The European regulatory framework on product sustainability has been profoundly transformed over the past two years. Between the entry into force of the ESPR in July 2024, the revision of the CPR and the gradual rollout of the Digital Product Passport (DPP), manufacturers of electrical and electronic equipment (EEE) face increasingly precise — and increasingly imminent — obligations.
This article gives you a clear reading of these three regulations, their interactions and the concrete actions to undertake today.
Three regulations, one shared objective: environmental transparency
The European Union has structured its product sustainability policy around three complementary texts:
- The ESPR (Ecodesign for Sustainable Products Regulation), adopted in July 2024, which replaces the 2009 Ecodesign directive and applies 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 tool stemming from the ESPR, whose rollout is planned between 2027 and 2030 by product category.
These three texts reinforce one another. And at the heart of each of them is a common requirement: the declaration of verified environmental data, based on a Life Cycle Assessment (LCA).
The ESPR: much more than a simple update of Ecodesign
A broadened scope
The old Ecodesign directive focused essentially on energy efficiency. The ESPR goes much further. It introduces minimum performance requirements (MPRs) covering durability, repairability, recyclability, recycled content, carbon footprint and substances of concern.
For EEE equipment, this means in particular: declaring the carbon footprint over the full life cycle of the product; guaranteeing the availability of spare parts and ease of disassembly; declaring SVHC substances present above 0.1% (m/m).
A tight timeline for electronics
The ESPR works by sectoral work plans. Electronic devices are among the priority categories from 2025-2026. EEE manufacturers do not have the luxury of waiting.
The ban on destroying unsold goods
From 2026, the ESPR prohibits the destruction of unsold goods for electronics. Companies will have to declare annually the volumes of products destroyed and the measures undertaken to reduce them.
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 revision of the CPR is a strong signal.
The new version expected for 2025-2026 makes EPDs (Environmental Product Declarations) mandatory as information to be provided for the CE marking of construction products. The DPP also becomes mandatory for this sector by 2028. Concretely: a manufacturer that has not yet started its EPD certification process is falling behind.
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 gathers the identification of the product and manufacturer, the composition (materials, SVHC, recycled share), environmental performance (LCA, carbon footprint, circularity score), repairability and end-of-life data, as well as certifications and declarations (CE, EPD, labels).
The timeline for electronics
For EEE equipment, the DPP is expected between 2027 and 2028. This timeframe may seem comfortable — it is not. Building the DPP rests on robust LCA data and certified EPDs, whose production process takes on average 12 to 24 months.
The LCA and the EPD: the foundation of all compliance
Why LCA is essential
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. Without LCA, no EPD. Without EPD, no compliant DPP. And without DPP, no access to the European market from 2027-2028.
The EPD: the document that makes data enforceable
The Environmental Product Declaration (EPD) is the standardised document (ISO 14025 / EN 15804+A2) that formalises and makes public the results of the LCA. Its certification process comprises five steps:
- Defining the system and collecting the inventory data (LCI)
- Calculating the impact indicators according to EN 15804+A2 (GWP, ODP, AP, EP, POCP, ADP…)
- Writing the declaration according to the applicable PCR format
- Independent verification by an accredited body (COFRAC or equivalent)
- Registration with a recognised EPD programme (EPD International, INIES, IBU…)
An EPD is valid for 5 years. Any significant change of composition or process requires an update.
The 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) specific to the different families of EEE equipment and is recognised by the main European buyers, notably in the construction and energy sectors.
In 2025, more than 2,000 new PEP declarations were registered (+10% vs 2024), and more than 9,000 new EPDs were published on the International EPD System. These figures reflect an accelerating market dynamic.
What companies still underestimate
The complexity of LCA
Carrying out an LCA is not just filling in a table. The modelling requires reconciling heterogeneous data from dozens of suppliers, mastering the PSR/PCR rules specific to each product category, and configuring specialised software. A material-mapping error or a poorly applied scenario can invalidate the entire declaration.
The greenwashing risk
The ESPR regulation and the Green Claims directive (being finalised) severely penalise unfounded 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 to produce an EPD
Between data collection, modelling, verification and registration, a certified EPD takes on average 12 to 18 months. Companies that have not yet initiated this process for their priority products take a real risk of being non-compliant by the regulatory deadline. By automating the modelling and data-reconciliation steps, Qweeko significantly reduces this timeframe, without compromising on reliability or regulatory compliance.
Conclusion: LCA is no longer optional
ESPR, revised CPR, DPP: these three texts converge towards the same conclusion. For EEE manufacturers, producing certified LCAs and PEP/EPD declarations is no longer a voluntary step; it is becoming a regulatory prerequisite to keep selling on the European market.
It is precisely to meet this challenge that Qweeko was designed. Our platform automates LCA modelling and the generation of PEPs and EPDs, and our experts support you according to your needs. The result: your environmental declarations are produced faster and compliant with the regulatory requirements in force.