ESPR: An Ecodesign Compliance Guide for Manufacturers and Importers
The ESPR is among the EU’s most far-reaching product sustainability regulations. Regulation (EU) 2024/1781, which entered into force in July 2024, creates a framework for setting ecodesign requirements on virtually all physical products sold in the EU — covering durability, repairability, recycled content, energy efficiency, and the Digital Product Passport. Delegated acts defining product-specific rules are expected from 2026 onwards, with the first product-specific delegated acts for iron and steel targeted for 2026. This guide explains the regulation’s scope, key obligations, the Digital Product Passport, the timeline ahead, and what manufacturers and importers should do now.
By Bo Yu, Founder & Managing Director | Updated March 2026 | ~15 min read
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: What Changed
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)
What Products Are Covered
The ESPR's scope is deliberately broad. It covers any physical product placed on the EU market or put into service, including components and intermediate products. This applies regardless of whether the product is manufactured inside or outside the EU – any economic operator placing goods on the EU market must comply.
Excluded products
The regulation explicitly 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. Certain vehicles and components subject to EU type-approval systems are also excluded. Batteries are regulated separately under Regulation (EU) 2023/1542 (the EU Batteries Regulation), though the ESPR's DPP framework is designed to be interoperable with the battery passport.
Economic operators in scope
The ESPR imposes obligations on all economic operators in the value chain:
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 & 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 & 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: Which Products Come First
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 scheduled for 2028. The plan prioritises six product groups for new ESPR delegated acts, plus two horizontal requirements, alongside energy-related products carried over from the previous Ecodesign Directive working plan.
Priority product groups and indicative adoption timelines
| Product Group | Type | Delegated Act Adoption (Indicative) | Earliest Application (est.) | Status |
|---|---|---|---|---|
| Iron & steel | Intermediate | 2026 | ~2027/2028 | Preparatory work |
| Textiles / apparel | Final product | 2027 | ~2028/2029 | JRC study ongoing |
| Aluminium | Intermediate | 2027 | ~2028/2029 | Preparatory work |
| Tyres | Final product | 2027 | ~2028/2029 | Preparatory work |
| Furniture | Final product | 2028 | ~2029/2030 | Preparatory work |
| Mattresses | Final product | 2029 | ~2030/2031 | Preparatory work |
| Repairability (horizontal) | Cross-product | 2027 | ~2028/2029 | Scope TBD |
| Recycled content & recyclability of EEE (horizontal) | Cross-product | 2029 | ~2030/2031 | Scope TBD |
Products deferred from the first Working Plan
Several product groups listed in Article 18(5) of the ESPR were not included in the first Working Plan: detergents, paints, and lubricants (assessed as lower environmental impact than selected products), chemicals (further study needed, expected to be completed by end of 2025), and footwear (new study to be commissioned, completion expected by end of 2027). These may be reassessed during the 2028 mid-term review.
Energy-related products in transition
For 19 energy-related product categories already regulated under the Ecodesign Directive, the ESPR provides a transition period until 31 December 2026 during which existing measures continue to apply. A further 16 product categories have been carried over from the 2022–2024 working plan. New ESPR delegated acts for energy-related products (covering washing machines, dishwashers, displays, and others) are being developed in parallel, with adoption dates ranging from 2026 to 2028.
The Digital Product Passport
The Digital Product Passport (DPP) is a core innovation of the ESPR. Every product for which ecodesign requirements are adopted through a delegated act will be required to carry a DPP – a machine-readable digital record accessible via a data carrier (such as a QR code) attached to the product, its packaging, or accompanying documentation.
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 Commission is required to establish a DPP registry – a centralised digital infrastructure for storing and searching DPP data – by 19 July 2026 (Article 12 of the ESPR). A web portal will allow stakeholders to search for and compare DPP data. Harmonised technical standards for the DPP system are being developed by CEN/CLC/JTC24, with publication of eight standards planned for 31 March 2026 (revised from the original December 2025 target). As of mid-March 2026, these have not yet been formally published.
Unsold Consumer Products: Disclosure and Destruction Ban
The ESPR contains two obligations relating to unsold consumer products that are already active or imminently applicable – unlike the product-specific ecodesign requirements, these do not depend on future delegated acts for their core scope.
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.
On 9 February 2026, the Commission adopted Regulation (EU) 2026/2, which establishes the standardised disclosure format (published in the Official Journal on 10 February 2026, entering into force on 1 March 2026). The standardised format will apply from 2 March 2027 – but the underlying disclosure obligation under Article 24 already applies to large companies for FY 2025. Companies may use any reasonable format for their FY 2025 disclosure and must transition to the standardised format from the 2027 reporting period onward.
Prohibition on destroying unsold apparel and footwear (Article 25)
From 19 July 2026, large companies will be prohibited from destroying unsold apparel, clothing accessories, and footwear (as listed in ESPR Annex VII). 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
Status of Delegated Acts
| Act | Subject | Status (March 2026) |
|---|---|---|
| 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 | Implementing acts on unique identifiers, data carriers, access rights (Art. 12) | Due by July 2026 |
| Harmonised DPP standards (CEN/CLC/JTC24) | Technical standards for DPP interoperability and data formats | Expected; not yet published |
| 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 ESPR explicitly amends the Batteries Regulation and the battery passport is designed to be interoperable with the ESPR's DPP. Battery products are regulated under the Batteries Regulation rather than under ESPR delegated acts, but the digital infrastructure is shared. 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). The ESPR defers social aspects to the CSDDD: it requires the Commission to evaluate the potential for setting social requirements for products by 2028, but for now, supply chain human rights and labour standards are addressed through the due diligence framework rather than product regulation.
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
The delegated act clock is ticking. Our product compliance team helps manufacturers, importers and brands map their exposure, build DPP-ready data infrastructure, and prepare for product-group requirements before they are adopted.
How to Prepare: Five Steps for Product Compliance
Step 1 – Map your product portfolio against the Working Plan
Identify which of your products fall within the priority product groups in the 2025–2030 Working Plan: textiles, iron and steel, aluminium, tyres, furniture, mattresses, and energy-related products transitioning from the Ecodesign Directive. For each product group, note the indicative adoption timeline and work backward – you will need 12–18 months of preparation before a delegated act enters into force.
Step 2 – Establish your unsold goods compliance
If you are a large company placing consumer products on the EU market, you must already be tracking and disclosing unsold products discarded during FY 2025. Review the standardised format in Regulation (EU) 2026/2 and plan to transition to it by 2027. If you operate in apparel or footwear, prepare for the destruction ban from 19 July 2026: audit your stock management, returns processing, donation pathways, and recycling partnerships.
Step 3 – Begin building DPP data infrastructure
The DPP will require product-level data covering materials, substances, environmental performance, repairability, and end-of-life instructions. Start mapping what data you currently collect and identifying gaps. Engage with suppliers on data-sharing requirements. While exact DPP data points will be set by product-specific delegated acts, the general framework in the ESPR's Annex III provides a reliable indication of scope.
Step 4 – Audit product design against the 16 product aspects
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 – Monitor delegated act development and participate
The Ecodesign Forum is the Commission's primary stakeholder consultation mechanism for developing ESPR requirements. Monitor the Forum's outputs and participate in public consultations on product-specific preparatory studies. For textiles, the JRC preparatory study consultation is open until 30 March 2026. Track delegated act adoption dates and transition periods, and adjust your compliance timeline accordingly.
Frequently Asked Questions
Conclusion
The ESPR represents one of the most far-reaching product regulation frameworks the EU has adopted. Its potential scope – covering virtually all physical products on the EU market – is matched only by the complexity of its implementation path. With up to 30 delegated acts expected by 2030, each bringing new performance requirements, information obligations, and Digital Product Passport mandates, the regulation will fundamentally reshape how products are designed, manufactured, documented, and marketed in Europe.
But the critical insight for companies today is one of timing and legal precision. The ESPR framework is in force; the product-specific obligations are not. The first active obligations – unsold goods disclosure and the apparel destruction ban – are narrow in scope but immediate in their demands. For everything else, the window between now and the first product-specific delegated acts is not a period of inaction: it is the preparation window. Companies that use this time to map their product portfolios, build DPP-ready data systems, and engage with the Ecodesign Forum consultations will be positioned to comply when their product group's delegated act arrives. Those that wait will face the same compliance demands in a fraction of the time.