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What role does ecodesign play in the EU’s approach to circularity?

Updated: Jan 3

A short overview of electronics supply chains, modular devices, and the EU's regulations on ecodesign.


Redesigning electronics’ supply chains

E-waste is created when electrical and electronic equipment is disposed. It is the world’s fastest-growing waste stream with upwards of 50 million tons being produced every year. One reason for the large growth of e-waste is that it is often still deemed to be more profitable to create appliances with shorter lifespans and have customers purchase new products more frequently. The phenomenon of purposely limiting the life span of products to foster consumerism is often referred to as “planned obsolescence”. It takes on many “subtle and sophisticated” forms and can occur due to a variety of technological and sociological factors, such as “industrial design, cheaply made (and priced) goods, continuous product upgrading, advertising, and compromises in product quality”.


The rapid replacement of functional and durable products to newer versions has a negative impact on the environment. In line with this, the rapid obsolescence of electronics leads to the production of vast amounts of e-waste. Luckily, there are ample opportunities for businesses to contribute to safer and cleaner supply chains around e-waste. Making sure less e-waste is created, and that the e-waste that is produced is easier to recycle, is one way to tackle the issue. Another path to solving the problem would be creating electronic and electrical products with longer lifespans – which are easily repairable (for example, by using modular designs) and for which spare parts are readily available for longer periods of time.


Making repairs easier through modular devices

Modular devices can help consumers repair their electronics themselves. They are designed in a way that allows them to be easily subdivided into smaller parts, so that broken or outdated parts can be replaced. An excellent example of this are the smartphones created using the Phonebloks concept or those manufactured by Fairphone or SHIFT. Moreover, Nokia also recently launched its G22 smartphone, which allows for easy repair of the battery, screen, charging port, and back cover.


If the battery, screen, or another part of these phones’ breaks, it can easily be repaired or replaced and the whole phone does not need to be disposed of. The devices’ modularity also allows parts to be swapped out if an updated part is wanted. So, for example, if you wanted a better phone camera, you could swap out the old camera of your phone for a newer or better one rather than buying a whole new phone.


Design requirements under the EU’s Ecodesign Regulation

The Ecodesign Regulation aims to “improve EU products’ circularity, energy performance and other environmental sustainability aspects”. On 4 December 2023, the European Parliament and Council reached a provisional agreement on the revised regulation. The regulation will now be completed at a technical level. To come into force, the European Parliament and Council must then still formally approve their agreement on the revised regulation.


The new rules set out minimum requirements for smartphones and tablets sold on the EU market and will make “devices more energy efficient, durable and easier to repair”. The minimum standards on smartphones and tablets include the “[r]esistance to accidental drops or scratches, protection from dust and water, and use of durable batteries”. Moreover, the European Commission has set out that the batteries used in smartphones and tablets need to “withstand at least 800 cycles of charge and discharge while retaining at least 80% of their initial capacity”. There are also “rules on disassembly and repair, including obligations for producers to make critical spare parts available to repairers within 5-10 working days, and until 7 years after the end of sales of the product model on the EU market”. The rules also require the “availability of operating system upgrades for longer periods “, namely “for at least 5 years after the product has been placed on the market”. Finally, under the rules, there is to be “non-discriminatory access for professional repairers to any software or firmware needed for replacement”.


The European Parliament's Committee on the Environment, Public Health and Food Safety adopted its position on the Ecodesign Regulation on 15 June 2023. The Committee had notably said that “manufacturers [should] not limit the lifetime of a product through design features” and should assure that “consumers […] have access to repair guidelines”. Under the Committee’s specific suggestions, relevant products were only to be sold if they came with a “product passport”. The Committee explained that the “passport could enable consumers and businesses to make informed choices […], facilitate repairs and recycling, and increase transparency about the environmental impact”. The Committee also sought to place a “ban on the destruction of unsold textiles and electronic appliances”.


A “digital product passport” and a ban on the destruction of “unsold apparel, clothing accessories and footwear” have been adopted in the revised text of the regulation, but no ban was placed on the destruction of unsold electronic appliances. The revised regulation does, however, require “[e]conomic operators that destroy unsold goods […] to report annually [on] the quantities of products they discarded as well as their reasons why”. Moreover, the European Commission may add further product categories (such as unsold small electronics) to the regulation’s destruction ban later on.


The introduction of a common charger in the EU

One concrete example of a sustainable design requirement mandated by law on the EU market is the “common charger”. The European Commission created specific new legislation on chargers in 2022, as the previous voluntary approach did not have the desired effect. The resulting law, which was published in the EU’s Official Journal on 7 December 2022, mandates the use of a “common charger” for all portable electronic devices in the EU as of 2024 or 2026. Its aim is to “improve consumers’ convenience, [and] reduce the environmental footprint associated with the production and disposal of chargers, while maintaining innovation” and “avoiding market fragmentation”.


More specifically, Directive (EU) 2022/2380 mandates that USB-C be used as a common port for all electronic devices in the EU – meaning that consumers can “charge their devices with any USB-C charger, regardless of the device brand”. Through the harmonization, the EU also plans to “prevent different producers from unjustifiably limiting charging speed”. Thereby, the directive will “help to ensure that charging speed is the same when using any compatible charger for a device”.


Under the rules, consumers in the EU “will be able to purchase a new electronic device without a new charger”. The aim of this is to “limit the number of chargers on the market” as well as those “left unused”. Manufacturers will also be required to provide consumers with “relevant visual and written information about charging characteristics, including information on the power the device requires and whether it supports fast charging”. The aim of this is to “help consumers understand if their existing chargers meet their new device’s requirements and/or help them select a compatible charger”.


The new rules “will apply to all handheld mobile phones, tablets, digital cameras, headphones, headsets, portable speakers, handheld videogame consoles, e-readers, earbuds, keyboards, mice, and portable navigation systems as of 2024” and “to laptops as of 2026”. Through a set of transition periods, the EU will however give industry actors additional time to adapt to the new requirements. The European Commission has said that it will also “review [additional] categories of radio equipment that can accommodate the ‘common charging’ requirements by three years after entry-into-force of the Directive and every five years after that”.


The impact of ecodesign rules

Ecodesign can reduce some of the negative impacts that electrical and electronic equipment has on the environment. The consumption of resources can, for example, be reduced by designing “more efficient and sustainable products”. In line with this, the European Commission anticipates that the measures it has set out around the common charger will help consumers reduce the number of new chargers they buy. Concretely, “[r]educing production and disposal of new chargers is estimated to reduce [e-waste] by 980 tonnes yearly” and to “save [consumers] at least €250 million a year on unnecessary charger purchases”.


Sustainable product design in electronics can also reduce energy consumption and CO2 emissions. In line with this, according to the European Commission, the ecodesign measures in place in 2021 “saved EUR 120 billion in energy expenditure for EU consumers and led to a 10% lower annual energy consumption by the products in scope” that year. The European Commission estimates that by 2040, the new measures’ cumulative energy and greenhouse gas emissions savings could respectively reach 15 TWh and 1.7 million tons of CO2 equivalent. The energy saved is equivalent to the annual electricity use of approximately 2.6 million electric vehicles and could save consumers about €2.8 billion. The European Commission also estimates that the smartphones and tablets, which are produced in line with the new labelling standards under the EU’s Ecodesign Regulation, could annually save close to 14 terawatt hours of primary energy by 2030. This amounts to a third of these two devices’ current primary energy consumption.


Next month’s newsletter will explore the right to repair and its role in the EU’s approach to circularity. If you want to be notified when it comes out, please subscribe to our mailing list.


About the author

Christine Nikander is the founder of the environmental and social sustainability consultancy, Palsa & Pulk. She studied law at the universities of Columbia (New York), Edinburgh (Scotland), and Leiden (the Netherlands). Christine has been doing scholarly research into the legal and policy framework surrounding e-waste and conflict minerals since 2015.


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Read more about circular economy and e-waste here:


Read more about planned obsolescence here:

- Nikander, Christine. 2016. “E-Waste Trafficking as an Environmental Crime: Countering the Transboundary Movement of E-waste by Legally Limiting Planned Obsolescence.” Leiden University College The Hague (unpublished thesis, available on request).

- Guiltinan, Joseph. 2009. "Creative Destruction and Destructive Creations: Environmental Ethics and Planned Obsolescence." Journal of Business Ethics 89: 19-28, 21-22.

- Park, Miles. 2012. "E-waste and Obsolescence: Designing out toxicity." Design Research Society 2012: Bangkok. Bangkok: Chulalongkorn University, 10.


Read more about modular electronics here:


Read more about the Ecodesign Regulation here:


Read more about the EU’s common charger here:

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