ESPR Explained: What the Ecodesign for Sustainable Products Regulation Means for Your Business

The Ecodesign for Sustainable Products Regulation (ESPR) is a European Union framework regulation — published as Regulation (EU) 2024/1781 — that sets the rules for making products sold in the EU more durable, repairable, recyclable, and transparent. It entered into force on 18 July 2024 and replaces the previous Ecodesign Directive (2009/125/EC), which only covered energy-related products. ESPR expands the scope to virtually all physical products placed on the EU market.

If you manufacture, import, or sell consumer products in the EU, ESPR will affect your business. The first obligations — including a ban on destroying unsold clothing and footwear — take effect on 19 July 2026. Product-specific requirements will follow through delegated acts rolling out between 2026 and 2030.

ESPR is a framework regulation. That means it does not set specific product requirements itself. Instead, it establishes the legal basis and the rules the European Commission will use to adopt delegated acts — secondary legislation that defines ecodesign requirements for specific product groups.

This is an important distinction. Unlike a regulation that lists every requirement upfront, ESPR creates the machinery for requirements to be developed product group by product group, based on detailed technical assessments. Think of ESPR as the operating system, and delegated acts as the applications that run on it.

The regulation's scope is broad. According to the European Commission, ESPR covers all products placed on the EU market or put into service, including components and intermediate products. The only exceptions are food, feed, medicinal products, and a handful of other categories explicitly excluded in the regulation text.

How is ESPR different from the old Ecodesign Directive?

The original Ecodesign Directive (2009/125/EC) applied exclusively to energy-related products — appliances, lighting, motors, and similar equipment. ESPR fundamentally expands this scope in three ways. First, it covers nearly all physical products, not just energy-related ones — textiles, furniture, steel, aluminium, tyres, and many more. Second, it introduces the Digital Product Passport (DPP) as a mandatory information tool. Third, it adds circularity-focused requirements like repairability, durability, and recycled content alongside traditional energy efficiency criteria.

ESPR delegates the specifics to product-level delegated acts, but the regulation defines two categories of requirements that those delegated acts can impose.

Performance requirements set minimum thresholds products must meet. These can cover parameters such as durability, reusability, repairability, energy and resource efficiency, recycled content, carbon footprint, and restrictions on substances that inhibit circularity. The regulation lists 20 potential parameters — delegated acts will select which apply to each product group.

Information requirements mandate that products carry specific data. At a minimum, these include a Digital Product Passport and information about Substances of Concern present in the product — their identity, location in the product, concentration, and instructions for safe use and end-of-life management.

What is the Digital Product Passport?

The Digital Product Passport (DPP) is a structured digital record attached to each product — typically accessible via a QR code, NFC chip, or RFID tag — that stores sustainability and compliance data throughout the product's lifecycle. The DPP must be machine-readable and comply with standardised data formats.

The type of data a DPP contains will vary by product group, but it is expected to cover material composition, environmental performance indicators, durability information, repairability scores, substances of concern, and end-of-life handling instructions. The EU DPP Registry — the central infrastructure that underpins the system — is set to become operational by 19 July 2026.

The DPP is not just a label. It creates a digital thread linking the product to its compliance data, accessible to consumers, businesses, market surveillance authorities, and recyclers. For product companies, this means building and maintaining structured, standardised product data at a level most have not needed before.

On 16 April 2025, the European Commission published its first ESPR and Energy Labelling Working Plan for 2025–2030. This plan identifies the priority product groups that will receive delegated acts first.

The priority list includes both new product categories (covered for the first time under ecodesign rules) and energy-related products carried over from the previous directive:

Note: Each delegated act includes a minimum 18-month transition period before requirements become enforceable. Estimated compliance dates are based on this minimum transition.

In addition, the Working Plan carries forward 16 energy-related product groups from the previous Ecodesign Directive, including dishwashers (2026), electric vehicle chargers (2028), fridges and freezers (2028), electric motors (2028), and mobile phones and tablets (2030).

The plan also introduces two horizontal requirements that cut across multiple product groups: repairability rules (targeted for 2027, potentially covering consumer electronics and small household appliances) and recycled content and recyclability requirements for electrical and electronic equipment (2029).

A mid-term review is planned for 2028, at which point the Commission may add additional product groups — footwear, paints, detergents, lubricants, and chemical products are all mentioned as candidates for future preparatory studies.

Separately, batteries are covered under the EU Battery Regulation (EU) 2023/1542, not ESPR. The Battery Passport — the first mandatory DPP in the EU — applies from 18 February 2027.

One of ESPR's most immediate obligations does not wait for delegated acts. Article 23 of the regulation introduces a general duty for all economic operators to take reasonable measures to prevent the need to destroy unsold consumer products.

Article 25 goes further. From 19 July 2026, large enterprises are prohibited from destroying unsold clothing, clothing accessories, and footwear listed in Annex VII of the regulation. Medium-sized enterprises have until 19 July 2030. Micro and small enterprises are exempt.

The European Commission adopted the final delegated regulation on derogations in early 2026, defining 10 circumstances under which destruction remains permitted — including products that are dangerous, non-compliant with law, damaged, or have manufacturing defects.

Alongside the destruction ban, a disclosure requirement applies. Large companies must publicly report the quantity of unsold consumer products they discard each financial year, starting from the first full financial year after the implementing act's date of application — confirmed by the Commission to be February 2027.

Does the destruction ban apply to all products?

Not yet. The initial ban covers clothing, clothing accessories, and footwear only. However, Article 25 of ESPR empowers the Commission to extend the ban to other product groups through delegated acts. The Working Plan does not specify a timeline for extending the destruction ban beyond textiles and footwear, but the regulatory framework is in place to do so.

ESPR's phased rollout gives companies time — but the companies that start preparing now will have a significant advantage.

When should companies start preparing for ESPR?

Now. Even though most product-specific requirements won't be enforceable until 2028 or later, the data infrastructure needed to comply — structured product records, supplier data collection processes, substances of concern tracking — takes significant time to build. Companies that wait for final delegated acts will find themselves scrambling to restructure their entire product data landscape under deadline pressure. The best way to prepare for ESPR is to get your product data in order today.

Does ESPR apply to non-EU companies?

Yes. ESPR applies to all products placed on the EU market, regardless of where they are manufactured. If a product is sold in the EU — whether by an EU-based company or imported from a third country — it must comply with the applicable ecodesign requirements and carry a DPP once the relevant delegated act is in force.

What is the difference between ESPR and the EU Battery Regulation?

The EU Battery Regulation (EU) 2023/1542 is a standalone regulation that establishes its own sustainability, labelling, and due diligence requirements for batteries — including the Battery Passport, mandatory from 18 February 2027. ESPR covers the broader product landscape. While both regulations introduce Digital Product Passports, they are separate legal instruments with separate requirements.

What happens if a company doesn't comply with ESPR?

ESPR follows the standard EU enforcement model: Member States are responsible for market surveillance and setting penalties, which must be effective, proportionate, and dissuasive. Specific penalty amounts and enforcement mechanisms will vary by Member State. Non-compliance could also result in products being blocked from the EU market or removed from sale.

Will ESPR affect products already on the market?

This depends on the specific delegated act. ESPR empowers the Commission to set requirements that apply to products placed on the market after a given date — not retroactively to existing stock. However, once a delegated act is in force, any new product placed on the market must comply, including new production runs of existing product designs.

ESPR is the EU's most ambitious product sustainability regulation to date. It will reshape how products are designed, documented, and tracked across their lifecycle. Three things matter most for product companies right now.

First, the destruction ban for unsold clothing and footwear hits on 19 July 2026 — that is the first hard deadline for large enterprises. Second, the DPP Registry goes live in mid-2026, signalling that the technical infrastructure for Digital Product Passports is being built now. Third, the Working Plan gives clear visibility into which product groups face requirements first — textiles, steel, aluminium, tyres, furniture, and mattresses are all on the 2026–2029 roadmap.

The common thread across all of these: structured product data is the foundation. Without it, meeting DPP requirements, tracking substances of concern, and generating audit-ready documentation becomes a manual, error-prone scramble for every delegated act that applies to your portfolio.

If your team is spending more time wrestling with product data and regulatory mapping than getting products to market, see how Complir automates product-to-regulation mapping and compliance documentation across your entire portfolio.

Sources & References

• Ecodesign for Sustainable Products Regulation (EU) 2024/1781 — Official Journal of the EU (EUR-Lex)
• Ecodesign requirements for sustainable products — EUR-Lex Summary
• Implementing the Ecodesign for Sustainable Products Regulation — European Commission Green Forum
• 2025–2030 ESPR Working Plan — European Commission Green Forum

This article is for informational purposes only and does not constitute legal advice. Regulatory requirements may vary by product category, market, and specific circumstances. Consult with a qualified legal professional for compliance guidance specific to your situation.