Further EU regulation poses more challenges to smartphone vendors operating in the region, but is also a necessary change for the industry if it is to achieve net-zero by 2050. 

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Summary

On June 20, 2025, the EU’s Eco-Design and Energy Labelling regulation came into effect, having been first approved in 2023. The goal of this regulation is to extend smartphone lifetimes and educate consumers to make more sustainable purchasing decisions, ultimately reducing the environmental impact of smartphone manufacturing, use, and disposal. The knock-on effect of this, however, is that smartphone vendors operating in the EU will have to meet new higher durability and repairability design standards and minimum update support periods.

Smartphone energy labels

The EU is introducing an energy label for smartphones, which includes: an energy efficiency class rating (from G to A); battery life per cycle, in hours and minutes; free-fall reliability rating (from E to A); repairability rating (from E to A); battery endurance in cycles; and an IP rating for water and dust resistance.

Figure 1: The EU’s smartphone energy label Figure 1: The EU’s smartphone energy label Source: EU

This mirrors the energy label introduced for washing machines in 1994, which drove the industry toward the production of more energy-efficient goods. Energy labelling has since proven effective in encouraging more sustainable designs across appliances such as dishwashers, fridge freezers, and washing machines. Lifecycle assessments have shown that these appliances’ energy use contributes the most to their total carbon footprint. According to EU estimates, the energy label could deliver a 25% reduction in electricity consumption from charging smartphones and tablets by 2030.

In effect, this represents a modest energy saving, and offers limited improvement to the sustainability of the industry. This is because lifecycle assessments consistently show that manufacturing, rather than energy use, accounts for the majority of a smartphone’s carbon footprint. As such, the most effective way to reduce environmental impact is to reduce the number of phones being produced by extending device lifespans to keep phones in people’s hands for longer. In response, the EU has incorporated battery endurance, durability, and repairability ratings into the energy label to support this.

EU eco-design legislation

At the core of this new regulation is eco-design legislation aimed at reducing the impact of smartphone manufacturing on the environment. The largest change in this policy is that smartphones and tablets must have at least five years of operating system and security updates. Unlike the support commitments of most vendors, which is measured from the launch date, these five years begin from the end of the last unit being placed on the market. In effect, this means from the end of sell-in.

The eco-design regulation mandates that batteries must withstand at least 800 cycles of charge and discharge while retaining 80% of initial capacity. Manufacturers are also requires to make critical spare parts (including the battery, display, and charging port) available to repairers within 5‒10 working days, and for seven years from the end of sell-in. These parts must be affordably priced to encourage repair rather than replacement. The regulation also sets durability benchmarks, requiring protection against dust and water ingress (minimum IP44 rating), and resistance to scratches and drops (it specifies a level of up to 45 drops). For foldable devices, many caveats and conditions have been applied to these regulations, where resistance standards differ and the devices must withstand 15 drops when open and 35 when folded.

Smartphone design will have to change

We have already seen how regulation can change how smartphones are designed; the EU’s Common Charger Directive mandated that all smartphones use USB-C charging ports. This forced Apple to stop using its proprietary lightning-bolt charger from the iPhone 16 onwards. The goal of this directive was to reduce electrical waste and simplify consumer choices by enforcing a universal charging standard.

For many smartphone vendors, the changes necessary to adhere to the new regulations will also come at a cost. Each additional year of software support is negotiated between the smartphone vendor and chipset maker, at cost to the vendor. For many low-end devices, which previously only received two or three years of updates, such as those from HMD Global or Motorola, this increase to five or six years will mean profit margins are squeezed. To minimize the impact of this, vendors may consolidate their smartphone portfolios, reducing the number of different devices on the EU market. As a minimum, it may mean that vendors consolidate the chipsets they use on devices, in order to minimize the costs of supporting multiple different chipsets for longer.

If the EU succeeds in their goal of extending the product lifetimes of smartphones, it will of course mean a decrease in smartphone shipment volume, at least within the EU. Figure 2 shows the percentage of 2024 shipments each vendor had for the EU market. Those most reliant on the EU currently include HMD Global (where the EU accounted for 23% of 2024 shipments), TCL (21.7%), Samsung (16.6%), and Google (16.0%).

Ultimately, extending the average smartphone lifetime will impact shipments. For example, a shift from three to four years in the EU would mean a 25% reduction in annual shipments, as the replacement of previous smartphones slows down. In 2024, this would be the equivalent of 26 million smartphones.

In fact, the impact could be even larger, as many of the measures introduced allow for phones to be repaired and refurbished and kept in the market even longer, boosting an already growing and strong second-hand market within the region.

Figure 2: EU share of smartphone vendor global shipments in 2024 Figure 2: EU share of smartphone vendor global shipments in 2024 Source: Omdia’s Mobile Handset Database Country - History - 1Q25

The end goal of eco-design

The EU is introducing more regulations with similar goals: reducing electrical waste; making consumer repair easier and cheaper; extending product lifetimes; increasing consumer awareness of carbon footprint impact; reducing plastic waste; and improving durability.

A key development for smartphones is the upcoming EU legislation, set to take effect in December 2026, mandating consumer-replaceable batteries. This concept has already been demonstrated by HMD Global and Fairphone, both of which prioritize sustainability through consumer repair. However, these implementations are largely limited to low- to mid-range devices. For high-end and premium models, the design challenges are greater due to tighter internal space and the need to maintain higher IP ratings for water and dust resistance ‒ factors that may be compromised by making batteries user-replaceable.

This aligns with the EU’s central end goal of reducing the environmental impact of the smartphone industry. It also signals a regulatory shift toward a more circular economy in the region.

Ultimately, this will be beneficial to everyone. Carbon emissions from manufacturing will be reduced ‒ a single phone can generate approximately 65kg of CO2e emissions, contributing to a global footprint of roughly 80 million tonnes of CO2 annually. There will be a reduced environmental impact in raw mineral extraction, some of which is wrapped up in controversy over possible conflict minerals and reliance on child labor. Finally, there will be reduced levels of e-waste globally, as the smartphone industry generates millions of discarded devices each year, with only a fraction being properly recycled.

All of these changes are necessary to meet the long-term objectives of the Paris Agreement – keeping global warming limited to no more than 1.5°C by reducing emissions across all sectors by 45% by 2030 and reaching net-zero by 2050. However, it will be a huge challenge for vendors to shift their business models away from being reliant on shipment-based revenue and onto secondary revenue sources such as services and advertising.

Appendix

Further reading

Smartphone Model Market Tracker – 1Q25 Analysis (June 2025)

Smartphone Need-To-Know – June 2025 (June 2025)

Mobile Handset Database Country - History - 1Q25 (May 2025)

EU eco-design regulation on smartphones and tablets (June 2023)

EU energy labelling regulation on smartphones and tablets (June 2023)

Author

Aaron West, Senior Analyst, Consumer Devices

[email protected]