EU Ecodesign for Smartphones: What Has Applied Since 20 June 2025 for Your Sourcing
Since 20 June 2025, Regulation (EU) 2023/1670 has set ecodesign requirements for smartphones, mobile phones other than smartphones, cordless phones and slate tablets. It covers spare parts, battery endurance and the EU energy label. For a used device, the decisive date is not when it was bought, but when its model was first placed on the EU market.
For buyers of used iPhones, this has practical consequences. The regulation shapes which parts repair businesses can expect to source, which battery benchmark applies to newer models and what the energy label has to show. This guide explains which generations are affected and turns the rules into questions for your next purchase. It is professional orientation, not legal advice: the text of the regulation in the Official Journal of the European Union is authoritative.
By TR Admin · Last updated: 2026-10-05
Who the regulation covers, and who it does not
The regulation covers smartphones, mobile phones other than smartphones, cordless phones and slate tablets. Devices with a rollable main display and smartphones for high-security communication are excluded.
The requirements apply to products placed on the EU market from 20 June 2025 onwards. The reference point is the date on which the first unit of a product model was placed on the market. Whether the rules apply is therefore a question about the model, not about the individual used device.
- iPhone 16 (announced September 2024, available from 20 September 2024) predates the cut-off. According to the wording, these requirements do not cover it.
- iPhone 17 (available from 19 September 2025) as well as iPhone 18 Pro and iPhone 18 Pro Max (available from 18 September 2026) come after the cut-off.
Spare parts: what manufacturers must provide
Manufacturers must keep certain spare parts available for a period the regulation defines after the end of placing a model on the market, and deliver them within delivery deadlines the regulation also sets. Annex II lists the parts. For professional repairers, the list includes, among others:
- the battery
- front and rear camera assemblies
- external audio and charging connectors
- mechanical buttons
- main microphones and speakers
- for foldable devices, the hinge assembly and the mechanical display-folding mechanism
End users, foldable devices and what it means for sourcing
End users get a separate, shorter list. It includes the battery, the back cover where it has to be removed to replace the battery, the display assembly, the charger, and SIM and memory card holders. Because the parts list names hinges and folding mechanisms, the regulation explicitly reaches foldable devices as well. For the announced iPhone Duo, see our iPhone Duo overview.
For sourcing, this means: for models after the cut-off, the supply of parts is secured by law. For older models the requirement does not apply, and parts availability remains a question of the specific model. Used stock should therefore be judged by model and documented condition, not by the hope that suitable parts will turn up when needed.
Battery endurance: the 80 % benchmark becomes an EU test standard
For smartphones, the regulation requires the battery to keep at least 80 % of its initial capacity after a defined number of charge and discharge cycles. The 80 % line is therefore no longer only a trade benchmark; it is now also a regulatory test standard for new models.
For the used market, the energy label is a model document: it describes a model, not the condition of an individual device. How far a used battery has aged depends on use and history, and only a test on the unit itself settles it. That is why every unit in our stock goes through a 5-minute full-load battery test, and why we guarantee a battery health above 80 % on every grade and every model. More in our battery health guide.
The EU energy label: what it shows for smartphones
Since 20 June 2025, smartphones and slate tablets carry an EU energy label. Among other things, it shows:
- the energy efficiency class on a scale from A to G
- battery endurance per charge cycle, in hours and minutes
- battery endurance in cycles
- a drop reliability class for repeated free falls
- the ingress protection rating against dust and water
- a repairability score, which the EU requires on a product label for the first time
The label compares models, not individual devices
For sourcing, the label is above all a model comparison. It does not replace a test of the individual device, but it adds a useful question: how robust and how repairable is the design of a model?
What this means for your buying decision
Four questions help apply the new rules to a purchase:
- Generation: Which models are in the lot, and when were they first placed on the EU market? That date decides whether the ecodesign requirements apply.
- Spare parts: For which models is the supply of parts secured by law, and for which does it depend only on the manufacturer?
- Battery: Is there a test value for each unit? A model data sheet or the energy label does not replace it.
- Documentation: Is there a test report per unit with IMEI, battery value and grade?
How we answer these questions
At TR Vertriebs GmbH, every unit runs through our 52-point test, every device gets an individual test report, and the packing list carries the IMEI of every unit. Stock is graded on a three-tier scale: Grade A, Grade A/B and Grade B/C. Our battery guarantee applies equally to every grade, with a battery health above 80 %. Details are in our grading guide.
Two other EU acts sit alongside this regulation. The Battery Regulation (EU) 2023/1542 is a separate legal act with its own battery requirements, which our USB-C and battery guide explains. The Right-to-Repair Directive (EU) 2024/1799 is covered in our right-to-repair guide.
Sources and status
All statements above rest on the following sources. Status: October 2026, unless otherwise stated.
- Regulation (EU) 2023/1670, Official Journal of the European Union (EUR-Lex)
- European Commission, energy efficiency page for smartphones and tablets
- Apple Newsroom: iPhone 16 announced 9 September 2024, available from 20 September 2024
- Apple Newsroom: iPhone 17 announced 9 September 2025, available from 19 September 2025
- Press coverage of the iPhone 18 Pro launch: pre-orders from 12 September 2026, availability from 18 September 2026
Frequently Asked Questions
Does the ecodesign regulation also apply retroactively to used iPhones?
According to the wording, no. The regulation attaches to the model: it covers models first placed on the EU market from 20 June 2025 onwards. Used devices of older models are not brought under it after the fact. For a specific case, take qualified legal advice; the text of the regulation is authoritative.
Which spare parts must manufacturers make available to repair businesses?
Annex II lists, among others, the battery, camera assemblies, speakers, microphones, charging and audio connectors, mechanical buttons and, for foldable devices, hinge assemblies and the folding mechanism. End users get a shorter list that includes the battery, the display assembly and the charger.
How does the 80 % requirement relate to your battery guarantee?
The regulation sets a test requirement for new smartphone models. Independently of that, we guarantee a battery health above 80 % on every grade and every model. Testing is done under full load, not by reading the iOS value alone.
Does the energy label also describe a used iPhone?
No. The label describes a model. The condition of an individual used device can only be established by testing that unit.