which data is fixed

For electrical equipment in general, none yet. Regulation (EU) 2023/1670 for smartphones and slate tablets does not mention a product passport; for the technical documentation it refers to the product database. A later act selects from Annex III ESPR: product identifier, GTIN, compliance documentation, instructions, details of the manufacturer and the importer.

For products with digital elements, documentation duties under the Cyber Resilience Act are added from 11 December 2027. That is not a product passport, see Cyber Resilience Act: documents and deadlines.

What you can do today

• List every device with a built-in battery and assign the battery to a category.
• Agree with your battery supplier who provides and maintains the battery’s QR code.
• Check whether your device carries an energy label and is registered in EPREL.
• Keep declarations of conformity, instructions and spare part information per model, with versions.
• Follow the horizontal rule on repairability. According to the working plan, its scope could include consumer electronics and small household appliances.

Further reading

• The product passport module: permanent address, QR code and documents per product
• The basics in the guide Digital product passport: deadlines and product groups
• Every date per product group in the deadline tracker
• All industries at a glance: product passport by industry

Frequently asked questions