EU Ecodesign — Smartphones & Tablets

Every EU-sold smartphone and tablet needs an energy label and repairability score.

Regulation (EU) 2023/1670 (ecodesign) and (EU) 2023/1669 (energy labelling) have been in force since 20th June 2025 — battery durability, drop/water resistance, spare-parts availability and a point-of-sale label are all tested requirements, not guidance.

Last updated 12th September 2026 · By and

EU Ecodesign for Smartphones & Tablets — Energy Label & Repairability Index
20th Jun 2025both regulations already in force
800minimum battery charge cycles at 80% capacity — smartphones and slate tablets (500 for other mobile and cordless phones)
7 yrsminimum spare-parts availability after a model is discontinued

What's actually being tested

Regulation (EU) 2023/1670 sets the technical thresholds a smartphone, feature phone, cordless phone or slate tablet has to meet before it can be placed on the EU market — and those thresholds are not identical across the four. A smartphone or slate tablet battery must be rated for at least 800 full charge cycles while retaining at least 80% of its original capacity; a mobile phone other than a smartphone, or a cordless phone, needs at least 500 on the same 80% basis. All four face physical durability testing against drops, scratches, dust and water ingress. The regulation also sets repair obligations directly — manufacturers (or their EU-based responsible party) must make key spare parts available to professional repairers within 5 working days for the first 5 years and within 10 working days for the remaining 2, across at least 7 years after the model stops being sold in the EU. Two categories sit outside the regulation entirely: devices with a flexible main display the user rolls and unrolls, and smartphones designed for high-security communication.

A smartphone opened on a repair mat with its battery beside it
Illustration: a phone taken apart for repair.

The label: energy class plus repairability index

A companion regulation, (EU) 2023/1669, requires an energy label at the point of sale — both online and in physical stores — showing an A-G energy efficiency class based on the device's Energy Efficiency Index, alongside a repairability class graded A to E and derived from a repairability index built on disassembly, spare-parts and documentation data. The two classes sit on one label, so a buyer sees energy efficiency and repairability side by side before purchase. Note the narrower scope: the labelling regulation covers smartphones and slate tablets only. Mobile phones other than smartphones, and cordless phones, are in scope of the ecodesign regulation but carry no energy label and no repairability class.

Not the same thing as the Right to Repair Directive

The EU Right to Repair Directive is a separate, broader law — in force from 31st July 2026, covering more product categories, and focused on warranty extension after repair and banning software/hardware repair locks. This ecodesign regulation is narrower, older, and specifically a product-testing and labelling regime: it's the reason a smartphone has to survive a defined drop-test and battery-cycle test before the repairability index on its label means anything. Manufacturers already compliant with the Right to Repair Directive's obligations still need to separately test and document against this regulation's thresholds if they haven't already.

See also our EU Right to Repair Directive page for the separate repair-lock/warranty-extension obligations.

Who this catches

Any smartphone, feature phone, cordless phone or slate tablet placed on the EU market from 20th June 2025 onward is in scope of the ecodesign regulation — including an existing model still being shipped into the EU after that date, not just new launches. The energy label and repairability class apply to the smartphones and slate tablets among them, not to feature or cordless phones. That makes this a live compliance gap for any consumer-electronics manufacturer or importer currently selling into the EU without a completed battery-cycle test, durability test, or — where the product is a smartphone or slate tablet — the required label.

Questions

What does the EU Ecodesign Regulation for smartphones and tablets require?

Regulation (EU) 2023/1670, in force since 20th June 2025, requires smartphones and slate tablets sold in the EU to meet minimum battery durability (at least 800 charge cycles retaining 80% capacity), physical durability (resistance to drops, scratches, dust and water), and repair obligations — manufacturers must supply key spare parts to professional repairers within 5 working days for the first 5 years and within 10 working days for the remaining 2, across at least 7 years after a model is discontinued. Feature phones and cordless phones are also covered, at a lower 500-cycle battery threshold. A companion regulation, (EU) 2023/1669, requires a physical energy label at point of sale for smartphones and slate tablets.

What is the repairability index?

The repairability index is a score covering how easily a device can be disassembled, how available spare parts and repair documentation are, and software-update support. The energy label displays it as a repairability class graded A to E, derived from that index. Both the index and the class are set out in the energy labelling regulation (EU) 2023/1669, which covers smartphones and slate tablets only. The class sits next to the A-G energy efficiency class on the same label, so a buyer sees both at point of sale.

How is this different from the EU Right to Repair Directive?

The Right to Repair Directive (in force from 31st July 2026) is a horizontal repair-obligation law covering a wider range of product categories, addressing warranty extension on repair and bans on software/hardware repair locks. The Ecodesign Regulation for smartphones and tablets is narrower and older (in force since 20th June 2025), and is specifically a product-testing and labelling regime: it sets the actual technical thresholds — battery cycle count, drop/water resistance, disassembly requirements — that a smartphone or tablet has to be tested against before it can legally be placed on the EU market, plus the label that displays the result.

Does this apply to a device already being sold in the EU?

Yes, if it is still being placed on the EU market. The ecodesign regulation applies to smartphones, feature phones, cordless phones and slate tablets placed on the market from 20th June 2025 onward, not just new model launches — an existing model still being shipped into the EU after that date has to meet the battery, durability and spare-parts requirements set for its own product type. The thresholds are not the same across types: 800 battery cycles at 80% capacity for smartphones and slate tablets, 500 for feature phones and cordless phones. The energy label and the A-E repairability class are required for smartphones and slate tablets only.

Where we fit

This is a testing and documentation regime, not a paperwork exercise — battery-cycle testing, drop/water/dust resistance testing and repairability-index scoring all need an accredited lab, and the spare-parts and documentation commitments have to be real and maintained for years, not just claimed once. We scope what your specific device needs tested, arrange that testing, and manage the label and ongoing spare-parts commitment end to end.

Contact us

Sources

  1. Commission Regulation (EU) 2023/1670 of 16 June 2023
  2. Commission Delegated Regulation (EU) 2023/1669 of 16 June 2023