What Emerging Circularity Policies Mean for the Electronics Industry

Estimated reading time: 5 minutes

As Europe accelerates toward a circular economy, electronics manufacturers face a wave of new sustainability requirements that will redefine product design, materials management, and end-of-life strategies. During a Nov. 11 webinar co-hosted by the Global Electronics Association and the Anthesis Group, industry leaders outlined the regulatory landscape shaping the next decade, including the Eco-design for Sustainable Products Regulation (ESPR), the Right to Repair (R2R) Directive, and the Extended Producer Responsibility (EPR) regulatory framework.

The key takeaway: Circularity is moving from an optional organizing principle of electronics manufacturing to a mandatory one, with emerging European policies leading the way, yet impacting global value chains.

The Policy Web Behind Circularity

Opening the session, Diana Radovan, the Global Electronics Association’s sustainability policy director, described a fast-evolving policy environment in which environmental, chemical, and digital policies are increasingly converging.

“Topics that used to be separate—such as chemicals policy, sustainable design, materials sourcing, and supply chain data —are now deeply interconnected,” Radovan said. “This regulatory development is reshaping how companies operate and comply beyond Europe.”

Radovan provided an overview of the current European political and sustainability policy landscape, highlighting the Clean Industrial Deal and the upcoming Circular Economy Act (expected at the end of 2026). Key legislative initiatives to match Europe’s ambitious goals also include a new Extended Producer Responsibility framework, expected in 2025–26, and a revised Waste from Electrical and Electronic Equipment (WEEE) Directive.

For the electronics value chain, Radovan’s message indicated that compliance is becoming more comprehensive and interdependent.

The Backbone of Circularity: ESPR and Its Implications

Jessica Onyshko, director of Products, Materials, and Chemical Solutions at Anthesis Group, provided an in-depth update on the Eco-design for Sustainable Products Regulation (ESPR)—the foundation for circular product policy in the EU.

“The ESPR is about making sustainable products the norm,” Onyshko said. “It creates a framework for delegated acts that define detailed product-specific requirements over time, from repairability and recyclability to product carbon footprint and information transparency.”

The ESPR introduces horizontal requirements that cut across product categories. For the electronics sector, this could include design for repairability, mandatory availability of spare parts, and access to maintenance information across the supply chain. New recycled content and recyclability standards for electrical and electronic equipment are also advancing. Phases one and two of the EU’s preparatory studies have already concluded, with final legislative drafting underway.

“Electrical and electronic equipment has been identified as a top priority,” Onyshko said. “The Commission is moving from analysis to drafting binding measures, which are likely to include product composition data, minimum recycled content thresholds—especially for plastics—and recyclability performance scores.”

Digital Product Passports: The Next Data Challenge

A central mechanism for enforcing ESPR is the Digital Product Passport (DPP), a data system enabling product traceability and circularity information across the supply chain.

Onyshko emphasized that digital product passports will soon become operational in the electronics sector, modeled on the EU’s Battery Passport initiative. “DPPs will capture information like material composition, recycled content, and repair instructions,” she said. “They’re one of the most powerful tools we’ve ever had for enabling transparency and accountability throughout the product lifecycle.”

Right to Repair: From Policy to Practice

Another pillar of Europe’s circularity agenda is the Right to Repair Directive, adopted earlier this year. This policy ensures consumers can have products repaired “more easily, affordably, and for longer,” Onyshko said, both during and after warranty periods. “Right to repair builds on ESPR. We move from repairability by design to repairability in practice.”

EPR and the WEEE Revision: Closing the Loop

Extended Producer Responsibility (EPR) remains the cornerstone of Europe’s waste strategy. The WEEE Directive, which governs electronics take-back and recycling, is under review, with a potential conversion from a directive to a regulation to ensure harmonized implementation across member states.

“Only a few countries have met the 65% collection target,” Onyshko said. “There are persistent issues around illegal trade, inconsistent calculation methods, and low recovery of critical raw materials.”

Industry Response: Sustainability Advocacy related to Circularity Policies

Radovan then outlined recent advocacy efforts regarding emerging circularity policies. The Global Electronics Association, on behalf of its members, has recently submitted consolidated feedback to the Circular Economy Act consultation, which ended on Nov 6th, emphasizing the need for a balanced, innovation-driven approach, which takes into account global value chain realities and builds on increased regulatory coherence. Read more about this effort on the Association’s blog: The Global Electronics Association Urges EU Policymakers to Advance the Circular Economy Act for a More Resilient Electronics Industry | electronics.org.

In addition, together with other associations, the Global Electronics Association has co-signed a letter urging European policymakers to ensure consistency across policies that deal with the Substances of Concern concept and directly impact the electronics supply chain. The timing of this letter was chosen in light of the upcoming REACH revision.In this joint effort, the associations advocated for a coherent regulation of the SoC concept under REACH instead of fragmentation across multiple policies, with clear requirements for companies, thus adding to increased business certainty. Find the joint letter here: Global Electronics Association Supports Industry Call on Substances of Concern.

IPC Standards: Tools for Compliance and Circularity

To close the webinar, Francisco Fourcade, next-generation standards manager at the Global Electronics Association, presented the role of standards in achieving circularity goals. IPC’s expanding portfolio of environmental and sustainability standards—including IPC-1402 (greener cleaning products), IPC-175x series (materials declaration),  IPC-1782 (traceability), and IPC-1783 CO2E (data collection and reporting on CO2E)—is designed to help manufacturers implement the data and process controls demanded by upcoming EU regulations.

Take-home Message

Players in the global value chain need to be prepared for the evolving sustainability framework. by conducting compliance assessments, building product data systems, integrating design-for-circularity, and engaging in advocacy and standardization. The Global Electronics Association will continue to inform the electronics industry of regulatory updates and to engage on its behalf with relevant policymakers around the globe, to ensure smarter sustainability policies, in the spirit of regulatory coherence, business certainty and competitiveness, and a reduction in administrative burden. Contact DianaRadovan@electronics.org.