Why Electronics Merchants Need to Act Now
February 18, 2027 marks the first mandatory Digital Product Passport requirement under EU regulations: battery passports for electric vehicles, e-bikes, and industrial batteries. This is followed by repairability requirements in 2027 and full electronics DPP implementation in 2028-2029. If you sell any battery-powered products, your deadline is approaching fast.
What You'll Learn
- Battery passport requirements starting February 18, 2027
- Repairability scores and spare parts documentation (2027)
- General electronics DPP requirements (2028-2029)
- Step-by-step compliance checklist for electronics merchants
Timeline: Phased Electronics DPP Implementation
Unlike textiles which have a single implementation date, electronics face a phased rollout starting with batteries in early 2027 and expanding to all electronics by 2029. Here's the official timeline:
First mandatory DPP requirement under EU Battery Regulation. Applies to:
- Electric vehicle (EV) batteries: All EV batteries placed on the market
- Light electric transport (LMT) batteries: E-bikes, e-scooters, electric skateboards
- Industrial batteries >2kWh: Energy storage systems, commercial battery packs
Critical: This is a hard deadline. Products without battery passports cannot be sold in the EU after February 18, 2027. No transition period exceptions.
Repairability rules for electronics are introduced in 2027 under ESPR, including:
- Repairability scores: Standardized scoring system for product repair ease
- Spare parts availability: Minimum 5-7 year availability requirements for key components
- Repair manuals: Public availability of disassembly and repair instructions
General electronics and ICT products enter full DPP scope with comprehensive requirements:
- Material composition: Complete disclosure of materials, including critical raw materials
- Environmental impact: Carbon footprint, energy efficiency, recyclability metrics
- Supply chain traceability: Manufacturer details, component sourcing, certifications
- End-of-life guidance: Recycling information, take-back programs, disposal instructions
Battery Passport Requirements (February 2027)
Battery passports are the first mandatory DPP requirement. Under the EU Battery Regulation, each battery must have a digital passport accessible via QR code or NFC containing comprehensive battery-specific data.
Required Information:
- Unique battery identifier: Serial number or digital ID for each individual battery
- Manufacturer information: Company name, location, manufacturing date and facility
- Battery category: Classification (EV, LMT, industrial, portable, etc.)
- Capacity and power: Rated capacity (kWh), power output, voltage specifications
Material Disclosure:
- Chemistry type: Lithium-ion, lithium-polymer, NiMH, lead-acid, etc.
- Critical raw materials: Cobalt, lithium, nickel content by weight percentage
- Recycled content: Percentage of recycled materials used in production
- Hazardous substances: Disclosure per REACH regulation requirements
Performance Metrics:
- Expected lifetime: Estimated cycles, years of operation, warranty information
- State of health (SOH): Current battery health vs. original capacity
- Carbon footprint: kg CO₂e emissions from battery production (cradle-to-gate)
- Temperature range: Safe operating and storage temperature specifications
Circular Economy Requirements:
- Recycling information: How and where to recycle the battery safely
- Disassembly instructions: Guide for safe battery removal and handling
- Take-back programs: Information on manufacturer collection services
- Safety warnings: Handling precautions, fire risks, chemical hazards
Repairability & Spare Parts Requirements (2027)
In 2027, the EU introduces repairability requirements for electronics to promote product longevity and reduce e-waste. These rules apply to smartphones, tablets, laptops, and consumer electronics.
Products must display a repairability index (0-10 scale) based on:
- Ease of disassembly (tools required, fastener types, accessibility)
- Availability of spare parts and pricing transparency
- Repair documentation quality and public availability
- Product design considerations (modular components, battery replaceability)
Minimum availability periods for key components:
Critical Components (7 years)
- • Batteries
- • Displays/screens
- • Charging ports
- • Main boards
Common Parts (5 years)
- • Buttons and switches
- • Cables and adapters
- • Camera modules
- • Speakers
Public availability required:
- Step-by-step disassembly guides with photos or diagrams
- List of required tools and recommended skill level
- Troubleshooting guides for common issues
- Spare parts catalog with part numbers and pricing
Step-by-Step Compliance Checklist for Electronics Merchants
Battery merchants: You have under 2 years until February 2027. Start gathering battery data now. For general electronics merchants, use this time to prepare for 2028-2029 deadlines.
- Inventory all battery-powered products (Feb 2027 deadline)
- Identify products subject to repairability requirements (2027)
- List all electronics in your catalog (2028-2029 deadlines)
- Contact battery manufacturers for composition, capacity, and chemistry data
- Obtain carbon footprint calculations for battery production
- Document recycled content percentages with certifications
- Gather warranty and expected lifetime data
- Create disassembly guides with photos or video tutorials
- Calculate repairability scores for your products
- Establish spare parts inventory and pricing
- Set up spare parts ordering system for 5-7 year availability
- Choose DPP platform (automated solution like GreenPass recommended)
- Generate unique identifiers for each battery unit
- Create QR codes or NFC tags for battery passport access
- Test passport scanning and data display functionality
- Add QR codes to battery labels or product packaging
- Include repairability scores on product labels (where required)
- Coordinate with suppliers to update packaging before Feb 2027
- Track EU Battery Regulation implementation guidance
- Stay updated on repairability scoring methodology
- Review final electronics DPP delegated acts when published
Automate Electronics DPP with GreenPass
GreenPass DPP helps electronics merchants create compliant battery passports and product DPPs without the manual complexity. Built specifically for Shopify stores.
Battery Passport Ready:
- Battery-specific templates with all required fields
- Material composition and chemistry tracking
- Automatic QR code generation for battery labels
Electronics Features:
- Repairability score calculator and documentation
- Spare parts catalog integration
- Updates automatically as regulations evolve
Join the Waitlist - Lock in €79 Lifetime Access
Be among the first electronics merchants to get GreenPass DPP. Early access members get lifetime access for a one-time payment of €79 (monthly subscription pricing starts later).
✅ Battery passport templates • ✅ Repairability tools • ✅ Priority support
Key Takeaways for Electronics Merchants
- February 18, 2027 is a hard deadline for battery passports - no exceptions or transition period
- Repairability requirements (2027) require spare parts availability for 5-7 years
- Full electronics DPP (2028-2029) includes material composition and environmental data
- Start battery data collection now - manufacturers need time to provide technical specs
- Automated solutions save significant time vs manual battery passport creation
Sources & References
• EU Battery Regulation (2023) - Battery passport requirements and timeline
• European Commission ESPR Working Plan (2025) - Electronics category designation
• EU Right to Repair Directive - Repairability scoring and spare parts requirements
• Industry consultations on electronics DPP implementation
• Official EU regulatory documentation and guidance for battery passports