EXECUTIVE SUMMARY
The Ecodesign for Sustainable Products Regulation (ESPR) extends ecodesign requirements beyond energy-related products to nearly all physical goods sold in the EU. The regulation enables the European Commission to set product-specific performance and information requirements via delegated acts, and introduces the Digital Product Passport (DPP). Iron, steel, and textiles are first in line for delegated acts (2026–2027). Companies should begin mapping their product portfolios against expected requirements and preparing data infrastructure for DPP compliance.
What is the ESPR
Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation, was published in the Official Journal of the European Union on 28 June 2024 and entered into force on 18 July 2024. It establishes a framework for setting ecodesign requirements for virtually all physical products placed on the EU market or put into service, with the objective of making environmentally sustainable products the norm in the EU.
The ESPR replaces the Ecodesign Directive 2009/125/EC, which was limited to energy-related products. The new regulation extends its reach to cover nearly all physical goods, including components and intermediate products, traded within the EU. Only a narrow set of product categories is excluded, including food and feed, medicinal products, and certain vehicles subject to harmonised type-approval systems.
The ESPR is rooted in the European Commission's 2020 Circular Economy Action Plan, itself a building block of the European Green Deal. Its stated aim is to improve product durability, reusability, repairability, recyclability, energy efficiency, and resource efficiency throughout the entire product lifecycle, from raw material extraction through manufacturing, distribution, use, and end-of-life disposal.
Three pillars define the ESPR framework: ecodesign requirements (performance and information requirements for products, to be set via delegated acts); the Digital Product Passport (DPP), a machine-readable digital identity that will accompany regulated products; and rules on unsold consumer products, including mandatory disclosure and a ban on destroying unsold apparel and footwear.
From the Ecodesign Directive to the ESPR
Ecodesign Directive 2009/125/EC
- Scope limited to energy-related products
- ~30 product-specific implementing measures in force
- Focus on energy efficiency and standby power
- No Digital Product Passport
- No rules on unsold goods
- No substances-of-concern requirements
- Directive form (required national transposition)
ESPR: Regulation (EU) 2024/1781
- Scope covers virtually all physical products
- Up to ~30 new delegated acts anticipated by 2030
- 16 product aspects: durability, repairability, recyclability, recycled content, carbon footprint, water use, and more
- Mandatory Digital Product Passport for all regulated products
- Unsold goods: disclosure obligation + destruction ban
- Substances of concern: information and restriction requirements
- Regulation form (directly applicable in all Member States)
Which products are covered
The ESPR covers a broad range of physical products placed on the EU market or put into service, including components and intermediate products, subject to its exclusions. A product manufactured outside the EU can be within scope. Identify the applicable product rules and your legal role before assigning responsibilities.
Excluded products
The regulation excludes food and feed (as defined by Regulation (EC) No 178/2002), medicinal products (Directive 2001/83/EC), veterinary medicinal products, living plants and animals, products of human origin, and products of plants and animals relating directly to their future reproduction. Its vehicle exclusion is limited by the wording of Article 1(2). Batteries have separate obligations under Regulation (EU) 2023/1542; do not treat that separate regime as a blanket ESPR exclusion.
Economic operators in scope
The regulation assigns different responsibilities to economic operators. Read the roles below with the applicable product measure and its requirements.
Manufacturers
Primary obligation holders. Responsible for conformity assessment, CE marking, technical documentation, and making the DPP available. Both EU and non-EU manufacturers are covered.
Importers
Must verify the manufacturer has carried out conformity assessment and that the DPP, CE marking, and technical documentation are in order before placing a product on the EU market.
Distributors and dealers
Must verify CE marking and DPP presence. Must not make available products they know or should know do not conform to ecodesign requirements.
Fulfilment service providers and online marketplaces
New for ecodesign law. Online marketplaces must cooperate with market surveillance authorities and, where required, remove or disable access to non-compliant product listings.
The 2025–2030 Working Plan
The ESPR requires the Commission to adopt multi-annual working plans, covering at least three years, identifying which product groups will be regulated and in what sequence. Article 18(5) of the ESPR pre-identified 11 product groups to be prioritised in the first working plan.
The Commission adopted the first ESPR and Energy Labelling Working Plan on 16 April 2025, covering 2025–2030 with a mid-term review planned for 2028. It prioritises six product groups and two horizontal measures alongside energy-related products carried over from the previous Ecodesign Directive working plan. The table records the plan’s indicative adoption targets. It does not establish whether an act has since been adopted or when a product requirement applies.
Priority product groups and indicative adoption timelines
| Product Group | Type | Delegated Act Adoption (Indicative) | Application date | Status |
|---|---|---|---|---|
| Iron & steel | Intermediate | 2026 | Check the applicable act | Preparatory work |
| Textiles / apparel | Final product | 2027 | Check the applicable act | JRC study ongoing |
| Aluminium | Intermediate | 2027 | Check the applicable act | Preparatory work |
| Tyres | Final product | 2027 | Check the applicable act | Preparatory work |
| Furniture | Final product | 2028 | Check the applicable act | Preparatory work |
| Mattresses | Final product | 2029 | Check the applicable act | Preparatory work |
| Repairability (horizontal) | Cross-product | 2027 | Check the applicable act | Scope TBD |
| Recycled content & recyclability of EEE (horizontal) | Cross-product | 2029 | Check the applicable act | Scope TBD |
Products deferred from the first working plan
The first Working Plan deferred detergents, paints and lubricants, and called for further work on chemicals and footwear. Its study forecasts are planning assumptions, not evidence that a study has been completed or a requirement adopted. Check the Commission’s current work programme for the product concerned.
Energy-related products in transition
Article 79 preserves parts of the previous Ecodesign Directive during the transition. The 2026 and 2030 dates concern powers to adopt or amend measures, not automatic expiry of all existing product requirements. Existing implementing measures continue until repealed or declared obsolete. Check the measure applying to each product.
The Digital Product Passport
Product-group delegated acts determine DPP requirements, scope and application dates. Article 9 permits specified exemptions, so a passport is not automatically mandatory for every product covered by any ecodesign requirement.
The DPP will store and share product information across the value chain, from manufacturers to consumers to market surveillance authorities. It is designed to enable product traceability, support informed purchasing decisions, facilitate customs checks, and underpin the circular economy by making repair, reuse and recycling information readily accessible.
What information will the DPP contain?
The ESPR's Annex III provides the general framework. Product-specific delegated acts will determine the exact data requirements for each product group. At a minimum, the DPP may include information on: product identification and unique identifiers, sustainability performance data, materials and substances of concern, carbon and environmental footprint, durability and repairability, recycled content, and end-of-life instructions.
DPP registry and infrastructure
The DPP registry is established under Article 13 of the ESPR. The Commission launched the registry and its test environment on 20 July 2026, following Implementing Regulation (EU) 2026/1778. It registers unique product identifiers and associated metadata. Product information is stored in a decentralised manner. Registration infrastructure does not by itself make every product subject to a passport obligation.
Unsold products: disclosure and destruction ban
The ESPR sets disclosure requirements for discarded unsold consumer products and a prohibition on destroying specified unsold apparel, accessories and footwear. Check these duties separately from product-specific ecodesign measures.
Mandatory disclosure of discarded unsold products (Article 24)
Economic operators who discard unsold consumer products, or have them discarded on their behalf, must publicly disclose information about the type, quantity, weight, and reasons for discarding, as well as the waste treatment operations used. This information must be published on the company's website or, for companies subject to CSRD reporting, may be included in their sustainability report with a website link.
The disclosure obligation applies to large companies from the first full financial year after the ESPR entered into force, meaning FY 2025 data, to be reported during 2026. Medium-sized companies are not required to disclose until 19 July 2030. Small and micro enterprises are exempt.
The Commission adopted Implementing Regulation (EU) 2026/2 on 9 February 2026. It was published on 10 February and entered into force on 2 March 2026. It applies from 2 March 2027. Article 1 covers products discarded from the first full financial year after that application date, with disclosure within 12 months after the end of the year. This does not postpone the earlier disclosure obligation under Article 24.
Prohibition on destroying unsold apparel and footwear (Article 25)
Since 19 July 2026, large companies have been prohibited from destroying unsold apparel, clothing accessories and footwear listed in ESPR Annex VII, subject to applicable derogations. The ban extends to medium-sized companies from 19 July 2030. Small and micro enterprises are exempt.
On 9 February 2026, the Commission also adopted a delegated regulation establishing derogations from this prohibition. Destruction is permitted in specific circumstances, including where a product is dangerous within the meaning of the General Product Safety Regulation (EU) 2023/988, where the product is unfit for purpose due to non-compliance with EU law, where the product is damaged or defective, or where destruction is required as a corrective measure under EU law.
Implementation timeline
Selected acts and implementation updates
This table combines dated descriptions from the original article with selected later corrections. It is not a complete current adoption register. Verify the relevant act and any amendments before relying on a recorded status.
| Act | Subject | Recorded status |
|---|---|---|
| Regulation (EU) 2026/2 | Implementing act: standardised disclosure format for discarded unsold consumer products (Art. 24) | Adopted 9 Feb 2026 |
| Delegated Regulation (destruction ban derogations) | Derogations from the prohibition on destroying unsold apparel and footwear (Art. 25) | Adopted 9 Feb 2026 |
| Iron & steel ecodesign requirements | Performance and information requirements, including DPP, for iron and steel products | Expected 2026 |
| Textiles / apparel ecodesign requirements | Performance and information requirements, including DPP, for textile products | JRC study ongoing; expected 2027 |
| DPP registry and technical infrastructure | Registry for unique product identifiers and associated metadata (Article 13) | Launched 20 July 2026 |
| Harmonised DPP standards (CEN/CLC/JTC24) | Technical standards for DPP interoperability and data formats | Decision (EU) 2026/1736, published 15 July 2026, cites six harmonised DPP standards. Check the relevant references and the requirements they cover. |
| Green Public Procurement requirements | Mandatory sustainability criteria for public purchasing (assessed per product group) | To be assessed per product |
Connections to other EU regulations
The ESPR does not operate in isolation. It intersects with several other EU regulatory frameworks that companies placing products on the EU market must consider:
EU Batteries Regulation (Regulation (EU) 2023/1542). The battery-passport requirement comes from the Batteries Regulation and relies on the common ESPR DPP technical system. Check the scope and application dates of each relevant product regime separately. For a detailed analysis, see our EU Batteries Regulation Compliance Guide.
Corporate Sustainability Reporting Directive (CSRD). Companies subject to CSRD reporting may include their unsold goods disclosure within their sustainability report rather than publishing it separately. The ESPR's product-level data (once available through DPPs) will complement the entity-level sustainability data required by the simplified ESRS.
Corporate Sustainability Due Diligence Directive (CSDDD). Article 75(4) requires the Commission to evaluate by 19 July 2028 the potential benefits of including social sustainability requirements within the ESPR. Assess any CSDDD obligations separately against their own scope and timetable.
Carbon Border Adjustment Mechanism (CBAM). For intermediate products like iron, steel, and aluminium, ESPR ecodesign requirements will complement CBAM's carbon pricing at the border. The regulations address different dimensions: CBAM focuses on embedded emissions pricing, while the ESPR will address circularity, recyclability, and resource efficiency.
Right to Repair Directive (Directive (EU) 2024/1799). Adopted alongside the ESPR, this directive complements ecodesign repairability requirements by establishing consumer rights to repair, including obligations on manufacturers to provide spare parts and repair services.
REACH and CLP Regulations. The ESPR's substances-of-concern provisions interact with REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and CLP (Classification, Labelling and Packaging). Product-specific delegated acts may restrict substances that inhibit circularity, a complementary approach to REACH's risk-based restrictions.
Build your ESPR readiness roadmap
Tell us which products you place on the EU market and where the compliance work needs attention. We can discuss the applicable requirements, evidence gaps and support that would be useful.
How to prepare
Step 1: map the product portfolio
Map the product portfolio to the Working Plan and any measures already applying to it. Record each product’s classification, your legal role, the relevant source and confirmed application dates. Use the gaps in evidence, product design and systems to set a project timetable, rather than assuming a standard preparation period.
Step 2: check unsold-product duties
Confirm whether Article 24 applies to each entity and identify the financial year and evidence covered by its disclosure. Plan the format transition under Regulation (EU) 2026/2. For apparel and footwear within the destruction ban, review decisions about stock, returns and end-of-life treatment against the prohibition and applicable derogations.
Step 3: prepare the product data
We recommend mapping the product data already held, its owners and the evidence supplied by partners. Test a representative data flow and record gaps in access, updating and verification. Use Annex III as a framework for preparation, then check the exact fields and responsibilities against the applicable product measure before treating the system as compliant.
Step 4: review product design
Article 5(1) of the ESPR lists 16 product aspects that ecodesign requirements may address: durability, reliability, reusability, upgradability, repairability, possibility of maintenance and refurbishment, presence of substances of concern, energy use and efficiency, water use and efficiency, resource use and efficiency, recycled content, possibility of remanufacturing, recyclability, possibility of material recovery, environmental impacts (including carbon and environmental footprint), and expected waste generation. Conduct a gap analysis of your products against these aspects to identify where design changes may be needed.
Step 5: track requirements and consultations
Assign an owner to track the Commission’s product-specific work and relevant consultation notices. Check whether a consultation is open before planning a submission. Record new adopted acts, entry-into-force dates and application dates in the compliance register, and review the work plan when those records change.
Frequently asked questions
Conclusion
We suggest managing ESPR preparation through a product-level compliance register with named owners and evidence requirements. Keep confirmed obligations separate from Working Plan targets and unresolved technical details, so teams can make decisions on a clear basis.
Start with the measures and unsold-product duties that apply to your business. Commission the missing product, supplier and systems evidence, then review the work plan when an applicable act or requirement changes. This makes preparation proportionate to the products and decisions involved.