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16 February 2026

Profitable Circularity: How to Design Electronics in Compliance with ESPR Requirements

Circular design in electronic devices represents an opportunity to reduce environmental impact while maintaining cost-efficiency. An example is a modular, easy-to-repair smartphone (FairPhone 6), which demonstrates that it is possible to lower a product's carbon footprint (PCF) by up to 20% with a cost increase of less than 3%. By extending the device's lifecycle to eight years, annual $CO_{2}e$ emissions can drop by as much as 46%. This approach not only supports sustainable development goals but also prepares manufacturers for the upcoming requirements of the Ecodesign for Sustainable Products Regulation (ESPR).

Context and Challenges

The electronics industry is under growing regulatory, market, and consumer pressure. EU regulations, such as the ESPR and the "Right to Repair" directive, mandate the design of products that are more durable, easier to repair, and transparent regarding their environmental impact. Simultaneously, consumers increasingly expect ethical and responsible products, while operational risks related to e-waste, emissions reporting, and extended producer responsibility are becoming more complex.

Failure to comply with the ESPR is not just an image problem but a real financial and strategic risk. Proposed sanctions could reach up to 4% of annual turnover in the EU or include fines, market restrictions, mandatory product recalls, or exclusion from public procurement. Shifting from the linear "take-make-dispose" model to a circular one opens new opportunities for electronics manufacturers: extending product life, resource recovery, emission reduction, and building brand trust.

Strategic Circular Opportunity

Circularity in electronics begins at the design stage—through modular architecture that enables repairs and upgrades. It also includes responsible component sourcing and new business models, such as leasing, remanufacturing, or buy-back programs. Key elements of circular design include:

  • Modularity to extend device life.

  • The use of lower carbon footprint components (e.g., energy-efficient integrated circuits).

  • Optimization of production and logistics processes.

This approach supports ESG goals, limits regulatory risks, brings cost savings, and strengthens brand positioning in environmentally sensitive markets.

Case Study: Sustainable Smartphone

The device was designed to be fully modular—the battery, screen, camera, and other key components can be replaced by the user without specialized tools. This significantly reduces the amount of e-waste and extends the product's lifecycle.

Environmental analysis shows that a standard smartphone emits approximately $42~kgCO_{2}e$ per year over a 3-year usage period, while extending the device's life to 8 years reduces this value to $7.6~kgCO_{2}e$ per year—a 46% reduction.

PCBAs, AMOLED displays, and camera modules account for the largest share of costs (86%) and emissions (73%). Using more energy-efficient integrated circuits can reduce emissions by approximately $4.2~kgCO_{2}e$ for a cost increase of only $4$ USD. Additional benefits come from moving production to locations with lower carbon intensity—reducing emissions in production and transport while providing logistical savings.

In total, a cost increase of $5.81$ USD (approx. 2.3%) allows for a reduction in the product's carbon footprint by $8.68~kgCO_{2}e$. This device already complies with ESPR requirements, providing the manufacturer with a competitive advantage and regulatory readiness.

 

Author: Tomasz Rola - Founder ro.lab consulting

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