The EU's Ecodesign for Sustainable Products Regulation will require machine-readable passports for a widening range of products — electronics included. It rewrites what 'knowing your assets' means.
The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) entered into force in July 2024 and extends ecodesign thinking far beyond energy efficiency. Its signature instrument is the Digital Product Passport (DPP): a structured, machine-readable dataset describing a product's composition, durability, repairability, recycled content and recyclability.
The DPP is being introduced product group by product group through delegated acts and a working plan, with batteries leading and priority categories — including electronics and ICT — following. For an industry that moves millions of devices and network components, this turns product data from an internal nicety into a market-access requirement.
The organisations that will find the DPP easiest are those already treating asset data as infrastructure: resolving every item to a verified identity, holding its material composition and condition, and keeping an evidence trail. The passport then becomes an output of good data hygiene rather than a scramble.
There is upside beyond compliance. The same passport data that satisfies a regulator also powers valuation, reuse matching and carbon accounting. A shared intelligence layer that already structures asset data — the role Cirveris is building for telecom circularity — is precisely the foundation a passport regime demands.
The Digital Product Passport is often described as a QR code, but the QR code is only the access point. The real change is the expectation that a product's sustainability and circularity data can be discovered, read and trusted by different actors across the value chain. That means product identity, materials, repair information, recycled content and end-of-life instructions move from static PDFs into structured data.
Telecom and IT hardware is fragmented across OEMs, variants, regions and product generations. Waiting for a delegated act to make a category mandatory leaves too little time to normalise legacy assets. The better strategy is to build passport-ready asset intelligence now: collect product identifiers, datasheets, materials evidence, repairability notes, security status and disposition history in a consistent structure.
A product passport can do more than satisfy regulators. The same structured data helps buyers trust second-life equipment, helps recyclers plan material recovery, helps operators forecast value and helps sustainability teams produce evidence-backed reports. In other words, the DPP is not only a compliance burden; it is a market infrastructure layer for circular hardware.
A common mistake is to treat the Digital Product Passport as a separate compliance database. In practice, the passport should be generated from the same trusted product and asset data that supports operations, valuation and reporting. That means the source of truth sits inside the company's asset intelligence layer, while passport fields are published or exposed as required.
This avoids duplication. If the same product identity powers procurement, maintenance, resale, carbon reporting and passport disclosure, then every operational improvement also improves compliance readiness. If passport data is managed separately, it becomes stale quickly.
Operators and refurbishers should start asking vendors for structured product data now. The strongest suppliers will be those that can provide part hierarchies, materials declarations, repair instructions, software constraints and end-of-life guidance in usable formats. Over time, product-data quality will become a supplier-performance issue, because poor data raises the cost of compliance and weakens circular outcomes.
This article is provided for general information and does not constitute legal, regulatory, or financial advice. Regulatory timelines and requirements should be verified against the primary sources cited.
Cirveris turns fragmented telecom asset data into value, carbon and audit-ready evidence.
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