ESPR, RPC, Digital Product Passport: What EEE equipment manufacturers need to know in 2026

The European regulatory framework on product sustainability has undergone a profound transformation over the past two years. With the ESPR entering into force in July 2024, the ongoing revision of the CPR, and the gradual rollout of the Digital Product Passport (DPP), manufacturers of electrical and electronic equipment (EEE) are facing increasingly precise  and increasingly imminent obligations.

This article gives you a clear overview of these three regulations, how they interact, and the concrete actions to take today.

Three regulations, one shared goal: environmental transparency

The European Union has built its product sustainability policy around three complementary pieces of legislation:

• The ESPR (Ecodesign for Sustainable Products Regulation), adopted in July 2024, replacing the 2009 Ecodesign Directive and applying to almost all physical products, including electronic equipment.
• The CPR (Construction Products Regulation), currently under revision, which will integrate strengthened environmental requirements by 2027-2028.
• The DPP (Digital Product Passport), a cross-cutting traceability tool stemming from the ESPR, to be rolled out between 2027 and 2030 by product category.

These three texts reinforce one another. And at the heart of each lies a common requirement: the declaration of verified environmental data, based on a Life Cycle Assessment (LCA).

The ESPR: far more than an Ecodesign update

A broader scope

The former Ecodesign Directive focused primarily on energy efficiency. The ESPR goes much further. It introduces minimum performance requirements (MPRs) covering durability, repairability, recyclability, recycled material content, carbon footprint, and substances of concern.

For EEE manufacturers, this means in particular:

• Declaring the carbon footprint over the product's full life cycle
• Ensuring the availability of spare parts and ease of disassembly
• Declaring SVHC substances present above 0.1% (w/w)

A tight timeline for electronics

The ESPR operates through sectoral working plans. Electronic appliances are among the priority categories from 2025-2026. EEE manufacturers cannot afford to wait: the European Commission will move on these categories first.

The ban on destruction of unsold goods

From 2026, the ESPR bans the destruction of unsold goods for electronics. Companies will be required to report annually on the volumes of products destroyed and the measures taken to reduce them.

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The CPR under revision: EPDs become mandatory for construction

For manufacturers whose equipment is integrated into buildings (HVAC systems, building management equipment, charging stations…), the CPR revision is a strong signal.

The new version expected for 2025-2026 makes EPDs (Environmental Product Declarations) mandatory as required information for CE marking of construction products. The DPP also becomes mandatory for this sector by 2028.

In practice: a manufacturer who has not yet initiated their EPD certification process is already falling behind.

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The Digital Product Passport: the backbone of transparency

What is the DPP?

The DPP is a structured set of data linked to a unique identifier (QR code, NFC, RFID), accessible throughout the product's life cycle. It includes:

• Product and manufacturer identification
• Composition (materials, SVHCs, recycled content)
• Environmental performance (LCA, carbon footprint, circularity score)
• Repairability and end-of-life data
• Certifications and declarations (CE, EPD, labels)

The timeline for electronics

For EEE, the DPP is expected between 2027 and 2028. This timeline may seem comfortable; it is not. Building the DPP relies on robust LCA data and certified EPDs, whose production process takes on average 12 to 24 months.

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LCA and EPD: the foundation of all compliance

Why LCA is unavoidable

Life Cycle Assessment is the reference methodology required by all of these regulations. It covers modules A1 to D: raw material extraction, manufacturing, transport, use, end of life, and recycling benefits.

No LCA, no EPD. No EPD, no compliant DPP. And no DPP means no access to the European market from 2027-2028.

The EPD: the document that makes data legally enforceable

The Environmental Product Declaration (EPD) is the standardised document (ISO 14025 / EN 15804+A2) that formalises and publishes LCA results. Its certification process involves five steps:

1. System definition and inventory data collection (LCI)
2. Impact indicator calculation according to EN 15804+A2 (GWP, ODP, AP, EP, POCP, ADP…)
3. Declaration drafting according to the applicable PCR format
4. Independent verification by an accredited body (COFRAC or European equivalent)
5. Registration with a recognised EPD programme (EPD International, INIES, IBU…)

An EPD is valid for 5 years. Any significant change in composition or manufacturing process requires an update.

PEP ecoPassport: the EPD standard specific to EEE

For electrical and electronic equipment, the PEP ecoPassport programme is the reference EPD framework. It defines the PSR (Product Specific Rules) for the various EEE product families and is recognised by major European buyers, particularly in the construction and energy sectors.

In 2025, over 2,000 new PEP declarations were registered (+10% vs 2024), and over 9,000 new EPDs were published on the International EPD System. These figures reflect an accelerating market dynamic.

The compliance roadmap

For an EEE manufacturer, achieving compliance with these regulations follows a logical sequence:

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What companies still underestimate

The complexity of LCA

Conducting an LCA is not simply a matter of filling in a spreadsheet. The modelling requires reconciling heterogeneous data from dozens of suppliers, mastering the PCR/PSR rules specific to each product category, and working with specialised software. A material mapping error or a misapplied scenario can invalidate the entire declaration.

The greenwashing risk

The ESPR and the Green Claims Directive (currently being finalised) impose severe penalties for unsubstantiated environmental claims. Any data published in a DPP must be verifiable and up to date. Market surveillance authorities will have the means to check the consistency between the declared DPP and the product's actual characteristics.

The time it takes to produce an EPD

From data collection to modelling, verification and registration, a certified EPD traditionally takes 12 to 18 months. By automating the modelling and data reconciliation steps, Qweeko significantly reduces this timeframe without compromising reliability or regulatory compliance.

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Conclusion: LCA is no longer optional

ESPR, revised CPR, DPP: these three texts converge on the same conclusion. For EEE manufacturers, conducting certified LCAs and producing PEP/EPD declarations are no longer voluntary differentiation initiatives, they are becoming regulatory prerequisites for continuing to sell on the European market.

This is precisely the challenge Qweeko was built to address. Our platform automates LCA modelling and the generation of PEP and EPD declarations, and our experts support you according to your needs.

The result: your environmental declarations are produced faster and in full compliance with current regulatory requirements.

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