ESPR evidence for durability, repairability, and recyclability

ESPR Article 4 empowers the Commission to set ecodesign requirements through delegated acts. A durability, repairability, or recyclability evidence file should first identify whether a delegated act covers the product group, which requirements it sets, and when those requirements apply.

Do not write product-group limits, scores, test methods, or pass/fail thresholds into the evidence model until the delegated act or an incorporated standard, common specification, transitional method, or reliable method supports them.

ESPR separates performance requirements from information requirements. Performance evidence supports whether the product meets minimum, maximum, or non-quantitative requirements for parameters such as durability, repair and maintenance, and design for recycling. Information evidence supports what must be communicated to customers, treatment facilities, authorities, or other actors.

For this topic, the evidence model should map each claim to one of those tracks. A repairability score, durability score, end-of-life disassembly information, spare-part availability field, material-composition field, or recycling-capability disclosure may be an information requirement even when a separate performance limit also exists.

The evidence file should show how each durability, repairability, or recyclability requirement can be verified. ESPR requires ecodesign requirements to be verifiable and allows verification by direct product checks or technical documentation. Article 39 then points tests, measurements, and calculations to harmonised standards or other reliable, accurate, and reproducible methods that meet the delegated act's requirements.

For internal production control, Annex IV describes technical documentation that makes conformity assessable. For this page's subject matter, that means keeping the delegated-act requirement, applied standard or method, design and manufacturing records, calculations, measurement results, test reports, and the copy of information supplied under Article 7 together.

Many durability, repairability, and recyclability fields depend on upstream materials, components, software, spare parts, maintenance services, and end-of-life information. ESPR defines supply-chain and value-chain concepts and, when a delegated act specifies Article 38 obligations, supply chain actors must provide available relevant information free of charge, allow assessment where information is not provided, and enable verification by notified bodies and authorities.

Supplier evidence should therefore be requestable, versioned, and tied to the exact product, component, material, service, or facility it supports. It should not be converted into a public claim unless the evidence owner can show the requirement, method, data source, and allowed disclosure route.

Durability evidence must describe the marketed product, not a test-only configuration. Article 40 prohibits products designed to detect testing and improve the measured result, test instructions that manually alter performance for a better result, and designs that worsen regulated or functional performance shortly after the product enters service.

Software and firmware changes belong in the evidence file when they can affect a regulated product parameter or user-facing function. Article 40 permits worsening beyond margins set by the applicable delegated act only with the customer's explicit prior consent, and an update may never make the product non-compliant with the requirements that applied when it was placed on the market or put into service.

The applicable delegated act decides the underlying information requirement; the DPP provides the specified disclosure and access mechanism. Under Article 9, products can only be placed on the market or put into service with a DPP where the applicable delegated act requires one, and DPP data must be accurate, complete, and up to date.

For durability, repairability, and recyclability, the DPP mapping should identify which fields are mandatory, who may access or update them, the data carrier and identifier level, and how long the passport remains available. Annex III lists candidate data categories; the delegated act selects the required or permitted fields. Article 10(4) separately requires the placing operator to make a back-up copy available through a DPP service provider.

The regulation and an applicable delegated act are the binding sources. Commission explanations, standards-body material, and CIRPASS outputs provide implementation context but do not create product-specific conformity duties.

Before using the evidence for a product, confirm the adopted delegated act, its application date and transitional provisions, the current harmonised-standard or common-specification status, and any later amendments.