ESPR: The EU Ecodesign Regulation—What the Ecodesign for Sustainable Products Regulation Means for Businesses
The Ecodesign for Sustainable Products Regulation (ESPR) is the key European law governing sustainable product design. It defines how products in the EU must be designed, manufactured, documented, and managed at the end of their life cycle—from durability and reparability to energy and resource efficiency, all the way to the Digital Product Passport.
The ESPR took effect on July 18, 2024, and is gradually replacing the previous Ecodesign Directive, which was limited to energy-related products. This expands the regulatory framework to cover a very broad range of physical products in the EU internal market that are sold on the EU market—from textiles and electronics to furniture and batteries, and even building materials and metals.
Executive Summary – ESPR at a Glance
- A New Era in Product Regulation: The ESPR replaces the previous Ecodesign Directive and expands the scope of energy-related products to include nearly all physical goods in the EU internal market, with the exception of food and medicines.
- Sustainability is becoming a prerequisite for market access: Products that do not meet the ESPR requirements may not be sold on the EU market. Compliance is not an option, but a prerequisite for access to the European market.
- The Digital Product Passport (DPP) will become mandatory: For product groups for which a DPP is required, corresponding DPP requirements will apply.
- Phased introduction via delegated acts: The specific requirements will be established on a product-group-by-product-group basis via delegated acts. The first deadlines are already in effect, with additional deadlines following at short intervals through 2030.
- Prohibition on the destruction of unsold goods: As of July 2026, large companies will no longer be permitted to destroy certain unsold consumer products, including clothing, headwear, and shoes.
- Circular economy as a design principle: The ESPR establishes the circular economy not as a downstream waste management issue, but as an integral design principle, from raw materials through use to end-of-life.
What is the ESPR?
The ESPR (Regulation 2024/1781 of the European Parliament and of the Council of June 13, 2024) establishes the European legal framework for setting ecodesign requirements for sustainable products. It lays the groundwork for products on the EU market to become more durable, repairable, recyclable, and resource-efficient.
The Regulation pursues three overarching objectives:
- Climate neutrality by 2050: Reducing emissions and resource consumption through more sustainable product design
- Strengthening the circular economy: Designing products so that materials remain in the economic cycle for as long as possible
- Preventing greenwashing: Sustainability claims must be backed by verifiable data in the future
Differences from the Previous Ecodesign Directive (2009/125/EC)
The previous Ecodesign Directive (Directive 2005/32/EC, amended as 2009/125/EC) was limited to energy-related products—such as washing machines and lighting.
The ESPR fundamentally expands this scope:
Aspect | Ecodesign Directive (old) | ESPR (new) |
Scope | Energy-related products | A very broad range of physical products in the EU internal market |
Legal Form | Directive (national implementation required) | Regulation (directly applicable in all EU member states) |
Focus | Energy Efficiency | Energy Efficiency + Resource Efficiency + Circular Economy |
Digital Product Passport | Not planned | Key tool |
Prohibition on Destruction | Not required | Mandatory for certain product categories |
The previous directive was implemented at the national level through the Energy-Related Products Act (EVPG). Until it is amended, the EVPG will continue to serve as the legal basis for all existing ecodesign product regulations.
Legal Framework and Effective Date
The ESPR entered into force on July 18, 2024. As an EU regulation, it is directly applicable in all member states—national implementation is not required.
The specific product requirements are established through delegated acts issued by the European Commission for individual product categories. Each delegated act defines the specific requirements regarding what data the DPP must contain, which performance standards apply, and which documentation requirements are in effect. Following adoption, there is often a transition period of approximately 18 months, depending on the product category.
According to the European Commission’s work plan, new product regulations covering, among other things, textiles, iron and steel, furniture, mattresses, tires, and aluminum are to be adopted by 2030. In addition, two cross-product-group horizontal requirements regarding repairability and recyclability are planned.
Core Requirements of the ESPR
The ESPR does not set a single requirement, but rather provides a comprehensive catalog that reorients the entire product design process. The specific requirements are defined on a product-group-by-product-group basis through delegated acts, while the ESPR framework specifies the possible dimensions of these requirements.
Durability, Repairability, Recyclability
The guiding principle is that products should last longer, be easier to repair, and be more easily recycled at the end of their life cycle. The ESPR can establish minimum requirements for product groups regarding:
- Durability: Products must achieve defined lifespans
- Repairability: Replacement parts must be available, repair instructions must be accessible, and products must be disassemblable
- Recyclability: Materials must be constructed in such a way that they can be sorted by type and recycled at the end of their life
- Reusability: Products or components should be reusable multiple times
Energy and Resource Efficiency
Building on the previous Ecodesign Directive, the ESPR maintains strict energy efficiency requirements and expands them to include resource efficiency:
- Energy consumption: Minimum standards for energy consumption during the in-use phase
- Water consumption and water efficiency: A new dimension that was not previously regulated
- Material efficiency: Minimizing material use while maintaining functionality
- Environmental and carbon footprint: Requirements for documentation and, in the future, maximum limits
Minimum Percentages of Recycled Materials
For certain product groups, the ESPR may mandate minimum percentages of recycled materials (recycled content). This is intended to promote closed-loop material cycles and increase demand for secondary raw materials. For batteries, phased-in recycled content quotas will take effect starting in 2031 and 2036.
Prohibition on the Destruction of Unsold Goods
One of the most sensational new provisions: The ESPR prohibits the destruction of certain unsold consumer products. Effective July 19, 2026, the destruction ban will apply to large companies, initially covering certain clothing, headwear, and shoes. Additional products may be added by the Commission through delegated acts.
For medium-sized companies (50–249 employees), the destruction ban will not take effect until July 2030; micro and small enterprises are exempt.
In addition, starting in March 2027, affected companies must report annually on the quantities destroyed—in a standardized format.
Substances of Environmental Concern
The ESPR may impose requirements regarding the handling of environmentally relevant substances—such as restrictions on or bans of certain chemicals and pollutants in products. This complements existing regulations such as REACH and creates a consistent framework for reducing problematic substances.
The Digital Product Passport (DPP)
The Digital Product Passport is the ESPR’s central information tool. It makes a product’s sustainability transparent, comparable, and verifiable for consumers, business partners, recycling companies, and government agencies alike.
What Is the DPP? – Concept and How It Works
The Digital Product Passport is a standardized digital data set that summarizes a product’s components, materials, and chemical substances—supplemented by information on repairability, replacement parts, and proper disposal. Structuring environmentally relevant data in a standardized, comparable format enables all stakeholders in the value and supply chains to work together toward a circular economy.
Products that fall within the scope of the ESPR must have a Digital Product Passport in order to be sold on the EU market. Among others, products affected by the DPP include construction products, electrical appliances, textiles, furniture, iron, and steel.
What Data Is Collected
Depending on the product category and delegated act, the following data may be stored in the DPP:
- Materials & Raw Materials: Origin, composition, percentage of recycled materials
- Environment & Sustainability: Carbon footprint, energy consumption, pollutants
- Production & Supply Chain: Manufacturers and suppliers involved, production sites
- Use & Maintenance: Instructions for proper care, availability of replacement parts, recommended service intervals
- Repair & Recycling: Repairability, disassembly instructions, disposal methods
- Compliance & Certification: Proof of compliance, safety data sheets, standards
The information must be verifiable, tamper-proof, and accessible on a role-based basis—not every stakeholder receives the same information.
Technical Implementation
Access to the DPP is provided directly through the product—via a QR code, RFID chip, or NFC access point on the product or its packaging.
A scan grants access to the information that has been made available to the user.
A single scan provides access to the information authorized for the user.
Key technical requirements include:
- Unique product identifiers (e.g., GTIN/serialization)
- Machine-readable data carriers, typically QR codes; depending on the use case, RFID or NFC technologies may also be used.
- Interoperable data formats in accordance with CEN/CENELEC draft standards
- Registration in the central EU DPP registry
Six of the eight CEN/CENELEC JTC 24 DPP standards were published in May 2026 and cited as harmonized in Implementing Decision (EU) 2026/1736.
The central EU DPP registry has been operational since July 20, 2026—initially for organizational registration. Product registration will follow the applicable delegated act for each category.
Timeline and Rollout – Which Product Categories First?
The DPP will be introduced in phases, by product category:
Time Period | Product category | Regulatory Basis |
February 18, 2027 | Batteries (EV, industrial > –2 kWh, LMT) | EU Battery Regulation (sectoral) |
2027/2028 | Textiles and Apparel, , Mattresses | ESPR (Delegated Act) |
2028 | Tires | ESPR (Delegated Act) |
2028/2029 | Furniture, Aluminum | ESPR (Delegated Act) |
September 2029 | Detergents | Detergents Regulation (sectoral) |
2029/2030 | Construction Products, | Construction Products Regulation / ESPR |
August 2030 | Toys | Toy Safety Regulation (sectoral) |
Importance for Transparency Throughout the Entire Supply Chain
For the first time, the DPP creates a uniform, machine-readable database for products that can be accessed by all relevant stakeholders along the supply chain—from manufacturers and retailers to consumers, recycling companies, and government agencies.
Each stakeholder within a value chain is responsible for its own product data and makes it available. The DPP is thus not only an information tool but also a collaboration tool that fosters transparency and cooperation throughout the entire supply chain.
Impact on Industries
The ESPR affects nearly all manufacturing sectors—but not all at the same time. It will be phased in in waves, prioritized based on environmental impact and regulatory readiness.
Textile & Apparel Industry
The textile industry is one of the top priorities under the ESPR. The delegated act is expected to be adopted by the end of 2027, with the compliance requirement taking effect approximately 18 months later. The first phase will cover clothing and clothing accessories—shoes are initially excluded.
Key topics: durability, recyclability, minimum recycled content requirements, fiber content labeling, mandatory DPP, and the already-in-effect ban on the destruction of unsold goods. Extended Producer Responsibility (Textile EPR) will strengthen the financial obligations for end-of-life collection, sorting, and recycling.
Electronics & IT
Electronic products and ICT devices are part of the first wave of the ESPR. Requirements for repairability, software support, spare-part availability, and energy efficiency are being tightened. Repairability scores for consumer electronics are expected to begin in 2027.
Construction and Building Materials Industry
Construction products, including cement, will be subject to DPP requirements under the Construction Products Regulation (sector-specific)—expected to take effect in 2029/2030. The focus is on material cycles, environmental footprint, and durability.
Iron and steel, as intermediate products, are one of the pioneering categories—the delegated act is expected in 2026, with compliance anticipated around 2027/2028.
Furniture & Home Decor
Furniture is included in the second wave of the ESPR. A delegated act is expected in 2028, with compliance anticipated around 2029/2030. Requirements include durability, reparability, recyclability, and the Digital Product Passport. Depending on the regulatory process, mattresses may be regulated either alongside furniture or after furniture.
Impact on Manufacturers, Importers, and Dealers
The ESPR obligations apply to all companies that place products on the EU market—regardless of where they are headquartered.
- Manufacturers are primarily responsible for creating and completing the DPP, as well as for complying with product requirements
- Importers must ensure that imported products have a valid DPP when they are placed on the market
- Distributors may no longer offer affected products without a valid DPP as of the respective effective date
Your Experts for ESPR
Benefits for Consumers and the Environment
The ESPR creates value that goes far beyond regulatory compliance—for both consumers and the environment.
More durable products, easier to repair
Minimum requirements for durability and repairability ensure that products remain usable for longer. Consumers benefit from a longer service life, available replacement parts, and accessible repair instructions—which can be accessed directly on the product via the DPP.
Transparency Through the DPP
The Digital Product Passport makes sustainability claims verifiable. Consumers can trace where a product comes from, how it was manufactured, what its carbon footprint is, and how sustainable it actually is. Greenwashing becomes detectable—in the future, sustainability claims must be backed by verifiable data.
Reducing Waste and CO₂ Emissions
Waste volumes are reduced thanks to longer shelf life, improved recyclability, and the ban on destroying unsold goods. Minimum requirements for recycled materials promote closed-loop material cycles and reduce the demand for primary raw materials.
Strengthening the Circular Economy
The ESPR establishes the circular economy as a design principle. Data from the use and end-of-life phases can be fed back into the design phase. These insights help in selecting materials in a way that conserves resources, designing products to be more sustainable, and increasing their longevity.
Challenges and Points of Criticism
Despite its clear objectives, the ESPR poses significant implementation challenges—particularly for small and medium-sized enterprises.
Implementation Complexity—Especially for SMEs
Data Infrastructure for the DPP
Transition Periods and Legal Uncertainty
International Competitiveness
Timeline, Outlook, and Planned Expansions
The ESPR will take effect gradually over the coming years. Three developments will shape its future course.
Delegated Acts – When Will Which Product Rules Take Effect?
The European Commission’s ESPR Work Plan for 2025–2030 sets out the sequence and approximate timeline:
Wave | Delegated Act Anticipated | Product Categories |
Pioneer Categories | 2026 | Iron and Steel, |
First Wave | 2027 | Textiles/Apparel, Electronics/ICT, Home Appliances, Mattresses, Tires |
Second Wave | 2028 | Aluminum, Furniture, , , Electric Motors |
Third Wave | 2029–2030 | Mattresses (if not in 2028), |
In addition, two cross-product-group horizontal measures are planned: repairability (starting with electronics; textiles may follow) and the recyclability of electrical and electronic equipment.
A midterm review of the work plan is scheduled for 2028. During this review, the Commission can assess progress, adjust timelines, and include new product categories.
Expansion to Additional Product Groups
Feasibility studies are already underway for several product categories, though no timeline has yet been confirmed for the delegated act: footwear (scoping study through the end of 2027), paints and coatings, cleaning products, lubricants, and chemical products.
For textiles, full supply chain traceability has been proposed as the third phase of a phased approach, with a possible target year of 2033.
Interaction with Other EU Regulations
The ESPR does not stand alone, but is part of a growing regulatory ecosystem:
- CSRD (Corporate Sustainability Reporting Directive): Companies must report on sustainability aspects—DPP data can serve as a basis for this
- CBAM (Carbon Border Adjustment Mechanism): CO₂ border adjustment for certain imported products—synergies with carbon footprint data
- EU Taxonomy: Definition of sustainable economic activities—DPP data supports sustainability verification
- EUDR (Deforestation Regulation): Verification of deforestation-free supply chains—relevant for leather, rubber, wood, and other raw materials
- Right to Repair Directive: EU member states must transpose repair obligations into national law by July 2026
- ECGT (Empowering Consumers for the Green Transition): Starting in September 2026, the directive prohibits blanket environmental claims without supporting evidence
Companies that establish the ESPR data infrastructure early on also lay the groundwork for compliance with these related regulations.
Getting Started: DPP Readiness Assessment by Ventum Consulting
The ESPR introduces new requirements—and new opportunities. Many companies are facing the same questions: Which product groups are affected, and when? What data is missing? Which systems need to be expanded? How large is the compliance gap—and how can a scalable, cost-effective DPP solution be developed?
Ventum Consulting’s Digital Product Passport (DPP) Readiness Assessment provides exactly this clarity—as a Quick Assessment for a fast start or as a Deep Assessment with a comprehensive, modular analysis across five pillars: Compliance Analysis, Data & System Readiness, Supply Chain Assessment, Business Case & Change Management, and Strategic DPP Roadmap.
Why Ventum Consulting:
- End-to-End DPP Expertise: From Product Design to End-of-Life
- Regulatory Compliance and Implementation Combined: Legal Requirements with Feasible Data and System Solutions
- Over 20 Years of Digitalization & Transformation: In-Depth Practical Experience in PLM, ERP, Data Architecture, and Supply Chains
- Scalable Solutions: DPP structures that work across multiple product groups and markets
- Proactive Focus on Innovation: We demonstrate how DPP can be used as a lever for innovation and efficiency
Conclusion: ESPR as a Game-Changer for Sustainable Business Practices in Europe
The Ecodesign for Sustainable Products Regulation is more than just a new environmental regulation—it represents a paradigm shift in European product regulation.
Key takeaways:
- Sustainability is becoming a prerequisite for market access. Products that do not comply with the ESPR may not be sold on the EU market.
- The DPP is becoming the central tool of this transformation. It makes sustainability transparent, comparable, and verifiable—for all stakeholders along the value chain.
- The deadlines are set—and the timeframe is tighter than expected. Implementation takes six to twelve months, and data collection from the supply chain is the critical path.
- Acting early creates competitive advantages. Companies that establish data infrastructure, governance, and supplier engagement now will be in a significantly better position when the Delegated Act for their product category is adopted.
- The ESPR is part of a larger ecosystem. CSRD, CBAM, the EU Taxonomy, EUDR—those who build the ESPR data infrastructure are simultaneously laying the groundwork for related regulations.
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FAQ – Frequently Asked Questions About the ESPR and the Ecodesign Regulation
The ESPR (Ecodesign for Sustainable Products Regulation, Regulation 2024/1781) is the new EU Ecodesign Regulation. It establishes the legal framework for ecodesign requirements for sustainable products—ranging from durability and repairability to energy efficiency and the Digital Product Passport.
On July 18, 2024. The specific product requirements will be established in stages through delegated acts.
In general, a very wide range of physical products in the EU internal market—with the exception of food and medicines. The specific requirements are defined on a product-group-by-product-group basis through delegated acts.
The previous directive was limited to energy-related products. The ESPR expands the scope to include virtually all product groups and adds requirements regarding resource efficiency, the circular economy, and the Digital Product Passport.
A delegated act is a set of regulations adopted by the European Commission that establishes the specific requirements for a particular product category—DPP content, performance standards, and documentation requirements. Only once it is adopted is the final deadline for the respective product group determined.
For batteries, the date is set for February 18, 2027. Under the ESPR, textiles, electronics, furniture, and other product categories will follow in stages. The exact deadlines are specified in the respective delegated act, plus a transition period.
Yes. Every company that places products on the EU market must comply with the ESPR requirements—regardless of where it is headquartered.
We support you in implementing the DPP. We also offer our DPP Readiness Assessment—available as either a Quick or Deep Assessment. From compliance analysis and data and system readiness to a strategic roadmap that includes a business case, governance, and a scaling plan.