Dec 26, 2024
What is ESPR?
The Ecodesign for Sustainable Products Regulation (ESPR) is a key part of the European Green Deal, designed to make products sold in the EU more sustainable. Taking effect on July 18, 2024, ESPR replaces the existing Ecodesign Directive and expands its scope beyond energy-related products to cover almost all consumer goods.
At its core, ESPR sets new rules for how products are designed, manufactured, and disposed of, with a focus on increasing durability, improving recyclability, and reducing waste. A key feature is the introduction of the Digital Product Passport (DPP), which will make detailed product information available throughout the supply chain to improve transparency and traceability.
Why ESPR matters
The goal behind ESPR is to address the growing environmental pressure caused by overconsumption, poor recycling rates, and the sheer volume of product waste. Until now, sustainability efforts have focused on energy efficiency, but ESPR takes a broader approach by regulating the materials used in products, how long they last, and how easily they can be repaired or recycled.
ESPR reflects a shift toward a circular economy, where products are designed not just for sale but for repair, reuse, and recovery at the end of their life. The EU’s aim is to reduce dependence on raw materials and cut down on the environmental costs of production and disposal.
Who needs to comply?
ESPR applies to businesses that make, import, or sell products in the EU. That includes manufacturers and importers, but also retailers and online marketplaces like Amazon and Zalando. If a business sells in multiple EU countries, they’ll need to register and comply with ESPR requirements in each market.
For online platforms, the responsibility extends to ensuring that the products listed by third-party sellers meet ESPR standards. This adds a new layer of accountability for platforms that have previously operated with limited responsibility for product compliance.
What products are covered?
ESPR dramatically expands the range of products subject to ecodesign rules. While the previous directive focused on energy-related products, ESPR includes consumer goods such as electronics, textiles, furniture, and packaging.
Electronics face stricter requirements for repairability and lifespan. Manufacturers will need to provide spare parts for longer periods and ensure that devices can be repaired using standard tools. Textiles and furniture will need to meet tougher recycling and material-use standards, with clear documentation of fiber content and chemical use. Packaging rules will focus on reducing waste by requiring minimum recycled content and banning certain single-use plastics.
Batteries are also covered, with new rules on material recovery and labeling to ensure better recycling and disposal. Even traditionally unregulated products like toys and cosmetics will need to comply with updated sustainability and transparency guidelines.
The Digital Product Passport
A central element of ESPR is the Digital Product Passport (DPP), which will store detailed product data and make it accessible throughout the supply chain. The passport will include information on materials used, product origin, repairability, and environmental impact.
The DPP is designed to give consumers and businesses greater visibility into the lifecycle of a product. A retailer will be able to trace where a product’s materials were sourced, while a repair shop will have access to detailed instructions for disassembly and recycling. The goal is to close the information gap and make it easier for businesses and consumers to make sustainable decisions.
What do you need to do as a retailer to comply with ESPR?
The Ecodesign for Sustainable Products Regulation (ESPR) will introduce major changes to how products are designed, sold, and disposed of in the EU. It’s not just manufacturers who need to adapt—retailers also have a clear set of responsibilities. To stay compliant and avoid penalties, here’s what you need to focus on:
1. Identify which products are covered
The first step is to figure out which of your products fall under ESPR requirements. The initial focus includes textiles, electronics, furniture, batteries, and packaging, but the list will likely grow over time. If you sell in multiple EU countries, you’ll need to register for compliance in each market individually.
2. Ensure each product has a Digital Product Passport (DPP)
The Digital Product Passport (DPP) is central to ESPR compliance. Every covered product will need a DPP, which provides key details like material composition, repairability, origin, and environmental impact. The DPP makes this information accessible throughout the supply chain and to consumers. If your suppliers can’t provide a complete and accurate DPP, you may not be able to sell the product.
3. Verify that suppliers meet compliance standards
It’s no longer enough to assume your suppliers are following the rules. Under ESPR, you’ll need to confirm that your suppliers meet all sustainability standards. This means:
• Ensuring the materials they use meet minimum recycled content requirements.
• Confirming that repairability and lifespan targets are met.
• Checking that suppliers provide proper documentation for recyclability and disposal.
If a supplier can’t meet ESPR requirements, it’s your responsibility as a retailer to adjust your sourcing strategy.
4. Update product labels and listings
Transparency is a key element of ESPR. You’ll need to update product information, both online and in-store, to reflect the details included in the DPP. That includes:
• Listing the product’s repairability score.
• Providing information about materials and environmental impact.
• Offering clear guidance on how to recycle or dispose of the product properly.
Inaccurate or missing information could lead to fines—or even product bans.
5. Manage product data and reporting
One of the more challenging aspects of ESPR will be the increased reporting requirements. Retailers will need to track and report detailed data on product materials, recycled content, and environmental performance. This includes:
• How many products are sold and in which markets.
• The amount and type of packaging used.
• The percentage of recycled materials in each product.
This is where Complir can help. Complir allows you to centralize product data from multiple suppliers and systems, ensuring that all compliance information is stored, organized, and easily accessible. It helps automate reporting by pulling data directly from your supply chain and preparing it in the format required by regulators. With Complir, you can stay ahead of the reporting burden and avoid the risk of incomplete or inconsistent data.
6. Develop a plan for unsold products
ESPR discourages the destruction of unsold consumer goods, especially textiles and footwear. As a retailer, you’ll need to have a clear plan for managing excess inventory, which could include:
• Reselling or redistributing products.
• Partnering with recycling firms to process unsold stock.
• Donating unsold goods where appropriate.
Failure to handle unsold goods properly could result in fines and reputational damage.
7. Stay on top of evolving requirements
ESPR requirements will continue to evolve as the EU refines its sustainability targets. New product categories will be added, repairability and recyclability thresholds will increase, and reporting expectations will become more detailed. Retailers will need to stay informed and adjust their practices as the rules develop.
Acting early matters
The push toward sustainability is not just coming from regulators—consumers are paying attention too. With the Digital Product Passport making product data more transparent, buyers will have a clearer understanding of a product’s environmental impact. Retailers that meet ESPR standards early will have a competitive advantage, while those that lag behind may face regulatory penalties and lost market share.
Complir can make the process easier by helping you track product data, manage compliance requirements, and simplify the reporting process. By acting early and using the right tools, you can turn ESPR compliance into a competitive advantage.
Consequences of non-compliance
Failure to meet ESPR requirements could lead to fines, legal penalties, and even product bans within the EU. National regulators will have the power to remove non-compliant products from the market and impose penalties on businesses that fail to provide accurate data or meet material-use standards.
But the bigger risk is reputational. As transparency increases, consumers and business partners will have more insight into product sustainability. Falling short on ESPR requirements could undermine a company’s reputation and brand value, especially as demand for sustainable products continues to grow.
But ESPR isn’t just about avoiding penalties—It can also be an opportunity. Companies that adapt early stand to benefit from increased consumer trust, lower production costs through more efficient use of materials, and a stronger competitive position in a market that’s shifting toward sustainability.
For businesses willing to embrace it, ESPR could be the push needed to build more sustainable, transparent supply chains and gain a long-term edge in the market.
