From 5a1cf5e6e08a0db7c0ec6e569ae5953bedb4de50 Mon Sep 17 00:00:00 2001 From: LKSNDRTMLKV Date: Thu, 20 Aug 2026 21:19:53 +0200 Subject: [PATCH] docs: withdraw the electronics page and its claim of an ESPR delegated act that does not exist, and correct the ESPR sector table's electronics basis and unsold-goods article --- site/dpp-docs/astro.config.mjs | 4 +- .../src/content/docs/core/sectors.mdx | 4 +- .../content/docs/regulatory/_electronics.mdx | 45 +++++++++++++++ .../content/docs/regulatory/electronics.mdx | 56 ------------------- .../src/content/docs/regulatory/espr.mdx | 6 +- 5 files changed, 53 insertions(+), 62 deletions(-) create mode 100644 site/dpp-docs/src/content/docs/regulatory/_electronics.mdx delete mode 100644 site/dpp-docs/src/content/docs/regulatory/electronics.mdx diff --git a/site/dpp-docs/astro.config.mjs b/site/dpp-docs/astro.config.mjs index d3b0b25..99cf7e2 100644 --- a/site/dpp-docs/astro.config.mjs +++ b/site/dpp-docs/astro.config.mjs @@ -89,7 +89,9 @@ export default defineConfig({ { label: 'ESPR Overview', link: '/regulatory/espr' }, { label: 'Battery DPP', link: '/regulatory/battery' }, { label: 'Textile DPP', link: '/regulatory/textile' }, - { label: 'Electronics DPP', link: '/regulatory/electronics' }, + // Electronics DPP is withdrawn pending a rewrite — its source is + // `_electronics.mdx`, which the underscore keeps out of the content + // collection. Restore this entry with the page, not before it. { label: 'Access Control', link: '/regulatory/access-control' }, { label: 'EU Central Registry', link: '/regulatory/central-registry' }, ], diff --git a/site/dpp-docs/src/content/docs/core/sectors.mdx b/site/dpp-docs/src/content/docs/core/sectors.mdx index 02ef6da..62db23b 100644 --- a/site/dpp-docs/src/content/docs/core/sectors.mdx +++ b/site/dpp-docs/src/content/docs/core/sectors.mdx @@ -3,7 +3,7 @@ title: Extending it — sectors & plugins description: New regulation arrives sector by sector and keeps moving; the core absorbs it through a single extension seam, so a new sector is a plugin, not a rewrite. --- -ESPR does not arrive all at once. It lands sector by sector — batteries, then textiles, then electronics — and each sector's rules keep changing as the delegated acts are finalised. The core is built so that movement is normal: every sector's compliance logic enters through one seam. +Product-passport obligations do not arrive all at once. They land sector by sector — batteries first, textiles next — and each sector's rules keep changing as the delegated acts are finalised. The core is built so that movement is normal: every sector's compliance logic enters through one seam. ## One seam, many sectors @@ -20,4 +20,4 @@ The seam is an architectural boundary, never a commercial one. The built-in sect ## Read next - [What the core does](/core/overview) — the standard sectors plug into. -- [Battery DPP](/regulatory/battery) · [Textile DPP](/regulatory/textile) · [Electronics DPP](/regulatory/electronics) — sectors in context. +- [Battery DPP](/regulatory/battery) · [Textile DPP](/regulatory/textile) — sectors in context. diff --git a/site/dpp-docs/src/content/docs/regulatory/_electronics.mdx b/site/dpp-docs/src/content/docs/regulatory/_electronics.mdx new file mode 100644 index 0000000..461cb1b --- /dev/null +++ b/site/dpp-docs/src/content/docs/regulatory/_electronics.mdx @@ -0,0 +1,45 @@ +--- +title: Electronics DPP +description: Withheld pending a rewrite against the governing ecodesign and energy-labelling regulations. +--- + +{/* + UNPUBLISHED — the leading underscore excludes this file from the content + collection, so no /regulatory/electronics route is built. Do not remove it + until the page has been rewritten and reviewed. + + WHY THIS CAME DOWN (2026-08-20) + + The previous version of this page asserted an ESPR electronics delegated act + "adopted on 18 March 2026" and "in force on 1 April 2026", a two-tier rollout + with dated compliance windows, and four named priority product classes. None + of it is traceable to any instrument in the Official Journal. It also listed + foldable-display devices as first in scope, which the governing regulation + expressly excludes, and told a named class of manufacturer that they were + already subject to the obligation. + + It was withdrawn rather than corrected in place, because every sentence on the + page inherited from the act that does not exist — including its framing as + "the most commercially significant DPP mandate in the near term". + + WHAT IS ACTUALLY TRUE + + Electronics is not an ESPR sector. Its basis is ecodesign and energy + labelling: Regulation (EU) 2023/1670 Art. 1(1) and Regulation (EU) 2023/1669, + in force since 20 June 2025, covering smartphones, other mobile phones, + cordless phones and slate tablets — and only those. Laptops, monitors, + televisions, servers, routers, chargers, earphones and PCBs carry no DPP + obligation, in force or dated, under any EU instrument. + + WRITING THE REPLACEMENT + + The sector manifest in dpp-core (crates/dpp-domain/sectors/electronics.json) + is the single home for act numbers, regulatory status and applicability dates. + Source this page from it or from primary text. Do not restate a regulatory + detail from memory, and do not carry anything forward from the version this + replaced. + + Four live references pointed at this route and were repointed when it came + down — the docs sidebar, the sector list on the core sectors page, and two + sentences on the ESPR overview. Restoring the route means restoring them. +*/} diff --git a/site/dpp-docs/src/content/docs/regulatory/electronics.mdx b/site/dpp-docs/src/content/docs/regulatory/electronics.mdx deleted file mode 100644 index 397fd55..0000000 --- a/site/dpp-docs/src/content/docs/regulatory/electronics.mdx +++ /dev/null @@ -1,56 +0,0 @@ ---- -title: Electronics DPP -description: The electronics delegated act under ESPR — tiered scope, data requirements, the repairability dimension, and where it stands. ---- - -import { Aside } from "@astrojs/starlight/components"; - -The electronics delegated act was adopted on 18 March 2026 and entered into force on 1 April 2026. It is the most commercially significant DPP mandate in the near term because of the sheer volume of electronics placed on the EU market and the tiered effective dates that create two distinct compliance windows. - -## Scope and timeline - -The act applies to electrical and electronic equipment (EEE) placed on the EU market, with a tiered rollout: - -| Tier | Product category | Effective date | -|---|---|---| -| **High-end** | AI servers, high-performance computing, high-end PCBs, foldable-display devices | 1 April 2026 (immediate) | -| **Low-end** | Consumer electronics — earphones, chargers, cables, small household appliances, and other general EEE | 1 January 2027 | - -The tiered structure means that high-end manufacturers are already subject to DPP requirements, while low-end manufacturers have until the end of 2026 to prepare. Both tiers share the same data categories; the difference is the deadline. - -## Data requirements - -The electronics DPP carries the following data categories: - -**Product identity** — manufacturer identification, product model, product code, place of manufacture. These are the base details every passport carries. - -**Eco-design parameters** — carbon footprint declaration (product-level, following the methodology in the act's annexes), energy efficiency class, material efficiency indicators. These feed the open compliance calculators. - -**Hazardous substances** — Substances of Very High Concern (SVHC) as defined under REACH, and CMR (carcinogenic, mutagenic, toxic to reproduction) substances. The passport must declare presence or absence, with concentration data where applicable. - -**Recycling and end-of-life** — disassembly instructions, material-recovery information, spare-parts availability (including the number of years spare parts are guaranteed to be available), and preparation for re-use indicators. The EU's 2025 repairability rules for smartphones and tablets are directly relevant here — the repairability scoring framework feeds into this data category. - -**Supply-chain traceability** — the chain from component supplier to finished product, with geographic origin information where consumer-protection regulators require it. - -## The repairability dimension - -Electronics is the first sector where repairability scoring has a mature regulatory framework feeding into DPP requirements. The EU's repairability label (applicable to smartphones, tablets, and expanding categories since June 2025) produces a score that the electronics DPP must carry, and an electronics passport carries it as a first-class field. - -This matters because repairability is not a static number — component availability changes, scoring methodologies are updated, and the delegated act's annexes may revise what constitutes a "repairable" product. Odal handles that by versioning the rules and recording which version a passport was validated against. - -## Where it stands - - - -The groundwork is in place: electronics slots into the same sector seam every other sector uses, so what remains is finalising the fields against the adopted act and validating them on a real manufacturer's data set. The open work — reading the act's annexes to fix the field mapping, settling the carbon-footprint methodology, and pinning down concrete fields like the spare-parts availability guarantee — is research against the regulation, not architectural change. - -Until those fields are pinned to the adopted act, an electronics passport is validated structurally but not yet given a binding compliance verdict — the same *not-yet-assessed* stance every sector takes where the law has not fully landed, described in the [ESPR Overview](/regulatory/espr). - -## Read next - -[Battery DPP](/regulatory/battery) — the battery-sector delegated act, the nearest hard mandate. -[Textile DPP](/regulatory/textile) — the textile-sector delegated act and the unsold-goods provision. -[ESPR Overview](/regulatory/espr) — the framework regulation. -[Access Control (Art. 10)](/regulatory/access-control) — the three-tier access model that applies across all sectors. diff --git a/site/dpp-docs/src/content/docs/regulatory/espr.mdx b/site/dpp-docs/src/content/docs/regulatory/espr.mdx index 6f24e2c..f72ec6c 100644 --- a/site/dpp-docs/src/content/docs/regulatory/espr.mdx +++ b/site/dpp-docs/src/content/docs/regulatory/espr.mdx @@ -42,14 +42,14 @@ ESPR is a framework; the binding detail arrives through per-product-group delega | Sector | Regulatory basis | Status today | |---|---|---| | **Battery** | EU 2023/1542 | In force — passport mandatory 18 Feb 2027; substance limits enforced now | -| **Textile** | ESPR delegated act (in drafting) | Structural validation now; unsold-goods ban (Art. 22) applies from 2026 | -| **Electronics** | ESPR delegated act (adopted Mar 2026) | Phasing in — high-end from Apr 2026, the rest from Jan 2027 | +| **Textile** | ESPR delegated act (in drafting) | Structural validation now; unsold-goods ban (Art. 25) applies from 2026 | +| **Electronics** | EU 2023/1670 + 2023/1669 — ecodesign and energy labelling, not ESPR | In force since 20 Jun 2025 for smartphones, other mobile phones, cordless phones and tablets | | **Steel · Aluminium** | CBAM 2023/956 / ESPR | Reference benchmarks only; no DPP mandate yet (aluminium expected ~2030) | | **Construction** | CPR 2024/3110 | Awaiting delegated acts (2028–2032) | | **Toys** | EU 2025/2509 | Awaiting delegated act (~2030) | | **Furniture · Detergent · Tyre** | ESPR | Seams in place; awaiting delegated acts | -Battery, textile, and electronics have dedicated pages below; the rest run on the same mechanism, waiting on their regulation. +Battery and textile have dedicated pages below; the rest run on the same mechanism, waiting on their regulation. ## What a compliance result actually claims