ESPR Regulation: Ecodesign Requirements for Sustainable Products
What is the ESPR regulation? Learn everything about the EU Ecodesign for Sustainable Products Regulation, affected product categories, delegated acts, the timeline from 2026, and what businesses need to do now.
ESPR Regulation: Ecodesign Requirements for Sustainable Products
Key Takeaways
The Ecodesign for Sustainable Products Regulation (ESPR) is the EU’s central regulatory framework for the ecological design of products. It replaces the previous Ecodesign Directive from 2009, extends its scope to nearly all physical products, and introduces the Digital Product Passport (DPP) as a mandatory instrument. For manufacturers, importers and retailers, this means that product data must be provided in a structured, digital and publicly accessible format going forward. This article explains what the ESPR specifically requires, which product categories are affected first, and how you can prepare.
If you are not yet familiar with what a Digital Product Passport is, we recommend our introductory article Digital Product Passport in 15 minutes.
What is the ESPR?
The abbreviation ESPR stands for Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781). The European Commission adopted the ESPR in July 2024. Unlike the old Ecodesign Directive (2009/125/EC), which applied exclusively to energy-related products, the ESPR covers virtually all physical products placed on the EU internal market.
The ESPR is a regulation, not a directive. This means it applies directly in all EU Member States without the need for national transposition laws. Companies cannot rely on individual countries delaying implementation.
The three pillars of the ESPR
- Ecodesign requirements: Binding minimum standards for durability, repairability, recyclability, energy efficiency and the use of recycled materials.
- Digital Product Passport (DPP): A structured digital dataset per product containing information on composition, origin, repair and disposal.
- Destruction ban for unsold goods: Manufacturers and retailers may no longer destroy certain unsold consumer goods (especially textiles and footwear).
ESPR vs. the old Ecodesign Directive: Key differences
| Feature | Ecodesign Directive (2009) | ESPR Regulation (2024) |
|---|---|---|
| Legal form | Directive (national transposition required) | Regulation (directly applicable) |
| Product scope | Energy-related products only | Nearly all physical products |
| Digital Product Passport | Not included | Mandatory for covered categories |
| Circular economy | Barely addressed | Core objective (repair, recycling, durability) |
| Destruction ban | Not included | Yes, for certain consumer goods |
| Information requirements | Energy label | DPP with comprehensive product data |
The decisive difference: the old Directive was essentially an energy policy instrument. The ESPR, by contrast, takes a holistic approach to the circular economy and affects significantly more industries.
Which product categories are affected?
The ESPR itself defines the framework. The specific requirements per product category are laid down in delegated acts. The European Commission has published a work plan that describes the prioritisation of product groups.
First wave (delegated acts by end of 2025/early 2026)
- Textiles and apparel (especially clothing and footwear)
- Iron and steel
- Aluminium
- Furniture (including mattresses)
- Tyres
- Detergents
- Paints and coatings
- Lubricants
Second wave (delegated acts from 2026/2027)
- Electronics and ICT devices
- Plastics and polymers
- Chemicals
- Further categories according to the Commission’s work plan
The Commission can add further product groups by delegated act without restarting the legislative process.
Timeline: When does the ESPR take effect?
| Date | Milestone |
|---|---|
| July 2024 | ESPR published in the Official Journal |
| 2025 | First delegated acts in preparation |
| 2026-2027 | Application of the first product-specific requirements (depending on the delegated act) |
| 2027-2030 | Gradual expansion to further product categories |
| From 2030 | Destruction ban for certain unsold goods (textiles, footwear) |
Important: Timelines vary by product category. A separate delegated act is issued for each category, defining a specific implementation period. There is no single deadline for all products.
The Digital Product Passport under the ESPR
The ESPR provides the legal basis that makes the DPP mandatory for numerous product categories. The DPP must:
- be accessible via a data carrier (e.g. QR code, GS1 Digital Link) on the product,
- contain machine-readable and human-readable information,
- be linked to a unique product identifier,
- include information on composition, origin, repair, recycling and conformity,
- be connected to a central EU DPP registry.
The precise data fields are specified per product category in the delegated acts. There is therefore not one DPP for all products, but category-specific requirements.
For a practical guide to DPP implementation, we recommend our DPP implementation checklist.
What do businesses need to do now?
Even though the product-specific requirements will only be finalised through delegated acts, there are sensible preparatory measures you can take today.
1. Assess whether you are affected
Analyse your product portfolio and compare it with the Commission’s work plan. Do your products fall into one of the prioritised categories?
2. Evaluate your data landscape
What product data do you already capture (ERP, PIM, PLM)? What data is missing to meet future DPP requirements? A data audit is the first step.
3. Involve your supply chain
The ESPR requires data along the entire value chain. Talk to your suppliers early about data requirements, especially regarding material composition and carbon footprint.
4. Evaluate DPP infrastructure
Check whether a DPP platform such as myDPP covers your industry’s requirements. Early pilot projects reduce the risk as deadlines approach.
5. Clarify internal responsibilities
DPP is a cross-functional topic that touches product management, IT, procurement, sustainability and compliance. Define clear responsibilities.
Penalties for non-compliance
The ESPR requires EU Member States to establish effective, proportionate and dissuasive penalties. Specifically, this means:
- Fines, the amount of which is set nationally (based on the company’s turnover),
- Sales bans for non-compliant products on the EU internal market,
- Recall obligations in serious cases,
- Public disclosure of infringements by market surveillance authorities.
Market surveillance is coordinated through the EU-wide market surveillance system (ICSMS). Products without a valid DPP can be held at the border.
Frequently Asked Questions (FAQ)
Does the ESPR also apply to small and medium-sized enterprises (SMEs)?
Yes, in principle the ESPR applies to all economic operators placing products on the EU market. However, there are allowances: delegated acts may provide simplified requirements for SMEs, and transition periods may be extended.
Does the ESPR also affect companies outside the EU?
Yes. Every product sold on the EU internal market must comply with ESPR requirements, regardless of where it was manufactured. Importers bear the responsibility for ensuring that imported goods are compliant.
Do I need to implement the DPP immediately?
No, the DPP does not become mandatory for all products at once. The obligation only takes effect with the respective delegated act for your product category. However, it is advisable to start preparing early, as the data requirements are complex.
Where can I find the current delegated acts?
The European Commission publishes all delegated acts on the ESPR page of the Official Journal of the EU. Additionally, the Commission’s website on sustainable product policy provides information on the current status.
Further reading
-
Digital Product Passport in 15 minutes: what DPP is and why the EU introduces it
-
ELV Regulation (EU) 2026/1738: the vehicle digital circularity passport