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Sustainability Legislation for the Electronics & IT Sector

Electronics & IT are sectors with a significant environmental impact, but also areas with vast opportunities for sustainability improvements. In this article, we outline the key pieces of sustainability legislation relevant to these sectors.

Are you working in the electronics & IT sector? These are sectors with a significant environmental impact, but also areas with vast opportunities for sustainability improvements. In the coming years, more and more (international) legislation will affect businesses. Some of this legislation is specifically aimed at the electronics & IT sector, while other parts will apply to all sectors. In this article, we outline the key pieces of sustainability legislation relevant to you.

Digital Product Passport

The Digital Product Passport (DPP) will become mandatory for products placed on the EU market, and consumer electronics are one of the first product categories that will be required to adopt this passport.

The Digital Product Passport is a label you must attach to your products. It contains detailed environmental information throughout the product's lifecycle, making this environmental information accessible to everyone interested in the sustainability of the product, including consumers, customers, investors, or government agencies.

The following information must be included on the digital product passport:

  • Information on sustainable performance
  • Traceability
  • Declaration of conformity
  • Technical documentation
  • User manuals
  • Information about the manufacturer, importer, or authorized representative.

The goal of the DPP is to enhance transparency and make products and materials traceable. This allows them to be utilized, designed, and used in a circular and sustainable manner.

Additionally, the passport combats greenwashing: by mandating transparency about the origin of a product's materials, it becomes harder to make false or unfounded sustainability claims.

The introduction of the digital product passport is expected following the final approval of the Ecodesign for Sustainable Products Regulation (ESPR) in 2024. It will be mandatory for both products manufactured within the EU and those imported.

Learn more about the Digital Product Passport:

Waste from Electrical and Electronic Equipment Directive (WEEE)

The volume of electronic waste, also known as e-waste, is rapidly increasing and is the fastest growing waste stream globally. This waste comprises a variety of devices such as mobile phones, computers, televisions, as well as refrigerators, household appliances, lamps, medical devices, and solar panels.

The Waste from Electrical and Electronic Equipment Directive, the WEEE Directive, focuses on the collection, recycling, and reuse of this electronic waste. Companies are required to ensure the proper disposal of discarded electronic devices and are encouraged to increase recycling rates.

The objective of the WEEE is to contribute to sustainable production and consumption by:

  • Preventing the generation of electronic waste
  • Contributing to the efficient use of resources and the recovery of secondary raw materials through reuse, recycling, and other recovery methods
  • Enhancing the environmental performance of all those involved in the lifecycle of electrical and electronic equipment

By improving the collection, treatment, and recycling of electronic devices at the end of their life, resource efficiency can be increased and the transition to a circular economy can be supported.

Restriction of Hazardous Substances in Electrical and Electronic Equipment Directive

The Restriction of Hazardous Substances in Electrical and Electronic Equipment, or RoHS Directive, limits the use of certain hazardous substances in electrical and electronic equipment. This includes heavy metals, flame retardants, and plasticizers.

Its aim is to reduce environmental impact and protect public health by preventing these substances from entering the environment. The RoHS Directive ensures that hazardous substances are replaced with safer alternatives.

Thus, the directive promotes the recyclability of electronic devices, as these devices and their components contain fewer hazardous substances. At the same time, it ensures a level playing field for manufacturers and importers of electronic devices in the European market.

Critical Raw Materials Act

"Critical Raw Materials" are resources that are scarce because they are difficult to extract and are needed for a wide range of applications. For instance, lithium, cobalt, and nickel are used in battery production; gallium is used in solar panels; and boron in wind technologies.

To continue meeting the demand for these resources safely and sustainably, the EU has introduced The Critical Raw Materials Act. This initiative aims to reduce the EU's dependence on imports of these materials from other parts of the world.

The European Critical Raw Materials Act also impacts organisations in the IT & electronics sector with its goals:

1.  Strengthening various stages of the value chain for strategic raw materials

This includes the following allocations:

  • At least 10% of the EU's annual need for these raw materials must come from domestic extraction.
  • 40% of the required processing of these raw materials must take place within the EU.
  • 15% of the recycling of these raw materials must be performed within the EU.

2. Diversifying imports of strategic raw materialsThe goal is to be less dependent on specific other countries, with no single country providing more than 65% of the EU's annual consumption of a specific strategic raw material by 2030.

3. Improving monitoring and mitigation of supply risks associated with critical raw materials.

4. Ensuring the free movement of critical raw materials and products containing them in the Union market.This is aimed at enhancing circularity and sustainability, thereby ensuring a high level of environmental protection.

CSRD (Corporate Sustainability Reporting Directive)

Another upcoming legislation is the CSRD. You might have heard about it; it's getting a lot of attention across the business world. Introduced by the European Union, the CSRD aims to strengthen and expand the requirements for corporate sustainability reporting. The goal is to enhance transparency, accountability, and sustainable practices among all European companies.

The first companies need to comply with the CSRD legislation starting in 2025. This means these companies need to start monitoring their impact from 2024, otherwise, they will have nothing to report.

The companies that must first comply with the CSRD are organisations that:

  • Have more than 250 employees
  • Have a turnover exceeding €50 million
  • Have a balance sheet total exceeding €25 million

And from 2027, all companies based in the EU (with more than 10 employees) must report according to the CSRD.

Our tip: don't leave the CSRD as something to fix at the last minute. Start early. The sooner, the better. Read our article on the CSRD to learn more about the implementation of this legislation and get tips on how to get started.

Legislation on communicating your sustainable performance

The European Union has laws to protect consumers from being misled by producers and to enable them to make informed choices about their purchases. These laws are the Green Claims Directive and the Directive on Empowering Consumers for the Green Transition.

According to these directives:

  • General environmental claims and other misleading product information are prohibited.
  • Sustainability claims must be substantiated through environmental impact studies (such as an LCA).
  • Sustainability labels are only allowed if they are based on recognized certification programs or introduced by a governmental body.
  • Information about warranties must be clearly displayed, and a new label is introduced for products with an extended warranty period.

We will further explain both directives below.

Green Claims Directive

The Green Claims Directive promotes transparency and honesty in environmental claims. This directive requires all companies to provide clear and substantiated information about the environmental benefits of their products, which is essential for building consumer trust and preventing greenwashing.

This directive complements the ESPR and CSRD, and strengthens the EU's efforts to create a more reliable market for sustainable products.

Directive on Empowering Consumers for the Green Transition

The Directive on Empowering Consumers for the Green Transition aims to provide consumers with reliable, accessible, and understandable information about the sustainability of products. With the requirement for clear information provision, companies must be able to convincingly demonstrate why their products or services are considered 'sustainable,' in a way that is verifiable and not misleading.

Read more in our article: How to communicate about your sustainable achievements & progress - Hedgehog Company (

How can you comply with all these laws & legislations?

The regulations described above require significant adjustments and preparation by companies. Therefore, start on time to save yourself last-minute work and a lot of stress. Below, we list several steps you can begin with now.

Inventory and analysis: Start with a thorough inventory of all current products and processes. Identify which materials and substances are used and trace their origins. This preparation will help you with the Digital Product Passport and RoHS, as well as broader regulations like the Critical Raw Materials Act.

Supply chain management: Strengthen relationships with suppliers and ensure transparency in your supply chains. This will help ensure sustainability and reduce risks associated with obtaining and using critical raw materials, as prescribed by the Critical Raw Materials Act.

Data and reporting capacity: Invest in systems for data collection and management that enable detailed reporting. This will be essential for complying with the CSRD and providing the necessary information for the Digital Product Passport.

Sustainable design and innovation: Encourage innovation in product design to reduce reliance on hazardous substances and critical materials and increase the recyclability of your products. This aligns with the Critical Raw Materials Act, RoHS, WEEE, and the general shift towards a circular economy.

Training and awareness: Ensure training for staff on new regulations and their implications for the company. This will help create a corporate culture focused on compliance and sustainability.

Strategic planning: Develop a long-term strategy that focuses not only on compliance but also on leveraging opportunities that new regulations may offer. This could include exploring new markets for recycled materials or offering more sustainable product options that may be attractive to environmentally conscious consumers.

Contact us if you need guidance or have questions about how your organisation can take steps towards greater sustainability.

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