Review and Analysis of ICT Regulations Under the Ecodesign Directive: Product Regulations Shifting from Energy Efficiency to Circular Economy

Information and communication technologies (ICT), such as televisions, cell phones and computers, are an indispensable part of everyday life. They make life easier, but they also have a significant environmental impact, particularly in terms of energy consumption in the use phase and demand for critical raw materials. Since 2005, the EU Ecodesign Directive has aimed to improve the environmental performance of energy-consuming and later energy-related products and plays an important role in the regulation of ICT products. For a long time, the focus of regulations developed under the Ecodesign framework has been on energy consumption in the use phase. However, for ICT products, both the raw materials and the end-of-life phases are of particular importance. This paper examines how products, and in particular ICT products, have been regulated under the Ecodesign Directive. Building on an existing assessment, we conduct an analysis to identify the coverage of specific, generic and informational circular economy related requirements. We use a keyword analysis of the legislative texts and compare ICT products with other product groups such as lighting products and white goods. We find a clear increase of circular economy requirements in recent ICT legislation, with many requirements for spare parts similar to the white goods product family. A particularly strong increase of circular economy requirements was found in the 2023 smartphone regulation, which also includes several requirements on durability, which were previously mainly found in lighting regulations. The high level of ambition of recent regulations could be seen as the next step in the evolution of ecodesign, paving the way for an expansion of the scope beyond a focus on greenhouse gases and energy-related products.