Ecodesign for smartphones and tablets

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

From 20 June 2025 ecodesign and energy labelling requirements for smartphones, cordless phones, other mobile phones and slate tablets will become mandatory.

Ecodesign requirements

The growing demand for smartphones and tablets, along with their wide range of features, has led to an increased need for energy and materials. The devices are often replaced before they reach the end of their useful (technical) life and not enough is done to reuse or recycle them. Reasons for the EU to implement of Regulation (EU) 2023/1670 which lays down the ecodesign requirements for smartphones and tablets.

Regulation (EU) 2023/1670 is established within the Ecodesign framework Directive 2009/125/EC.

The ecodesign requirements for smartphones and tablets are related to:

  • Design for reliability (resistance to drops, scratches, dust and water);
  • Ability to be disassembled and repaired;
  • Availability of operating system version upgrades;
  • Data deletion and the transfer of functionalities after use;
  • Provision of appropriate information for users, repairers and recyclers;
  • Battery endurance.

Cordless phones

Currently ecodesign requirements for cordless phones are included in Regulation (EU) 2023/826 regarding off mode and  standby mode. To prevent any overlap, cordless phones will be excluded from Regulation (EU) 2023/826.

Energy labelling

Energy labels on smartphones and slate tablets must apply to Regulation (EU) 2023/1669 and will also become mandatory from 20 June 2025. Regulation (EU) 2023/1669 supplements energy labelling framework Regulation (EU) 2017/1369.

Obligations

Suppliers shall ensure that each individual product is accompanied with accurate printed energy labels (Annex III) and with product information sheets (Annex V). The supplier is also obliged to enter information in the European Product Database for Energy Labelling (EPREL).

Dealers shall display the energy label at the point of sale (stores and websites) in such a way that is clearly visible for consumers so they can make an informed buying decision. The regulation prescribes specific requirements for information to be provided in advertisements, promotional material and in distance selling on the internet.

Energy label

The following information shall be included in the label:

No. Description
(I) QR code (in black)
(II) Trade mark in black and bold
(III) Model identifier in black
(IV) Energy efficiency classes ranging from A to G
(V) Energy efficiency class (actual)
(VI) Battery endurance per cycle
(VII) Free fall reliability class
(VIII) Repairability class / index (R)
(IX) Battery endurance in cycles
(X) Ingress Protection (IP) code
(XI) Regulation number: ‘2023/1669’.

No circumvention

The entry date of Article 6 ‘Circumvention’ of Regulation (EU) 2023/1670 is set on 20 September 2023. From this date it is not allowed to:

  • Place on the market products designed to alter their behaviour or properties when tested;
  • Prescribe test instructions specific for when these products are tested;
  • Place on the market products designed to alter their behaviour or properties negatively within a short period after being put into service.

These requirements prevent that products are placed on the market which have a better score on the energy label than they actually should have based on actual usage.

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