The Digital Product Passport and Home Appliances — A Regulatory Research Dossier

1. Executive summary

No Digital Product Passport obligation applies to home appliances today, and none is scheduled in the first wave of the Ecodesign for Sustainable Products Regulation. The ESPR — Regulation (EU) 2024/1781, in force since 18 July 2024 — is a framework. It binds a product group to a DPP only once a product-specific delegated act is adopted and becomes applicable, and that act cannot apply earlier than 18 months after its entry into force. The Commission's ESPR Working Plan 2025–2030 (COM(2025) 187 final, 16 April 2025) places iron and steel, textiles, tyres, aluminium, furniture and mattresses in the first wave; home appliances are not among the product-specific priorities. Washing machines, dishwashers, refrigerating appliances, tumble dryers, cooking appliances and vacuum cleaners remain under their existing ecodesign and energy labelling regulations, carried over on revision tracks.

What already binds manufacturers today is the data layer underneath a passport: the resource-efficiency and spare-parts duties of the 2019 ecodesign package and the 2023 tumble-dryer rules; mandatory model registration in EPREL under Regulation (EU) 2017/1369; the repair obligations of Directive (EU) 2024/1799; SCIP notifications of substances of very high concern; RoHS material conformity; WEEE marking and producer financing; and, for appliances with portable batteries, Regulation (EU) 2023/1542. These duties already require manufacturers to hold, at model level, most of the data families a future appliance DPP will draw on.

Meanwhile the DPP infrastructure has moved from text to operation. The EU DPP registry required by Art. 13 ESPR has been live since 20 July 2026, governed by Commission Implementing Regulation (EU) 2026/1778. Six of the eight European DPP standards developed by CEN-CLC/JTC 24 were cited in the Official Journal on 15 July 2026 by Commission Implementing Decision (EU) 2026/1736, giving presumption of conformity with the DPP requirements of Arts. 10 and 11 ESPR. The remaining two standards — access rights and security; data authentication, reliability and integrity — have been available since 16 September 2026 and await citation.

At a glance

Sources: Regulation (EU) 2024/1781 (EUR-Lex, consolidated text); COM(2025) 187 final; Commission Implementing Regulation (EU) 2026/1778; Commission Implementing Decision (EU) 2026/1736. Full references in section 18.

How the dossier is organised

Sections 2 to 4 describe the ESPR framework, the Working Plan and the technical architecture of the passport as they stand. Sections 5 to 11 map, category by category and file by file, the data obligations that already apply to appliances: ecodesign, energy labelling and EPREL, the right to repair, the French indices, substances, WEEE and batteries. Section 12 sets this against APPLiA's own public positions. Sections 13 to 15 synthesise the result into a DPP Map, a worked example at model level and a list of the data to structure now. Section 16 consolidates all dates; section 17 lists every point the dossier could not settle; section 18 lists the sources.

2. The ESPR framework

Regulation (EU) 2024/1781 of the European Parliament and of the Council establishing a framework for the setting of ecodesign requirements for sustainable products — the ESPR — entered into force on 18 July 2024. It replaces the product-group-by-product-group logic of Directive 2009/125/EC with a horizontal framework under which the Commission adopts delegated acts setting, for each product group, performance requirements (durability, repairability, recycled content, substances, environmental footprint) and information requirements, including the Digital Product Passport. The Regulation itself imposes no DPP obligation on any product group: every DPP duty flows from a delegated act adopted under Art. 4 and from the general requirements of Arts. 9 to 15.

2.1 Scope and exclusions (Art. 1)

The ESPR applies to almost all physical goods placed on the EU market. Art. 1 excludes food, feed, medicinal products, live plants and animals, products of human origin, and vehicles for the aspects covered by sectoral type-approval law. Home appliances fall squarely within scope. Their current ecodesign and labelling rules, however, were adopted under Directive 2009/125/EC and Regulation (EU) 2017/1369 and remain in force under the transitional regime described in section 2.13; ESPR-specific requirements will reach them only through new delegated acts.

2.2 "Substance of concern" (Art. 2(27))

The definition in Art. 2(27) is the one future delegated acts will use for substance tracking in a DPP. It is broader than any single chemicals instrument and is built in four limbs:

Limbs (a) to (c) are list-based and can be matched against existing supplier declarations, SCIP notifications and RoHS conformity files (section 9). Limb (d) is functional: it captures substances that hinder recycling regardless of their hazard classification, and its application to a given appliance component will depend on what the delegated act specifies.

2.3 Key definitions (Art. 2(28)–(33))

Art. 2(29) is not reproduced in this dossier; the five definitions above are the ones on which Arts. 9 to 15 and Annex III rest.

2.4 Delegated acts and the 18-month rule (Art. 4)

Art. 4 empowers the Commission to adopt delegated acts laying down ecodesign requirements per product group. It also lays down the timing rule that governs every future appliance DPP: the date of application of a delegated act shall not be earlier than 18 months from its entry into force, except in duly justified cases. For planning purposes this means that, from the day an appliance-specific act is published in the Official Journal, a manufacturer has at least a year and a half before a DPP becomes a condition for placing products on the market. The delegated act is also where every product-specific choice is made: which Annex III data elements are required, whether the passport refers to model, batch or item, which actors have which access rights, and for how long the passport must remain available.

2.5 The DPP as a condition for placing on the market (Art. 9)

Art. 9 provides that products covered by a delegated act requiring a DPP may be placed on the market or put into service only if a DPP is available in accordance with that act and with Arts. 10 and 11. The data in the passport must be accurate, complete and up to date. This formulation matters operationally: the passport is not a one-off document generated at launch but a maintained data set, and the responsibility for its accuracy over time rests with the economic operator.

2.6 Requirements for the DPP (Art. 10)

Art. 10 sets the general requirements that every DPP must satisfy, regardless of product group:

• Data carrier and identifier. The passport is connected through a data carrier to a persistent unique product identifier. The data carrier must be physically present on the product, on its packaging or on the documentation accompanying the product, as specified in the delegated act.
• Standards. The data carrier and the unique product identifier must comply with the standards referred to in the second paragraph of Annex III (the ISO/IEC 15459 family, section 4.3) or with equivalent standards until references to harmonised standards are cited in the Official Journal.
• Open, machine-readable data. All information in the passport must be based on open standards, developed with an interoperable format, and be machine-readable, structured, searchable and transferable through an open interoperable data exchange network without vendor lock-in, in accordance with the essential requirements of Arts. 10 and 11.
• Personal data. Art. 10(1)(e): personal data relating to the customer may not be stored in the DPP without the customer's explicit consent in accordance with the GDPR.
• Granularity. The passport refers to the model, the batch or the individual item, as specified in the delegated act.
• Dealer copy — Art. 10(3). The economic operator placing the product on the market must provide dealers and online marketplaces that sell the product with a digital copy of the data carrier or of the unique product identifier, free of charge, promptly and in any event within five working days of a request.
• Back-up — Art. 10(4). A back-up copy of the passport must be held through a DPP service provider (an independent third party), to guarantee that the data survive the operator's own systems.

2.7 Technical design and operation (Art. 11)

Art. 11 governs how passports must work across the market:

• Interoperability. Full technical, semantic and organisational interoperability between passports, data carriers and the data exchange network.
• Access. Free access, according to the access rights set in the delegated act, for customers, manufacturers, importers, distributors, dealers, professional repairers, independent operators, refurbishers, remanufacturers, recyclers, market surveillance authorities and customs authorities.
• Storage. The data are stored by the economic operator responsible for the product or by DPP service providers authorised to act on its behalf — not centrally by the Commission.
• Linkage. Where a new passport is created for a product that already has one (for example after remanufacturing), the new passport must link to the original.
• Persistence. The passport remains available for the period set in the delegated act, including after an insolvency, a liquidation or a cessation of activity of the economic operator — the reason the back-up copy and the service-provider role exist.
• Integrity. Rights to introduce, modify or update data are restricted to the actors the delegated act authorises; data authentication, reliability and integrity must be ensured.
• Service-provider limits. DPP service providers may not sell, re-use or process the data beyond what is necessary to provide the storage and processing service.
• Certification. The Commission may set requirements for DPP service providers and establish a certification scheme for them.

2.8 Unique operator and facility identifiers (Art. 12)

The unique operator identifiers and unique facility identifiers referred to in Annex III points (g), (h) and (i) must comply with the first paragraph, point (c), and the second paragraph of Annex III — that is, with the ISO/IEC 15459 family or equivalent standards. Delegated acts will govern the issuing agencies and the conditions under which economic operators may issue their own identifiers. For an appliance group, the operator identifier would typically attach to the manufacturer, to importers and to the responsible EU operator; facility identifiers to the plants and sites associated with the product, to the extent the delegated act requires them.

2.9 The DPP registry (Art. 13)

Art. 13 provides that "by 19 July 2026, the Commission shall set up a digital registry" that stores securely at least the unique identifiers; for products released for free circulation, also the commodity code; and the unique battery identifiers under Art. 77(3) of Regulation (EU) 2023/1542. The economic operator uploads the data; the registry automatically issues a unique registration identifier. Art. 13(5) empowers the Commission to adopt an implementing act laying down the registry arrangements — this is Commission Implementing Regulation (EU) 2026/1778 (section 4.1). The registry stores identifiers, not passport content: the data themselves remain with the operator or its service provider.

2.10 Public portal (Art. 14)

Art. 14 provides for a public web portal allowing stakeholders to search and compare the data contained in passports, consistent with the access rights set in the delegated acts. The portal is under development (section 4.1).

2.11 Customs controls (Art. 15)

Under Art. 15 the declarant provides the unique registration identifier to customs; customs verify it against the registry through the EU Customs Single Window Certificates Exchange System (EU CSW-CERTEX). The interconnection between the registry and the Single Window must be operational within four years of the Art. 13(5) implementing act. For appliance importers, the practical implication is that a DPP-covered product without a registration identifier would in time be stopped at the border — but only once a delegated act covers the product.

2.12 Unsold consumer products (Arts. 24–25, Annex VII)

Art. 24 imposes disclosure duties on economic operators that discard unsold consumer products: the number and weight of products discarded per year and the reasons, in a format laid down by Commission Implementing Regulation (EU) 2026/2. Art. 25 prohibits the destruction of unsold consumer products in the categories listed in Annex VII. Commission Delegated Regulation (EU) 2026/296 operationalises the prohibition; the first wave covers apparel, clothing accessories and footwear, with large enterprises bound from 19 July 2026. Home appliances are not listed in Annex VII today. The disclosure duty of Art. 24 is horizontal and should be checked against each company's own practices; the destruction ban is not an appliance issue at present and is noted here only to delimit it.

Sources: Regulation (EU) 2024/1781, Arts. 1, 2, 4, 9–15, 24–25, Annexes III and VII; Implementing Regulation (EU) 2026/2; Delegated Regulation (EU) 2026/296.

2.13 Annex III — the data-element menu

Annex III lists the information that delegated acts may require in a passport. It is a menu, not a mandatory list: each act selects. For an appliance manufacturer the value of the table lies in the right-hand column — nearly every element already exists in some form.

The second paragraph of Annex III names the standards for data carriers and identifiers: ISO/IEC 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014 and 15459-6:2014. These are discussed in section 4.3.

2.14 Transitional regime for the ex-Directive product groups

For the 19 product groups formerly regulated under Directive 2009/125/EC, the existing implementing measures continue to apply under the Directive framework until 31 December 2026. This transitional regime is why the appliance regulations described in section 5 — the 2019 package for refrigerating appliances, washing machines, washer-dryers and dishwashers, the 2023 tumble-dryer rules, the 2013–2014 rules for vacuum cleaners and cooking appliances, and the 2023 standby rules — remain the applicable law in 2026. The mechanism and timing by which each group will be carried into the ESPR framework, and the status of the existing measures after 31 December 2026, are tracked in section 17 rather than asserted here.

3. The ESPR Working Plan 2025–2030

The Commission adopted the Ecodesign for Sustainable Products Regulation and Energy Labelling Working Plan 2025–2030 on 16 April 2025 as COM(2025) 187 final. The plan identifies the product groups and horizontal measures the Commission intends to prioritise for delegated acts during the period, with indicative adoption years. It is a planning document: the years are indicative, and only the adoption of a delegated act creates obligations.

3.1 Product-specific priorities

Home appliances are not among the product-specific priorities. No appliance family appears in the list of new ESPR delegated acts for the period. Two of the priority materials — iron and steel, and aluminium — are nonetheless relevant upstream: an appliance manufacturer buying steel sheet and aluminium components may receive DPP-bearing inputs from its suppliers before any obligation attaches to the finished appliance. That is an input-side data flow, not an appliance DPP duty.

3.2 Horizontal measures

The plan sets out two horizontal measures that cut across product groups and that are the most likely routes by which ESPR requirements reach appliances before any product-specific act:

Whether large household appliances fall within the repairability measure, or only small household appliances, is not settled by the plan; the "may include" language is deliberate and the point is listed in section 17.

3.3 The 16 carried-over energy-related product groups

The plan carries over 16 energy-related product groups from the Ecodesign and Energy Labelling Working Plan 2022–2024 — including washing machines, dishwashers and televisions — on revision tracks under the existing ecodesign and energy labelling framework. These groups are not scheduled for new ESPR acts; their existing regulations are to be reviewed and revised through the processes already running. For appliances this is the practical meaning of "not in the first wave": the live files are the revisions of Regulations (EU) 2019/2019, 2019/2022, 2019/2023, 2019/2024, the review of the cooking-appliance rules and the vacuum-cleaner revision (section 5), not a new ESPR delegated act.

3.4 Where home appliances actually stand

• No appliance group is a product-specific ESPR priority for 2025–2030.
• Major appliances continue under product-specific ecodesign and energy labelling measures on revision tracks.
• Small household appliances may enter the scope of the horizontal repairability measure targeted for 2027; large appliances are not named.
• All appliances are EEE and would in principle be reached by the recycled-content and recyclability measure targeted for 2029.
• Any of these routes, once it takes the form of a delegated act, is subject to the 18-month minimum before application (Art. 4 ESPR).

3.5 The plan's position on the DPP

The Working Plan states that every product group for which ecodesign measures are adopted under the ESPR will be accompanied by a Digital Product Passport. Read together with sections 3.3 and 3.4, this has a precise consequence for appliances: the DPP will not arrive on its own, but it will arrive with the first ESPR-based ecodesign measure that covers an appliance group — whether that is a revision of an existing regulation re-based on the ESPR, or a horizontal measure. The passport and the next generation of appliance ecodesign requirements are therefore the same event, not two.

Source: COM(2025) 187 final, Ecodesign for Sustainable Products Regulation and Energy Labelling Working Plan 2025–2030, adopted 16 April 2025.

4. The DPP technical architecture

Since mid-2026 the DPP has a working infrastructure: an operational registry, an implementing regulation governing it, and a first set of European standards cited in the Official Journal. This section describes each component and what it implies for the way an appliance manufacturer should structure its data, even before any obligation applies.

4.1 The registry and the portal

The DPP registry required by Art. 13 ESPR has been operational since 20 July 2026, one day after the legal deadline of 19 July 2026. It is accompanied by a testing environment, and organisations can enrol. Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026, in force since 6 August 2026, lays down the implementation arrangements under Art. 13(5): the registration process, the verification of the economic operator's identity, the data stored and their retention.

The architectural principle is decentralisation. The registry stores identifiers — the unique product identifier, where applicable the commodity code, the battery identifiers under Art. 77(3) of Regulation (EU) 2023/1542 — and issues the unique registration identifier. It does not store the passports. DPP data remain with the economic operator or with its DPP service provider, under the differentiated access rights set in the delegated act. The public search and comparison portal of Art. 14 is under development; its publication date is not available in the sources consulted.

For appliances, two consequences follow. First, enrolment in the registry and in the testing environment is possible now, without any obligation, and allows a manufacturer to test the identifier logic against the live system. Second, because the registry holds only identifiers, the entire substance of a passport — the Annex III data elements — lives in the manufacturer's own systems or those of its provider. The quality of that data layer is therefore the manufacturer's problem to solve, not the Commission's.

4.2 Customs interconnection (Art. 15)

Customs verification of the registration identifier runs through EU CSW-CERTEX (section 2.11). The interconnection must be operational within four years of the Art. 13(5) implementing act, which is Implementing Regulation (EU) 2026/1778. The Commission's own planning date for the interconnection is not stated in the sources consulted; the four-year window is the only legal anchor.

Sources: Regulation (EU) 2024/1781, Arts. 13–15; Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026.

4.3 Identifiers and data carriers

The second paragraph of Annex III ESPR references the ISO/IEC 15459 family as the standard for unique identifiers and data carriers (or equivalent standards until harmonised references are cited). The six parts named are:

GTIN. Annex III point (c) provides for the Global Trade Item Number "as provided for in ISO/IEC 15459-6 or equivalent". The GTIN is the model-level identifier most appliance manufacturers already maintain in their GS1 master data. Whether it is accepted as, or as part of, the unique product identifier for a given appliance group will depend on the delegated act and on the harmonised identifier standard (EN 18219); but the fact that the ESPR names it in Annex III makes it the natural starting point.

GS1 Digital Link. GS1 Digital Link (the web-resolvable syntax standardised as ISO/IEC 18975, which encodes a GTIN together with batch or serial data in a QR code) is one candidate data-carrier and identifier approach compatible with the ISO/IEC 15459 family referenced in Annex III. Its formal position within the harmonised DPP standards set is not stated in the sources consulted and is listed in section 17. It is relevant to appliances because the energy label already carries a QR code linking to EPREL (section 6): a single QR code serving the label, the passport and, in time, the EU identifier APPLiA advocates (section 12) is technically a Digital Link question.

Operator and facility identifiers. Art. 12 requires these to comply with the same Annex III standards or equivalents; the issuing agencies and the conditions under which operators may issue their own identifiers are left to the delegated acts. No accepted scheme can be stated for appliances today.

4.4 The European DPP standards: CEN-CLC/JTC 24 and M/604

The European standards for the DPP system are developed by the joint technical committee CEN-CLC/JTC 24 under Commission standardisation request M/604. The series comprises eight standards, each matching an essential requirement of Arts. 10 and 11 ESPR:

Commission Implementing Decision (EU) 2026/1736 of 14 July 2026, published in the Official Journal on 15 July 2026, cites the references of the six 2026 editions — EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223 — as harmonised standards. Products and systems conforming to them benefit from the presumption of conformity under Art. 41(2) ESPR with the corresponding requirements of Arts. 10 and 11. The standards were published by CEN/CENELEC on 27 May 2026 and must be implemented as national standards by 30 November 2026. EN 18239 and EN 18246 became available on 16 September 2026; their citation in the Official Journal was still awaited as of the date of this dossier, so that for access rights, security, authentication, reliability and integrity no presumption of conformity yet exists and compliance must be demonstrated directly against Art. 11.

The practical reading for appliances is that the technical specification of a DPP is now largely known, independently of any delegated act: how data are modelled and exchanged (EN 18216), how a product, operator or facility is identified (EN 18219), what carrier links the physical product to the passport (EN 18220), how long and in what form data persist (EN 18221), how systems interrogate each other (EN 18222) and how they interoperate (EN 18223). A manufacturer structuring its model-level data now can do so against these standards rather than against an assumption.

Sources: Commission Implementing Decision (EU) 2026/1736 of 14 July 2026 (OJ, 15 July 2026); CEN-CLC/JTC 24 publications under standardisation request M/604; Regulation (EU) 2024/1781, Arts. 10, 11, 41(2), Annex III.

4.5 DPP service providers

The DPP service provider (Art. 2(32)) is a defined role in the architecture, not an optional convenience. Under Art. 10(4) the back-up copy of every passport must be held through such a provider; under Art. 11 the provider may also store and process the passport on the operator's behalf and must keep it available for the period set in the delegated act, including if the operator becomes insolvent, is liquidated or ceases activity. The same article strictly limits the provider's use of the data: it may not sell, re-use or process them beyond what is necessary to provide the service. The Commission may lay down requirements for providers and establish a certification scheme; no such scheme is in place as of the date of this dossier. For an appliance manufacturer, the provider relationship — contractual data-use limits, persistence guarantees, export rights without lock-in — is a procurement decision that can be prepared now and that Annex III point (l) will eventually require to be disclosed in the passport itself.

4.6 EPREL and the "once-only" direction

Work carried out under CIRPASS-2 together with the Commission is developing a "once-only" approach under which data already registered in EPREL — the product database of Regulation (EU) 2017/1369 — can serve DPP purposes where the data elements are equivalent, so that the supplier does not re-enter the same information twice. Draft acts implementing this approach were published for feedback in 2026; they are not adopted, and their final shape is listed in section 17.

For appliances this is the single most important architectural signal. Every major appliance model is already registered in EPREL before being placed on the market, with its product information sheet, its label and — in the compliance part — elements of its technical documentation (section 6). If the once-only principle is carried into the delegated acts, the EPREL entry becomes the first and largest block of the appliance passport, and the manufacturer's task shifts to aligning the remaining Annex III elements (compliance documentation, manuals, identifiers, service provider, substances) with the model record it already maintains.

5. Ecodesign today, category by category

All product-specific ecodesign measures covering home appliances were adopted under Directive 2009/125/EC and remain in force under the ESPR transitional regime: for the 19 product groups formerly under the Directive, existing measures continue under the Directive framework until 31 December 2026 (Regulation (EU) 2024/1781, transitional provisions). The Working Plan 2025-2030 (COM(2025) 187 final) carries 16 energy-related product groups from the 2022-2024 plan — including washing machines, dishwashers and televisions — on revision tracks under the existing ecodesign/labelling framework, and states that every product group for which ecodesign measures are adopted will be accompanied by a DPP under the ESPR. For APPLiA's members, therefore, the ecodesign resource-efficiency duties described below are both the binding regime of today and the most probable content skeleton of any future appliance DPP.

5.0 The common pattern of the 2019 package

Sources: Commission Regulations (EU) 2019/2019, 2019/2022, 2019/2023, 2019/2024; Regulation (EU) 2024/1781 (transitional regime); COM(2025) 187 final.

5.1 (a) Household refrigerating appliances

Acts. Commission Regulation (EU) 2019/2019 (ecodesign) and Commission Delegated Regulation (EU) 2019/2016 (energy labelling), both in application since 1 March 2021. Scope in brief. Mains-operated household refrigerating appliances (refrigerators, freezers, combined appliances and wine storage appliances), excluding appliances with a direct sales function, which fall under Regulation (EU) 2019/2024 below. Label. Rescaled A-G label with QR code linking to the model's EPREL entry; registration in EPREL before placing on the market.

Operational meaning. Two publication clocks run in parallel: the professional-only list has a two-year grace period from the first unit, the end-user list and repair instructions must be online from day one. The repair-information access window opens two years after the first unit and runs to the end of the parts period. A manufacturer must therefore track, per model, both the first-unit and the last-unit dates — the same two anchors a DPP would use to define the period during which the passport remains available (Art. 11 ESPR).

Sources: Commission Regulation (EU) 2019/2019; Commission Delegated Regulation (EU) 2019/2016; Regulation (EU) 2017/1369.

5.2 (b) Refrigerating appliances with a direct sales function

Acts. Commission Regulation (EU) 2019/2024 (ecodesign) and Commission Delegated Regulation (EU) 2019/2018 (energy labelling), in application since 1 March 2021. Scope in brief. Refrigerating appliances used to display and sell chilled or frozen goods to customers (supermarket cabinets, beverage coolers, ice-cream freezers, vending machines and the like). Energy efficiency index. EEI thresholds apply in two tiers, from 1 March 2021 and from 1 September 2023. Label. Label with QR code; EPREL registration before placing on the market.

Operational meaning. This is the first appliance regulation in which software and firmware, including reset software, appear explicitly as a spare part reserved to professional repairers — a precedent later generalised in the washing-machine, dishwasher and tumble-dryer acts. Software versions and reset tools thus become inventory items with an eight-year availability commitment, which is a data-governance question (versioning, access control) rather than a logistics one.

Sources: Commission Regulation (EU) 2019/2024; Commission Delegated Regulation (EU) 2019/2018.

5.3 (c) Household washing machines and washer-dryers

Acts. Commission Regulation (EU) 2019/2023 (ecodesign) and Commission Delegated Regulation (EU) 2019/2014 (energy labelling), in application since 1 March 2021. Scope in brief. Mains-operated household washing machines and household washer-dryers, including built-in models. Label. Rescaled A-G label with QR code; EPREL registration before placing on the market. The group is on the Working Plan's revision track and is listed in Annex II of the Repair Directive (section 7).

Operational meaning. Washing machines carry the longest and most detailed professional list of the 2019 package — essentially the full mechanical, hydraulic and electronic bill of materials, plus software. A ten-year commitment on a part list of this depth means that, for a model placed on the market in 2026, the parts, ordering channels and documentation must remain live well into the second half of the 2030s. The parts taxonomy of the regulation is already a de facto DPP data model for the family.

Sources: Commission Regulation (EU) 2019/2023; Commission Delegated Regulation (EU) 2019/2014.

5.4 (d) Household dishwashers

Acts. Commission Regulation (EU) 2019/2022 (ecodesign) and Commission Delegated Regulation (EU) 2019/2017 (energy labelling), in application since 1 March 2021. Scope in brief. Mains-operated household dishwashers, including built-in models. Label. Rescaled A-G label with QR code; EPREL registration before placing on the market. Listed in Annex II of the Repair Directive and on the Working Plan revision track.

Operational meaning. Dishwashers invert the refrigerator logic: the shorter period (7 years) covers the technical core reserved to professionals, the longer period (10 years) covers the consumer-replaceable wear parts. Because the two lists expire at different times for the same model, the model-level record must carry a per-part availability end-date, not a single figure — a granularity that a DPP data model should reproduce rather than flatten.

Sources: Commission Regulation (EU) 2019/2022; Commission Delegated Regulation (EU) 2019/2017.

5.5 (e) Household tumble dryers

Acts. Commission Regulation (EU) 2023/2533 (ecodesign) and Commission Delegated Regulation (EU) 2023/2534 (energy labelling), both applying from 1 July 2025; Regulation (EU) 2025/2262 (amendment/clarification); Commission Delegated Regulation (EU) 2025/1353 of 1 July 2025 (repairability class on the label). Scope in brief. Household tumble dryers. From 1 July 2025 only heat-pump dryers may be placed on the market, and the label is rescaled to A-G. APPLiA engaged operationally on this package (public statement on the 2023 package with policy manager Giulia Zilla).

Operational meaning. The dryer package is the most advanced data regime of the appliance families and the clearest preview of where the others are heading. Three novelties go beyond the 2019 pattern: indicative pre-tax spare-part prices become published data; a ten-year software-update commitment is written into ecodesign; and the repairability index (SDD/SF/ST/SRI) is a computed, registered parameter in EPREL that becomes a label class from 1 January 2027. Delegated Regulation (EU) 2025/1353 also settles the stock question in a manufacturer-friendly way — units placed on the market before 1 January 2027 keep the previous label without a sell-out deadline — but it means two label versions will coexist in retail for an extended period and the EPREL record must correctly flag which applies to which model.

Sources: Commission Regulation (EU) 2023/2533; Commission Delegated Regulation (EU) 2023/2534; Regulation (EU) 2025/2262; Commission Delegated Regulation (EU) 2025/1353 of 1 July 2025.

5.6 (f) Domestic ovens, hobs and range hoods

Acts. Commission Regulation (EU) No 66/2014 (ecodesign) and Commission Delegated Regulation (EU) No 65/2014 (energy labelling of ovens and range hoods, applying since 1 January 2015). Scope in brief. Domestic ovens (including when incorporated in cookers), domestic hobs and domestic range hoods. Energy efficiency tiers under 66/2014. Oven cavity EEI below 146 from 20 February 2015, below 121 from 2016, below 96 from 2019; hob and range hood requirements phased in tiers at one, three and five years. Label. Ovens and range hoods carry an energy label under 65/2014 and must be registered in EPREL; there is no energy label for hobs.

Sources: Commission Regulation (EU) No 66/2014; Commission Delegated Regulation (EU) No 65/2014; Directive (EU) 2024/1799, Annex II.

5.7 (g) Vacuum cleaners

Acts. Commission Regulation (EU) No 666/2013 (ecodesign). Scope in brief. Mains-operated vacuum cleaners. Requirements in force since 1 September 2017. Rated input power below 900 W; sound power level not exceeding 80 dB(A); dust re-emission not exceeding 1.00 %; the hose must remain usable after 40,000 oscillations under strain; operational motor lifetime of at least 500 hours. Label. The energy label under Delegated Regulation (EU) No 665/2013 was annulled by the General Court in Case T-544/13 RENV (judgment of 8 November 2018). Vacuum cleaners therefore carry ecodesign duties but no EU energy label today, hence no label QR code to an EPREL entry.

Sources: Commission Regulation (EU) No 666/2013; General Court, Case T-544/13 RENV, judgment of 8 November 2018; Directive (EU) 2024/1799, Annex II.

5.8 (h) Standby and off mode across families

Acts. Commission Regulation (EU) 2023/826, as amended by Regulation (EU) 2025/2262. Scope in brief. A horizontal regulation applying across the appliance families above (and beyond): it sets power-consumption limits for off mode, standby mode and networked standby, and lays down information duties for the products in scope. It operates alongside, not instead of, the product-specific acts.

Operational meaning. For a DPP-readiness exercise, standby/off-mode data is a reminder that the appliance data layer is not only product-specific: horizontal ecodesign measures add fields to every model record and are amended on their own cycle. A model-level data structure that can absorb horizontal fields without redesign is the practical goal.

Sources: Commission Regulation (EU) 2023/826; Regulation (EU) 2025/2262.

6. Energy labelling and EPREL — Regulation (EU) 2017/1369

Regulation (EU) 2017/1369 is the framework act for energy labelling. It allocates duties to suppliers (Art. 3) and dealers (Art. 4) and establishes, in Art. 12, the product database — EPREL — with a public part, a compliance part and an online portal. Product-specific delegated regulations (those listed in section 5) set the label classes, the product information sheet content and the testing methods for each family.

6.1 Supplier obligations (Art. 3) and model registration

• Registration of each model in EPREL is mandatory before placing units on the market, since 1 January 2019.
• Since 22 October 2024, under Regulation (EU) 2024/994, only verified suppliers — whose identity and EU establishment have been electronically proven — may register or modify models in EPREL.
• The supplier provides the label and the product information sheet with each unit, makes the technical documentation available, and ensures the label class is shown in advertising and technical promotional material.
• Labels carry a QR code linking to the model's EPREL entry, so that the physical label is already a data carrier pointing to a regulated, model-level dataset.

6.2 Dealer obligations (Art. 4)

Dealers must display the label and make the product information sheet available at the point of sale, including in online offers, where the energy class arrow must appear next to the price. The duty structure — supplier registers and supplies, dealer displays what the supplier has supplied — anticipates the ESPR mechanism under which the operator must give dealers and online marketplaces a digital copy of the data carrier or unique product identifier free of charge, promptly and in any event within five working days (Art. 10(3) ESPR).

6.3 The database (Art. 12): public part and compliance part

6.4 Circularity data already in the product information sheet

EPREL is no longer only an energy database. Several product information sheets already carry circularity fields:

• the minimum duration of the guarantee offered by the supplier;
• in the newest acts, spare-parts availability durations;
• for tumble dryers under Delegated Regulation (EU) 2023/2534, the repairability parameters SDD (depth of disassembly), SF (fasteners), ST (tools) and the resulting SRI, which from 1 January 2027 feed the A-E repairability class on the label under Delegated Regulation (EU) 2025/1353.

Combined with the ecodesign duties in section 5 (public spare-parts lists, availability periods, and for dryers indicative pre-tax prices), the regulated public footprint of an appliance model today already covers energy, water, noise, capacity, guarantee, parts availability and — for one family — a computed repairability score.

Sources: Regulation (EU) 2017/1369, Arts. 3, 4, 12 and 12(5); Regulation (EU) 2024/994; Commission Delegated Regulation (EU) 2023/2534; Commission Delegated Regulation (EU) 2025/1353; Regulation (EU) 2024/1781, Arts. 10-11; Commission Implementing Regulation (EU) 2026/1778; APPLiA submissions of 26 September 2025 and 15 April 2026.

7. The right to repair — Directive (EU) 2024/1799

Directive (EU) 2024/1799 on common rules promoting the repair of goods entered into force on 30 July 2024, with a transposition and application deadline of 31 July 2026. It does not create new technical requirements; it converts the ecodesign reparability requirements of section 5 into an enforceable consumer right and a manufacturer obligation, and it amends the sales-of-goods Directive (EU) 2019/771. For APPLiA's members the Directive is the point at which spare-parts lists, availability periods and repair documentation stop being market-surveillance data and become consumer-facing commitments.

7.1 Art. 5 — the obligation to repair

• Who is obliged. The manufacturer. Where the manufacturer is established outside the Union, the obligation falls on its authorised representative or, failing that, on the importer in the Union.
• What is covered. Goods for which reparability requirements are laid down in the Union legal acts listed in Annex II of the Directive.
• Trigger. The consumer's request.
• Price. Repair may be free of charge or for a price; where a price is charged it must be reasonable and must not deter the consumer from repairing.
• Subcontracting. The obliged party may subcontract the repair to fulfil the obligation.
• Duration. The obligation lasts as long as the ecodesign spare-parts availability period applicable to the product group — between 5 and 10 years depending on the family (for the appliances in section 5: 7 and 10 years for refrigerating appliances, 8 years for direct-sales refrigerating appliances, 10 years for washing machines and washer-dryers, 7 and 10 years for dishwashers, 10 years for tumble dryers).

7.2 Annex II — the eleven product families

Not in Annex II: domestic ovens, hobs and range hoods (section 5.6) and, more generally, any family without reparability requirements in a listed Union act. The 2026 addition of domestic local space heaters shows that Annex II is a living list, extended as new ecodesign acts with reparability requirements are adopted — which is the mechanism by which a future revised cooking-appliance regulation with spare-parts duties would bring that family into the repair obligation.

7.3 Information and market instruments

7.4 Transposition status

The transposition deadline was 31 July 2026. National status is uneven. For France, specialist sources report that no transposing law had been published as of late September 2026 and that the Commission sent a letter of formal notice dated 25 September 2026.

7.5 Operational meaning for manufacturers

• The duration clock is the ecodesign clock. The repair obligation for each model ends when the spare-parts period ends; models therefore need a tracked last-unit date and, where the family has two periods (refrigerating appliances, dishwashers), the obligation should be managed against the relevant part list.
• Prices become public data. Indicative repair prices (Directive) and, for dryers, indicative pre-tax part prices (ecodesign) join the free-access publication layer. Price information is thus a maintained dataset, not a one-off disclosure.
• Repairers become a data audience. The professional-repairer registration regime of section 5 and the Repair Information Form create defined counterparties with defined information rights — the same actors (professional repairers, independent operators, refurbishers) to whom Art. 11 ESPR guarantees DPP access.
• Build-on logic. Because the Directive relies entirely on existing ecodesign duties, a manufacturer that has its spare-parts lists, periods, prices and repair documentation structured at model level is already compliant on the data side; what the Directive adds is a service obligation and a consumer-facing publication duty.

Sources: Directive (EU) 2024/1799, Art. 5 and Annex II; Directive (EU) 2019/771 as amended; Regulations (EU) 2019/2019, 2019/2022, 2019/2023, 2019/2024, 2023/2533; specialist-source reports on the French transposition (September 2026) — to be verified.

8. France: the repairability and durability indices

France is the only Member State operating a mandatory, consumer-facing repairability and durability score for home appliances. The legal basis is the anti-waste and circular economy law, Loi n° 2020-105 of 10 February 2020 (loi AGEC), codified in Art. L.541-9-2 of the Code de l'environnement. The French indices matter to APPLiA for two reasons: they are the standing example, in APPLiA's own public positions, of divergent national legislation against which EU harmonisation is argued; and they run on exactly the data families a DPP will need.

8.1 The repairability index (indice de réparabilité)

8.2 The durability index (indice de durabilité)

Operational meaning. The move from repairability to durability adds a second data block that is not covered by any EU ecodesign act today: stress and wear resistance, maintenance ease, the length of the commercial guarantee and the existence of a quality process. For washing machines sold in France since 8 April 2025, a manufacturer must therefore hold and maintain, per model, both the EU-mandated parts and documentation data (section 5.3) and a reliability dataset that exists only because of French law.

8.3 Why the French indices matter for a DPP strategy

Sources: Loi n° 2020-105 of 10 February 2020; Code de l'environnement, Art. L.541-9-2; implementing decree of 5 April 2024; service-public.gouv.fr; COM(2025) 187 final; Commission Delegated Regulations (EU) 2023/2534 and 2025/1353; APPLiA public reporting of the ESPR event with Director-General Paolo Falcioni.

9. Substances and materials: REACH, SCIP, RoHS and the ESPR "substances of concern" bridge

Substance data is the one layer of the future appliance DPP that is already fully regulated today, under three instruments that do not talk to each other: REACH (chemical substances and articles), the Waste Framework Directive's SCIP notification (articles with SVHC content, for the benefit of waste operators) and RoHS (restricted substances in electrical and electronic equipment). The ESPR does not replace any of them. It adds a fourth, wider definition — "substances of concern", Art. 2(27) of Regulation (EU) 2024/1781 — that product-specific delegated acts will use when they decide what substance information a DPP must carry across the product's life cycle. For appliance manufacturers the practical question is therefore not "which list applies" but "can the substance data already produced for REACH, SCIP and RoHS be organised, at model level, against the Art. 2(27) perimeter".

9.1 REACH — Regulation (EC) No 1907/2006

Three REACH mechanisms are relevant to appliances as articles:

• Candidate List of substances of very high concern (SVHC). Substances identified under Art. 57 and placed on the Candidate List by the procedure in Art. 59(1). The Candidate List triggers the communication duty of Art. 33 for articles containing a Candidate List SVHC above 0.1% w/w (information to recipients in the supply chain and, on request, to consumers) and the SCIP notification described in 9.3.
• Authorisation (Annex XIV). Substances moved from the Candidate List to Annex XIV may not be used in the EU without an authorisation after their sunset date. Authorisation bears on EU manufacturing and use; for imported articles the operative tools are Art. 33 communication and restrictions.
• Restrictions (Annex XVII). Conditions or bans on the manufacture, placing on the market or use of substances, on their own, in mixtures or in articles. Annex XVII restrictions apply to imported articles as well as to EU-made ones and are enforced by market surveillance.

REACH compliance for an appliance is a supply-chain information exercise: the manufacturer depends on component suppliers' declarations to know whether any Candidate List substance exceeds 0.1% w/w in any article incorporated in the product (the threshold is assessed per article, i.e. per component, not per finished appliance).

Source: Regulation (EC) No 1907/2006 (REACH), Arts. 33, 57, 59(1); Annexes XIV and XVII; ECHA Candidate List.

9.2 The bridge: ESPR Art. 2(27) "substance of concern"

Art. 2(27) ESPR is the definition that DPP delegated acts will use when they require tracking and disclosure of substances in a product. It is deliberately wider than the REACH SVHC concept and has four limbs:

Two consequences follow. First, limb (b) brings in harmonised CLP classifications that have no REACH-article reporting duty today: a component may contain a chronic aquatic hazard cat. 4 substance, for example, with no Art. 33 or SCIP obligation attached, yet it would fall within Art. 2(27). Second, limb (d) is open-ended and product-specific: what hinders recycling in a refrigerator (e.g. in insulation foams or refrigerant circuits) is not what hinders recycling in a washing-machine drum. The delegated act for each product group will have to specify it. Until an applicable delegated act exists, Art. 2(27) imposes no obligation on appliances; it is a definition awaiting activation.

Source: Regulation (EU) 2024/1781, Art. 2(27); Regulation (EC) No 1907/2006, Arts. 57, 59(1); Regulation (EU) 2019/1021 (POPs).

9.3 SCIP notification

Since 5 January 2021, suppliers of articles containing a Candidate List SVHC above 0.1% w/w must notify the ECHA SCIP database, under Art. 9(1)(i) of Directive 2008/98/EC (Waste Framework Directive). The notification exists to inform waste operators about the presence of SVHC in articles reaching end of life; it is in substance the first EU-level, machine-readable, article-level substance disclosure — a precursor of the DPP substance layer, limited to limb (a) of Art. 2(27) and to the 0.1% w/w threshold. SCIP data is organised by article and by the complex object (the appliance) in which the article is incorporated, which is exactly the hierarchy a DPP delegated act would expect.

Source: Directive 2008/98/EC, Art. 9(1)(i); ECHA SCIP database (notification duty from 5 January 2021).

9.4 RoHS — Directive 2011/65/EU

RoHS restricts 10 substances in electrical and electronic equipment, with maximum concentrations of 0.1% by weight in homogeneous materials (0.01% by weight for cadmium). The assessment unit is the homogeneous material — not the component and not the article as under REACH — which is why RoHS and REACH declarations from the same supplier cannot simply be merged. Home appliances fall in RoHS Category 1 (large household appliances) and Category 2 (small household appliances). RoHS compliance is demonstrated through the EU declaration of conformity, the technical documentation and CE marking, and depends on the exemptions in the Directive's annexes, each carrying an expiry date and, for most entries, a category-specific validity.

Source: Directive 2011/65/EU (RoHS), Annex I categories, Annex II restricted substances and concentration limits.

9.5 The November 2025 exemption package — lead in metal alloys and solders

A package of delegated directives amending the RoHS exemption annexes was published in the Official Journal on 21 November 2025 and entered into force on 11 December 2025. Member States must transpose it by 30 June 2026 and apply the transposing measures from 1 July 2026. The package includes Delegated Directive (EU) 2025/2364 (lead in metal alloys) and Delegated Directive (EU) 2025/1802 (lead in high-melting-point solders). It tightens precisely the lead exemptions most relied on in appliance components — steel fasteners and machined parts, galvanised parts, aluminium castings, brass fittings and valves, and electronics solder.

Two mechanics qualify the table. First, home appliances in Categories 1 and 2 are on the earlier of the two 6(b)-I dates — 11 December 2026 — not on the mid-2027 date reserved for category 9-industrial and category 11. Second, renewal applications filed in December 2025 suspend the expiry of several entries until the Commission decides on them; if a renewal is refused, a 12-18-month phase-out period applies after the decision. The status of each entry therefore has to be checked against the Commission's handling of the pending applications rather than read off the expiry column alone.

Source: Delegated Directives (EU) 2025/2364 and (EU) 2025/1802 and accompanying package, OJ 21 November 2025; Directive 2011/65/EU, exemption annexes; verified fact base (27 October 2026).

9.6 What the three regimes contribute to a DPP substance layer

• REACH / Art. 33: article-level presence of Candidate List SVHC above 0.1% w/w; supply-chain communication only, no central database.
• SCIP: the same information, notified centrally to ECHA with article-in-object hierarchy, since 5 January 2021.
• RoHS: homogeneous-material-level compliance with 10 restrictions, documented in the technical documentation and the declaration of conformity (which ESPR Annex III point (e) already lists as DPP "compliance documentation"), with exemption references expiring on dated schedules.
• ESPR Art. 2(27): the wider perimeter that a product-specific delegated act will specify — including CLP classes and recycling-relevant substances with no current reporting duty.

None of these obligations changes for appliances because of the ESPR today. What changes is the design target: substance data organised once, at model level, against the widest of the four definitions.

10. End of life: the WEEE Directive, Italy's transposition and the 2024 targeted amendment

10.1 Directive 2012/19/EU — scope, categories and producer financing

The WEEE Directive has had an "open scope" since 15 August 2018: all electrical and electronic equipment is in scope unless expressly excluded, organised in six categories. Home appliances sit mainly in Category 1 (temperature exchange equipment — refrigerators, freezers, heat-pump dryers and other appliances containing refrigerant circuits) and Category 4 (large equipment — washing machines, dishwashers, ovens, hobs, hoods and the other large household appliances without temperature-exchange function). Small appliances and vacuum cleaners fall in the small-equipment categories. The category determines the collection and treatment stream, the recovery targets reported by the producer and, in practice, the treatment-information duties towards recyclers.

Producers finance the collection, treatment, recovery and environmentally sound disposal of WEEE. For household WEEE this is organised through collective compliance schemes; producers register in each Member State where they place equipment on the market and report quantities placed, collected and treated. Distributors carry take-back duties: 1-to-1 take-back of equivalent WEEE when supplying a new product, and, for large-surface retailers, 1-to-0 take-back of very small WEEE without any purchase obligation.

Source: Directive 2012/19/EU (WEEE), open scope from 15 August 2018; Annexes III-IV categories; producer financing and distributor take-back provisions.

10.2 Marking and producer identification — EN 50419:2022

Each unit must bear the crossed-out wheeled bin symbol and the identification of the producer, so that the equipment can be attributed to the financing producer at end of life. The applicable marking standard is EN 50419:2022. The producer identification on the product is, functionally, the earliest "unique operator identifier" in EU product law; a DPP delegated act would carry the same information through the manufacturer identification field of ESPR Annex III point (g) and the unique operator identifiers of points (h) and (i), without replacing the physical marking required by WEEE.

Source: Directive 2012/19/EU, marking requirements; EN 50419:2022.

10.3 Italy — D.Lgs 49/2014

Italy transposed the WEEE Directive by Legislative Decree 49/2014. It applies the standard 1-to-1 take-back at retail and the 1-to-0 take-back for very small WEEE at large-surface retailers, and goes beyond the Directive by extending a "1-contro-0" take-back to large household appliances at retail. For a manufacturer selling in Italy this means the retail channel is a return channel for large appliances independently of any new sale — with the corresponding logistics and reporting flows through the national collective schemes.

Source: D.Lgs 14 marzo 2014, n. 49 (Italy), transposing Directive 2012/19/EU.

10.4 Directive (EU) 2024/884 — the targeted amendment after CJEU C-181/20

Directive (EU) 2024/884 of 13 March 2024 is a targeted amendment of the WEEE Directive adopted after the Court of Justice judgment in case C-181/20. It makes two corrections and adds one clause:

• Photovoltaic panels: producer financing for PV panel waste runs from 13 August 2012 (not retroactively from the Directive's original dates).
• Open scope and EPR: extended producer responsibility under the open scope applies only to products placed on the market after 15 August 2018; producers are not made liable for the end-of-life financing of open-scope products placed on the market before that date.
• Review clause: the Commission must assess by 2026 whether a broader revision of the WEEE Directive is needed.

The transposition deadline for Directive (EU) 2024/884 was 9 October 2025.

Source: Directive (EU) 2024/884 of 13 March 2024 (OJ), transposition by 9 October 2025; CJEU, case C-181/20.

10.5 What WEEE data a DPP would absorb

The WEEE layer already produces, per producer and per category, the quantities placed on the market and the identification needed to attribute a unit to its producer. What it does not produce at model level is the information recyclers need before dismantling — refrigerant type and quantity, location of components requiring selective treatment, presence of substances of concern (section 9). ESPR delegated acts list recyclers explicitly among the actors with free DPP access (Art. 11), and the Working Plan's horizontal measure on recycled content and recyclability of EEE is targeted for 2029 (section 3). A DPP designed for appliances would therefore sit between WEEE registration (producer level) and treatment information (model level), with the crossed-out bin and EN 50419:2022 marking unchanged on the product.

11. Batteries in appliances — Regulation (EU) 2023/1542

Batteries incorporated in home appliances — cordless vacuum cleaners, handheld kitchen appliances, back-up cells in controls — are portable batteries under Regulation (EU) 2023/1542. The Regulation applies to them directly, as products in their own right, in parallel with the appliance's own ecodesign, RoHS and WEEE obligations. The duties below bind the appliance manufacturer as the party placing the incorporated battery on the market, independently of any ESPR delegated act.

11.1 Art. 11 — removability and replaceability from 18 February 2027

From 18 February 2027, portable batteries incorporated in products must be readily removable and replaceable by the end-user at any time during the product's lifetime. The Regulation specifies the conditions:

• removal and replacement with commercially available tools, without the use of heat or solvents;
• replacement instructions published by the manufacturer;
• spare batteries available as spare parts for at least 5 years after the last unit of the model is placed on the market, at a reasonable price;
• software must not obstruct replacement with a compatible battery (no software locking of a compatible replacement).

Art. 11(2) provides derogations where continuity of power supply is necessary for safety, performance or data integrity. The Commission published interpretative guidelines on Art. 11 in 2025; the derogations are to be read against those guidelines and are not a general exemption for appliances in wet environments or with sealed housings. Appliances with incorporated portable batteries designed today are being designed for a market on which Art. 11 applies at the point of sale from 18 February 2027.

Source: Regulation (EU) 2023/1542, Art. 11 (application 18 February 2027), Art. 11(2); Commission interpretative guidelines 2025.

11.2 Art. 13 — labelling, QR code, CE marking

The battery QR code is a second data carrier on an appliance with an incorporated battery, distinct from the energy-label QR code linking to EPREL and from any future DPP data carrier under ESPR Art. 10. The battery QR must resolve to battery-specific content (label information, declaration of conformity, end-of-life information) and cannot be replaced by the appliance's own carrier unless a future act permits consolidation — which is the practical background to APPLiA's "one single EU QR code" position (section 12.3).

Source: Regulation (EU) 2023/1542, Art. 13 (crossed-out bin from 18 August 2025; QR code from 18 February 2027).

11.3 Extended producer responsibility and collection targets

Extended producer responsibility for batteries applies since 18 August 2025, with registration in each Member State where the batteries are sold (including batteries sold incorporated in appliances). Portable-battery collection targets are 63% by the end of 2027 and 73% by the end of 2030; they are national targets met through the producer responsibility organisations, and the appliance manufacturer contributes as a battery producer for each incorporated battery placed on the market.

Source: Regulation (EU) 2023/1542, EPR provisions (from 18 August 2025); portable-battery collection targets 63% (end-2027) and 73% (end-2030).

11.4 Due diligence — from 18 August 2027

Battery due diligence obligations covering cobalt, lithium, nickel and natural graphite apply from 18 August 2027 to economic operators with a turnover above €40 million. The date was postponed by Regulation (EU) 2025/1561. Appliance manufacturers above the threshold placing lithium-based portable batteries on the market, incorporated or not, fall within the obligation; the turnover threshold is the only size criterion stated in the fact base.

Source: Regulation (EU) 2023/1542, due diligence chapter; Regulation (EU) 2025/1561 (postponement to 18 August 2027).

Source: Regulation (EU) 2023/1542, Arts. 7, 8, 77; Regulation (EU) 2024/1781, Art. 13 (registry storing Art. 77(3) battery identifiers).

12. APPLiA's own agenda: the documented positions and what they imply for an appliance DPP

APPLiA — Home Appliance Europe has set out its position on digital product information in five documented steps since 2021. They are summarised here from the association's public documents, with date and document type, as a reference against which the design options in this dossier can be checked. No position is paraphrased beyond what the documents state.

12.1 Feedback on the potential EU Digital Product Passport — policy paper, 9 June 2021

In its June 2021 feedback paper on the potential EU DPP, APPLiA set three conditions that have remained constant since. First, a DPP must demonstrate added value for each actor it touches — consumers, recyclers, repairers — rather than being justified at the level of the instrument as a whole. Second, the feasibility, relevance and effectiveness of a passport must be assessed sector by sector and product by product; a horizontal justification does not establish that a passport is useful for a given appliance family. Third, the paper leaves open whether the post-sale life of the individual unit — repairs, service events, ownership changes — belongs in the passport at all, as distinct from static model-level information. That open question maps directly onto the ESPR's own design choice, left to each delegated act under Art. 10, between a model-, batch- or item-level DPP.

Source: APPLiA, "Feedback on the potential EU Digital Product Passport", policy paper, 9 June 2021.

12.2 Submission to the ESPR energy label questionnaire — 26 September 2025 — and call-for-evidence comments

In its submission of 26 September 2025 to the ESPR energy label questionnaire, and in its comments on the related call for evidence, APPLiA opposed a one-size-fits-all ESPR label. Concretely, the association proposes deleting the generic label provision — Art. 16(5) ESPR — so that label layout and content are set only in product-specific delegated acts, as is the case today under the energy labelling framework of Regulation (EU) 2017/1369. The submission gives priority to digitalisation and to the tools that already exist — EPREL, the DPP and QR codes — over new physical labels, and places the consumer perspective at the centre, citing the Energy Label's record as a successful, recognised instrument and Eurobarometer evidence on consumer use of it. The position is not against information; it is against a second, generic label layer competing with the Energy Label on the same product.

Source: APPLiA, submission to the ESPR energy label questionnaire, 26 September 2025; APPLiA comments on the related call for evidence.

12.3 Policy paper on the future European Product Act — 15 April 2026

APPLiA's policy paper of 15 April 2026 on the future European Product Act is the most complete statement of the association's architecture for digital product information. Its elements:

• the CE mark should evolve into a digital identifier — a QR code linked to a mandatory EU registry;
• one single EU QR code for all requirements, instead of a proliferation of data carriers (energy label QR, battery QR, DPP carrier, national schemes);
• rigorous product-by-product impact assessments before any mandatory DPP roll-out;
• manuals and declarations of conformity digital by default, with paper available on request;
• self-assessment as the default conformity route;
• harmonised standards that remain voluntary.

Read against the ESPR as it stands in October 2026, the first two points describe a convergence that the Regulation partly enables: the DPP registry under Art. 13 is live (20 July 2026, Implementing Regulation (EU) 2026/1778), and Art. 10 requires a single data carrier linked to a persistent unique product identifier. What the ESPR does not do is consolidate the battery QR under Regulation (EU) 2023/1542 or the energy-label QR under Regulation (EU) 2017/1369 into that carrier; APPLiA's "one QR" position is therefore a request addressed to the future Product Act and to the "once-only" work with EPREL (section 4), not a description of current law.

Source: APPLiA, policy paper on the future European Product Act, 15 April 2026.

12.4 The ESPR event with Director-General Paolo Falcioni — EU harmonisation against national divergence

In its public reporting of the ESPR event featuring Director-General Paolo Falcioni, APPLiA framed the central benefit of the ESPR as harmonisation at EU level against a drift of divergent national legislation. The standing example is France: the repairability index since 1 January 2021 and the durability index since 2024-2025 (section 8) impose, at national level, scoring and display duties on the same data families — documentation, disassembly, spare-parts availability and price, reliability — that the ESPR horizontal repairability measure (targeted 2027) and a product-specific DPP would address at EU level. The position is consistent with 12.1 and 12.3: EU instruments are preferred not because they are lighter, but because one EU data set replaces several national ones.

Source: APPLiA public reporting of the ESPR event with Director-General Paolo Falcioni.

12.5 Operational work on the ecodesign and labelling files

APPLiA's positions are formed inside the technical detail of the product-specific acts, not above them. Its statement on the 2023 tumble dryer package — Regulation (EU) 2023/2533 and Delegated Regulation (EU) 2023/2534, the first appliance acts to carry repairability index parameters (SDD, SF, ST, SRI) on the product information sheet and, from 1 January 2027, a repairability class on the label — was issued with policy manager Giulia Zilla. The same operational engagement covers the other 2019-package acts (refrigerating appliances, washing machines and washer-dryers, dishwashers) and the revision tracks carried over in the ESPR Working Plan 2025-2030. For the purposes of this dossier the relevance is practical: the association already works the data fields that a DPP would export — spare-parts lists and periods, repair information access, product information sheet parameters — act by act.

Source: APPLiA statement on the tumble dryer package (Regulation (EU) 2023/2533 / Delegated Regulation (EU) 2023/2534), policy manager Giulia Zilla.

12.6 Synthesis — what the positions imply for the design of an appliance DPP

Taken together, the five positions define a design envelope for an appliance DPP that is narrower and more concrete than the ESPR's general framework, and that this dossier has used as its reference:

• Product-by-product assessment. A DPP for appliances should be specified family by family (refrigerating appliances, washing machines, dishwashers, tumble dryers, cooking appliances, vacuum cleaners), each with its own data elements selected from Annex III, after an impact assessment — consistent with the ESPR's own delegated-act structure under Art. 4 and with the Working Plan, in which appliances are not in the first wave.
• One data carrier. A single QR code resolving to a persistent unique product identifier, compatible with the ISO/IEC 15459 family and the EN 18219/18220 standards cited in the OJ, serving energy-label, battery, conformity and DPP functions — a convergence that current law does not yet deliver and that the Product Act is the vehicle for.
• Digital-first documentation. Manuals, declarations of conformity and technical documentation digital by default (Annex III points (e) and (f)), with paper on request — the same documents already partly held in EPREL's compliance part under Art. 12(5) of Regulation (EU) 2017/1369.
• Convergence with EPREL. EPREL is the existing model-level registry with verified suppliers, QR-linked labels and product information sheets that already carry circularity fields; the "once-only" work under CIRPASS-2 and the Commission points the same way. An appliance DPP should reuse EPREL data where equivalent rather than duplicate it.
• No generic label layer. No horizontal ESPR label alongside the Energy Label; label layout and content only in product-specific acts, with the DPP carrying the information that does not belong on a physical label.

The implication for a manufacturer is the one stated in the dossier's headline: the DPP, when it comes for a given appliance family, should be an export of data structured today at model level — substances (section 9), end-of-life and producer identification (section 10), battery data (section 11), and the ecodesign and EPREL layers (sections 5-7) — through one carrier, into a registry that is already live.

13. The DPP Map (synthesis)

The one-page DPP Map distributed with this dossier condenses sections 1-12 into a planning tool for appliance manufacturers. It is reproduced here in full; two table cells have been tightened against the verified fact base (the tumble-dryer row and the 1 March 2021 row). Everything in the Map is a synthesis of verified items — indicative points are labelled as such.

14. A worked example: one model's passport

The worked example of this dossier, rendered as a passport — in the same form as the Ledger passports that run in production for other product groups (Annex A). The record is organised in the blocks of the production passport: identity, energy and performance as registered in EPREL, materials and substances, repairability and spare parts, the signed lifecycle events, the certificates and proofs, the registry anchoring, the version history and the map of norms. Each field names the legal source of the data element where one exists today, and the ESPR Annex III item it corresponds to where the delegated acts may later draw on it.

Basis: Regs. (EU) 2019/2023 and 2019/2014; Reg. (EU) 2017/1369; Reg. (EU) 2024/1781 Arts. 9-15 and Annex III; Dir. (EU) 2024/1799; Dir. 2011/65/EU and Delegated Directives (EU) 2025/2364, 2025/1802; Dir. 2012/19/EU; Reg. (EU) 2023/1542; AGEC law. Product values are illustrative.

Two further worked examples — a dishwasher and a refrigerator — together with the Ledger passports already in production for other product groups, are set out in Annex A, rendered as passports in the same form.

15. The data to structure now

The Map's thirteen checklist items expanded. The fourth column names only instruments that bind appliance manufacturers today; the fifth states what the family is for in a DPP context, and where the driver is still expected rather than adopted. "Where it usually lives today" describes the typical corporate location of the data, which is exactly why structuring at model level is the first step: these families sit in different systems, owned by different functions.

A note on responsibility applies across all thirteen rows: under every instrument cited, the manufacturer or responsible economic operator remains legally responsible for the accuracy of declared data. Infrastructure that aggregates, anchors or makes data available does not certify the truth of manufacturer-supplied data.

Basis: fact base sections on ESPR, EPREL, ecodesign per category, right to repair, AGEC, substances, WEEE and batteries; analysis extract section 10.

16. Consolidated timeline

Verified deadlines in chronological order. Rows marked "indicative" are Working Plan or planning signals, not legal deadlines. Past dates are included because they define duties that bind today.

Basis: fact base (checked 27 Oct 2026 against official sources); analysis extract section 9. Where the two differed, the fact base was used (tumble-dryer label dates; registry implementing regulation reference; RoHS expiries).

17. Open points and items to verify

The following points are unsettled at the date of writing or depend on sources that are not yet official. They are stated as open, not as fact, and should be re-checked before any decision is based on them.

• EN 18239 (access rights and security) and EN 18246 (data authentication, reliability and integrity). Both became available on 16 September 2026; their citation in the Official Journal — and hence presumption of conformity under ESPR Art. 41(2) — is still awaited. Until cited, equivalent technical solutions are permitted under Art. 10, but the reference point for access-rights and integrity design remains provisional.
• National transposition of Directive (EU) 2024/1799. The 31 July 2026 deadline has passed; status varies by Member State. The France point (no transposing law published as of late September 2026; Commission letter of formal notice dated 25 September 2026) is reported by specialist sources only and must be verified at national level before being relied on. A Member-State-by-Member-State check is needed for the +12-month guarantee option and for the practical enforcement of the manufacturer repair obligation.
• Vacuum cleaners. The revision of Reg. (EU) No 666/2013 (2023 draft working document: wider scope incl. commercial and robot vacuums, debris-pickup and stricter dust re-emission requirements) is still at draft stage; no EU energy label exists since the annulment of Del. Reg. (EU) No 665/2013 (T-544/13 RENV, 8 November 2018). Timing of any revised labelling framework is open.
• Ovens, hobs and range hoods. The Commission review of Reg. (EU) No 66/2014 and Del. Reg. (EU) No 65/2014 — including a possible label for hobs and rescaling of oven/hood labels — is under way; outcome and timing open. This family currently has no spare-parts regime and is not in Annex II of the Repair Directive.
• Scope of the 2027 horizontal repairability measure. The Working Plan indicates adoption in 2027 with a scoring system; the final product scope (consumer electronics, small household appliances, possibly others) is to be refined in the JRC preparatory study. Whether and how it will interact with the French durability index is open.
• Registry operating practice under Implementing Regulation (EU) 2026/1778. The act is in force since 6 August 2026 and the registry is operational, but enrolment practice, identity-verification workflows, retention handling and the public portal under Art. 14 are still bedding in; the EU CSW-CERTEX customs interconnection (Art. 15) is to become operational within four years of the Art. 13(5) act. The "once-only" EPREL-DPP approach is at draft-act stage.
• Broader WEEE revision. Directive (EU) 2024/884 requires the Commission to assess by 2026 whether a broader revision is needed; no proposal is on the table at the date of writing. The announced Circular Economy Act is a related live file.
• RoHS renewal decisions. Renewal applications filed in December 2025 suspend the expiry of several exemption entries until the Commission decides; if refused, a 12-18 month phase-out applies. The effective dates in section 16 are therefore the baseline, not necessarily the operative ones for every entry.
• An appliance-specific DPP delegated act. Whether one will be proposed beyond the current Working Plan horizon (2025-2030), for which product group first, at model or item level, and with which access rights, is entirely open. The Working Plan position — every product group with adopted ecodesign measures to be accompanied by a DPP — is a policy orientation, not a timetable.

Basis: fact base items marked [TO VERIFY] and [status Oct 2026]; analysis extract section 11.

18. Sources

Official texts were consulted in their consolidated versions where available. Secondary and specialist sources were used only for the points flagged in section 17 and are identified as such in the text.

Legislation (EUR-Lex)

• Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation) — Arts. 1, 2, 4, 9-15, 24-25, Annexes III and VII; transitional provisions.
• Regulation (EU) 2017/1369 (energy labelling framework; EPREL) and Regulation (EU) 2024/994 (verified suppliers).
• Regulation (EU) 2023/1542 (batteries) — Arts. 7, 8, 11, 13, 77; Regulation (EU) 2025/1561 (postponement of due diligence).
• Regulation (EU) 2023/2533 (tumble dryers, ecodesign) and Delegated Regulation (EU) 2023/2534 (tumble dryers, labelling); Delegated Regulation (EU) 2025/1353 (repairability class); Regulation (EU) 2025/2262 (amendments to 2023/2533 and 2023/826).
• Directive (EU) 2024/1799 (right to repair) incl. Annex II; Directive (EU) 2019/771 as amended.
• Directive (EU) 2024/884 (WEEE targeted amendment); Directive 2012/19/EU (WEEE).
• Directive 2011/65/EU (RoHS) and the November 2025 delegated-directive package, incl. Delegated Directives (EU) 2025/2364 and (EU) 2025/1802.
• The 2019 ecodesign and energy labelling package: Regulations (EU) 2019/2019, 2019/2022, 2019/2023, 2019/2024 and Delegated Regulations (EU) 2019/2014, 2019/2016, 2019/2017, 2019/2018.
• Regulation (EU) No 66/2014 and Delegated Regulation (EU) No 65/2014 (cooking appliances); Regulation (EU) No 666/2013 and Delegated Regulation (EU) No 665/2013 (vacuum cleaners); General Court judgment T-544/13 RENV.
• Regulation (EU) 2023/826 (standby and off mode).
• Regulation (EC) No 1907/2006 (REACH); Directive 2008/98/EC Art. 9 (SCIP); Regulation (EU) 2019/1021 (POPs).
• Commission Implementing Regulation (EU) 2026/1778 (DPP registry arrangements); Commission Implementing Decision (EU) 2026/1736 (citation of harmonised DPP standards); Implementing Regulation (EU) 2026/2 and Delegated Regulation (EU) 2026/296 (unsold products).
• Regulations (EU) 2019/1020 and (EU) 2023/988 (responsible EU operator, as referenced in ESPR Annex III).

Policy documents and official pages

• COM(2025) 187 final — ESPR and Energy Labelling Working Plan 2025-2030 (16 April 2025).
• European Commission: Digital Product Passport registry pages (go-live, enrolment, testing environment); energy-efficient products and EPREL pages; CIRPASS-2 materials on the EPREL-DPP "once-only" approach.
• CEN-CENELEC: CEN-CLC/JTC 24 work programme under standardisation request M/604; publication of EN 18216, 18219, 18220, 18221, 18222, 18223 (27 May 2026) and EN 18239, 18246 (16 September 2026).
• ECHA: SCIP database guidance and notification duty.
• service-public.gouv.fr: indice de réparabilité and indice de durabilité (categories, dates, criteria); Loi n° 2020-105 and Art. L.541-9-2 Code de l'environnement; decree of 5 April 2024.
• Italy: D.Lgs 49/2014 (WEEE transposition; "1-contro-0" take-back).
• EN 50419:2022 (WEEE marking).

APPLiA documents (as listed in section 12)

• "Feedback on the potential EU Digital Product Passport", policy paper, 9 June 2021.
• Submission to the ESPR energy label questionnaire, 26 September 2025, and comments on the related call for evidence.
• Policy paper on the future European Product Act, 15 April 2026.
• APPLiA's public reporting of the ESPR event with Director-General Paolo Falcioni.
• APPLiA's statement on the 2023 tumble dryer package.

Consolidated texts

• Consolidated versions as published on EUR-Lex; UK-retained versions on legislation.gov.uk consulted for comparison where helpful.

All references checked on 27 October 2026. Items reported by specialist sources only are identified in section 17.

19. About Ledger Consortium

Ledger Consortium provides distributed-ledger infrastructure for the legal certification of documents, products and data. For products, it aggregates the data its clients provide, anchors the record on a governed distributed ledger and manages regulatory updates over time. It does not certify the truth of client-supplied data: responsibility for the data — its accuracy, completeness and currency, as ESPR Art. 9 will require — stays with the manufacturer or responsible economic operator.

For the Digital Product Passport specifically, the relevant service surface is threefold: identifier and registry management (persistent unique product identifiers, operator and facility identifiers, data carriers, and interaction with the EU DPP registry under ESPR Art. 13 once a category is covered); data structuring at model level from flows manufacturers already maintain (EPREL, technical files, spare-parts and service data, supplier declarations); and lifecycle maintenance of the passport as acts and data change — including versioned records, access-tier configuration and the regulatory watch items listed in section 17. A back-up copy under ESPR Art. 10(4) and the service-provider constraints of Art. 11 apply to this role.

This dossier was prepared for APPLiA — Home Appliance Europe in October 2026. It is a research document, not legal advice, and it will be updated as the open points in section 17 are resolved. Questions, corrections and requests for the underlying references are welcome: gianluca.medeot@ledgerconsortium.com.

Annex A. The Ledger DPP in production — and two further appliance passports

Section 14 gave one complete worked example — a washing machine. This annex, added in October 2026, does the two things the worked example alone could not. First, it integrates the Digital Product Passports that Ledger already runs in production for other product groups: the appliance passports below use the identical data model, signing logic and registry anchoring. Second, it adds two further dedicated appliance passports — a dishwasher and a refrigerator — built block by block on the product-group regulations in sections 5 and 6. The honesty rules of section 14 apply unchanged: the models are fictional, every product value is illustrative, the regulations and dates are real, and no ESPR delegated act currently requires a Digital Product Passport for home appliances.

The same Ledger passport model, in production today

The appliance passports in this dossier are not a paper exercise. The data model used for the dishwasher and refrigerator examples is the same Ledger Digital Product Passport model that already runs in live production demos for other product groups: textiles, leather goods, wine, furniture, steel, machinery and agri-food exports. The structure, the signing logic and the registry anchoring do not change from one product group to another. What changes is the content of each block, which follows the legal sources applicable to that product.

Live demos: ledgerconsortium.com/demo/ (seven product passports) and ledgerconsortium.com/demo-jiacc/ (olive-oil export passport).

Fixed structure of every Ledger passport

Worked example: "LavaLine iQ 14" household dishwasher

Worked example: "FrescoLine iQ Total No Frost" household refrigerator