80% of smartphones lack required repair information: the market surveillance lesson for the Digital Product Passport

One year after the EU's ecodesign and energy-labelling rules for smartphones and tablets started to apply, most of the repair information they require is missing. That is the finding of a report published on 7 September 2026 by Right to Repair Europe, a coalition of repair and consumer organisations. For anyone building or enforcing a Digital Product Passport, the details are worth reading closely, because the passport relies on the same mechanism: self-declared data in an EU database.

What the report found

The coalition analysed more than 7,000 records in EPREL, the European Product Registry for Energy Labelling, plus spot checks in physical stores and online. Its headline numbers:

• Of 2,334 smartphone records for models placed on the market over the previous year, only 18% listed an accessible website with spare-part prices or repair instructions.
• About 50% of records left the URL field blank.
• 19% linked to product pages that did not contain the required repair data.
• The remainder pointed to references described as unhelpful, from "see manual" to redirects to third-party marketplaces.
• The energy label itself was missing on roughly 30% of smartphones offered by online retailers checked and 19% in physical stores. On one German retailer's site, 690 of 1,671 smartphones were offered without the label.

The rules in question are Commission Regulation (EU) 2023/1670 on ecodesign requirements for smartphones, other mobile phones, cordless phones and slate tablets, and Commission Delegated Regulation (EU) 2023/1669 on their energy labelling. Both apply since 20 June 2025. The label carries a repairability class from A to E that manufacturers calculate and declare themselves.

The coalition's sharpest observation is not about manufacturers. It notes that no public authority appears to have checked the declared data, since thousands of blank fields went unnoticed.

Why this matters for the DPP

The ESPR builds the Digital Product Passport on the same principle: the economic operator placing the product on the market is responsible for the passport's content. The central registry, governed by Implementing Regulation (EU) 2026/1778, includes a verification platform that confirms a passport exists and is complete against the applicable data model. Completeness is not accuracy. Whether a declared recycled content share, a durability score or a repair link is true remains a job for market surveillance.

Three parallels stand out:

• Blank and placeholder fields. EPREL accepted empty URL fields for a year. A DPP schema can make fields mandatory, but it cannot stop an operator from entering a link that leads nowhere useful. Validation rules need to test what the field points to, not just that it is filled.
• Retail display. The label was missing at the point of sale for a large share of devices. The DPP equivalent is the data carrier and the requirement that the passport be accessible where the product is offered, including online. Enforcement will need to look at listings, not only at registry entries.
• Self-declared scores. The repairability class is calculated by the manufacturer. Several ESPR product groups will carry declared performance classes in their passports. The coalition asks for full calculation reports to be published so that scores can be checked.

The recommendations, read as a DPP checklist

Right to Repair Europe calls for more market surveillance resources, publication of the calculation reports behind repairability scores, an EU-wide platform for reporting non-conformity, and automated detection of blank compliance fields. Each of those maps onto a design decision for the DPP system: budgets for national authorities, mandatory publication of methodology evidence in the restricted tier of the passport, a reporting channel for incorrect passports, and registry-side automated checks that go beyond schema completeness.

What to do now

• If you sell smartphones or tablets in the EU, check your EPREL entries today. The report shows that blank and broken links are the norm, not the exception, and that is the easiest non-conformity for an authority to find once it starts looking.
• If you are preparing a DPP for any product group, treat every declared field as something an authority or a competitor could test. Keep the evidence behind classes and scores ready to disclose.
• Follow how the Commission and Member States respond. The report's timing, a year into the rules, is the kind of milestone at which enforcement priorities get set.

Primary source: Right to Repair Europe, One year into EU ecodesign rules, 80% of smartphones still lack required repair information.