Electronics and ICT sit in an odd position under ESPR. There is no product-specific DPP delegated act scheduled for the sector yet — but electronics was studied early, already carries more EU product data obligations than almost any other category, and the batteries inside some devices are caught by a passport rule with a hard 2027 date. For EU importers of non-EU-made electronics, "no deadline yet" is not the same as "nothing to do".
ESPR (Regulation (EU) 2024/1781) rolls out per product group through delegated acts, and the first working plan of April 2025 put textiles, furniture, tyres, iron & steel and aluminium at the front of the queue — not consumer electronics. So there is currently no scheduled delegated act that would give phones, laptops or network equipment their own product passport, and any claim of a fixed electronics DPP date is speculation.
Two caveats stop this being a reason to relax. First, the working plan includes horizontal requirements — repairability and recyclability rules that can cut across product groups, and electronics is the textbook candidate. Second, the sector already lives under ecodesign and energy-labelling rules, so the regulatory groundwork — product data, registration habits, technical documentation — exists. When electronics is picked up in a later working plan, the step to a full DPP is shorter than for most sectors, and obligations typically bite around 18 months after a delegated act enters into force.
One part of the electronics import business is not waiting for ESPR at all. The Batteries Regulation (EU) 2023/1542 applies to batteries incorporated into products, and from 18 February 2027 a battery passport is mandatory for every EV battery, every LMT battery (e-bikes, e-scooters, e-mopeds — no capacity threshold) and every industrial battery above 2 kWh.
For an ICT importer that catches more than you might expect: UPS systems and rack-mounted backup power above 2 kWh, energy-storage units bundled with equipment, e-mobility electronics. If the device you import contains an in-scope battery, you are placing that battery on the EU market and the passport duty is yours. Ordinary portable batteries — laptops, phones, tablets, power tools — are outside the passport’s scope, though they keep their labelling and collection rules.
Because your manufacturers sit outside the EU, the economic-operator role lands on you. That is already true for CE marking, RoHS, REACH and WEEE, and it will be true for any electronics DPP: the operator placing the product on the EU market ensures the required data record exists, is accurate and stays accessible. Contracts can oblige your factory to supply data; they cannot move the legal responsibility.
Practically, this means the importer needs a repeatable way to pull evidence out of suppliers — spec sheets, declarations, test reports — and keep it current across firmware revisions, component swaps and factory changes. Importers who build that pipe once answer every new obligation from the same desk; importers who don’t start a document chase per regulation.
Electronics is the rare sector where a future DPP is mostly an assembly problem, not a data-creation problem. Substance restrictions (RoHS), chemical declarations (REACH), take-back registration (WEEE), energy-label values and ecodesign technical files together cover much of what a passport would ask for — identity, materials, substances of concern, end-of-life information. The problem is that it lives in dozens of PDFs across supplier inboxes.
That is the gap PassPer closes: AI extraction reads the documents you already hold, maps them into one structured record per product with human review, and publishes it behind a GS1 Digital Link QR with an eIDAS qualified seal when an obligation lands. Start with the products that carry in-scope batteries — those have a real 2027 date — and run a free readiness check to see where your portfolio stands.
Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.