On 31 August 2022 the European Commission published draft ecodesign and energy labelling regulations for smartphones and tablets. The proposal was drawn up in accordance with the requirements of the EU Ecodesign Directive 2009/130/EC and the EU Energy Labelling Regulation (EU) 2017/1369, and is expected to be signed into law in 2023, published in the Official Journal and given short transition periods of 12 and 18 months respectively.

1. Ecodesign Regulation
To improve the energy efficiency and durability of smartphones and tablets, strict requirements are laid down on repairability, reliability and recyclability through ecodesign principles such as the public right to repair, greater product transparency and recycling and reuse.
Under the ecodesign requirements, manufacturers, importers or authorised representatives must be able to continue supplying key spare parts, such as batteries, back covers, screens, front and rear cameras and speakers, to technicians or users for five years after the product is placed on the market and until it is withdrawn, so that the product can continue to be repaired and recycled.
If a battery or back cover assembly cannot be supplied to users, the manufacturer must ensure that the product design meets the following requirements:
battery cycle life of at least 500 cycles, with at least 83% of remaining capacity after 500 cycles;
battery cycle life of at least 1000 cycles, with at least 80% of remaining capacity after 1000 cycles;
IP67 dust and water protection design.

The regulation requires manufacturers, importers or authorised representatives to publish repair manuals on their free websites, providing professional technicians or users with information on repair and maintenance, including product identification, exploded views, fault diagnosis information, the necessary circuit diagrams, position designations and the tools required for disassembly.

To improve the durability of smartphones and tablets, the regulation requires products to meet certain reliability requirements:
drop-resistant design;
screen design with Mohs hardness level 4;
IP44 dust and water protection rating design;
battery cycle life of at least 500 cycles;
improved battery management functions and optimized charging efficiency.


The regulation requires manufacturers to be transparent about the key raw materials used in smartphones and tablets. For plastic parts weighing more than 50 g, the polymer type of the plastic part must be marked, with the appropriate standard symbol or abbreviation placed between the greater-than and less-than markers specified in existing standards. For some raw materials (cobalt, tantalum, neodymium and gold), the weight range must be published on the relevant website, and end-of-life recycling of the product must comply with the EU WEEE Directive (2002/96/EC).

To encourage reuse of these devices, manufacturers, importers or authorised representatives must ensure that the owner of the device cannot recover encrypted data after handing in the old device, including through a software function that resets the device to factory settings and securely erases the default address book, SMS and call records. Operating system updates must be available for at least three years, and security updates must be provided for five years or more from the last date the product concerned was placed on the market. Manufacturers must also ensure that these updates do not degrade the performance of older devices.

2. Energy Labelling Regulation
For the first time, the European Commission has proposed a corresponding energy labelling regulation for all smartphones and tablets placed on the EU market. The regulation includes an energy efficiency rating for the product and, for the first time, adds the repairability rating, durability rating, IP rating, battery endurance and battery life to the label. Under the regulation, all smartphones and tablets must be accompanied by an energy efficiency class label and must be registered in the EU public product database EPREL before they can be sold.

Label notes:
(i) QR code
(ii) Trademark
(iii) Product model identifier
(iv) Energy efficiency class A to G
(v) Nominal energy efficiency class of the product
(vi) Battery endurance of the product
(vii) Drop resistance rating
(viii) Repairability rating
(ix) Battery life
(x) IP rating
(xi) Code of the energy efficiency regulation