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The EU Ecodesign for Sustainable Products Regulation (ESPR) entered into force on 18 July 2024, fundamentally expanding ecodesign requirements from energy-related products to virtually all physical products placed on the EU market. Regulation (EU) 2024/1781 replaces Directive 2009/125/EC and introduces Digital Product Passports, performance requirements for durability and repairability, and a ban on destroying unsold clothing starting 19 July 2026.
The original Ecodesign Directive (2009/125/EC) applied exclusively to energy-related products such as appliances, lighting, and motors. ESPR represents a fundamental shift in EU product regulation, extending sustainability requirements to nearly all physical products sold in the European market. According to the Official Journal publication, ESPR covers "all products placed on the EU market or put into service, including components and intermediate products," with exceptions only for food, feed, medicinal products, and explicitly excluded categories.
This regulatory expansion aligns with the EU's circular economy objectives and Green Deal commitments. The regulation establishes a framework for product-specific requirements to be developed through delegated acts, creating a systematic approach to product sustainability across diverse industries.
Regulation (EU) 2024/1781 was published in the Official Journal on 28 June 2024 and entered into force on 18 July 2024. The European Commission published its first ESPR and Energy Labelling Working Plan for 2025-2030 on 16 April 2025, identifying priority product groups for initial delegated acts.
The Working Plan establishes a clear timeline for product-specific requirements:
The plan also carries forward 16 energy-related product groups from the previous directive, including dishwashers (2026), electric vehicle chargers (2028), refrigerators and freezers (2028), electric motors (2028), and mobile phones and tablets (2030).
ESPR operates as a framework regulation under Article 114 of the Treaty on the Functioning of the European Union. Unlike prescriptive regulations, ESPR establishes the legal basis and procedural rules for the European Commission to adopt delegated acts that define specific ecodesign requirements for individual product groups.
Article 2 of the regulation defines its scope as covering "all products placed on the market or put into service" within the EU, including components and intermediate products. The regulation explicitly excludes food, feed, medicinal products for human or veterinary use, living plants and animals, products of human origin, and products resulting from primary production activities.
Article 8 of ESPR mandates Digital Product Passports (DPP) for products subject to delegated acts. The DPP must be machine-readable, accessible via data carriers such as QR codes or NFC chips, and comply with standardised data formats. The EU DPP Registry, referenced in Article 12, will become operational by 19 July 2026 to support the technical infrastructure.
The DPP must contain product identification data, economic operator information, and product-specific sustainability data as defined in relevant delegated acts. This includes material composition, environmental performance indicators, durability information, repairability scores, substances of concern, and end-of-life handling instructions.
Article 5 establishes two categories of ecodesign requirements that delegated acts may impose:
Performance requirements set minimum thresholds for parameters including durability, reusability, repairability, energy and resource efficiency, recycled content, carbon footprint, and restrictions on substances that inhibit circularity. The regulation lists 20 potential parameters in Annex I.
Information requirements mandate specific data disclosure, including Digital Product Passports and information about Substances of Concern present in products - their identity, location, concentration, and safe use instructions.
The 2025-2030 Working Plan identifies priority product groups representing significant environmental impact and market presence. New product categories under ESPR include:
Energy-related products continue under ESPR with updated requirements, including household appliances, lighting, electronic displays, and ICT equipment.
Article 18 establishes that Member States must designate market surveillance authorities and ensure effective enforcement. Article 19 requires penalties that are "effective, proportionate and dissuasive." Non-compliance may result in products being withdrawn from the market or blocked from entry.
The regulation strengthens market surveillance through standardised product data in Digital Product Passports, enabling more efficient compliance verification and cross-border enforcement coordination.
ESPR defines specific obligations for manufacturers, importers, and distributors. Manufacturers must ensure products comply with applicable ecodesign requirements, affix required markings, and maintain technical documentation. Importers must verify manufacturer compliance and maintain product conformity documentation. Distributors must ensure products carry required information and markings.
Article 25 introduces the most immediate ESPR obligation: from 19 July 2026, large enterprises are prohibited from destroying unsold clothing, clothing accessories, and footwear listed in Annex VII. Medium-sized enterprises have until 19 July 2030. Micro and small enterprises are exempt.
The European Commission adopted delegated regulation defining 10 permitted derogations, including products that are dangerous, non-compliant with law, damaged, or have manufacturing defects.
Article 26 requires large companies to 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 application date.
Companies must prepare for DPP requirements by:
ESPR information requirements will mandate disclosure of substances of concern present in products, including their identity, location within the product, concentration levels, and instructions for safe use and end-of-life management. Companies must establish systems to track and document chemical content across their product portfolios.
Each delegated act includes a minimum 18-month transition period before requirements become enforceable. Based on the Working Plan targets:
A mid-term review is planned for 2028, at which point the Commission may add additional product groups. Candidates mentioned include footwear, paints, detergents, lubricants, and chemical products.
ESPR applies uniformly across all EU Member States as a regulation under Article 288 of the Treaty on the Functioning of the European Union. However, Member States retain responsibility for:
While the substantive requirements are harmonised, enforcement approaches and penalty levels may vary between Member States, following the principle that penalties must be "effective, proportionate and dissuasive."
Portfolio Mapping: Identify products falling into priority categories in the Working Plan. Companies selling textiles, steel-containing products, furniture, tyres, or electronics face the earliest specific requirements.
Data Infrastructure Development: Establish systems to collect, structure, and maintain product sustainability data. This includes material composition, environmental performance metrics, durability indicators, and substances of concern tracking. Centralising this data supports both ESPR compliance and existing regulatory obligations.
Supplier Engagement: Develop processes to collect detailed material and chemical composition data from suppliers. This typically requires 6-12 months to implement effectively across complex supply chains.
Destruction Ban Preparation: Large enterprises selling clothing or footwear must review unsold inventory processes before 19 July 2026. Establish documentation systems for any permitted derogations and prepare disclosure reporting mechanisms.
Digital Product Passport Readiness: Prepare technical infrastructure for DPP implementation, including data carrier selection (QR codes, NFC chips, RFID tags), data format standardisation, and integration planning with the EU DPP Registry.
Regulatory Monitoring: Subscribe to European Commission Green Forum updates and track delegated act development for relevant product groups. Requirements will be defined product-by-product, making targeted monitoring essential.
Cross-functional Coordination: Establish coordination between compliance, product development, procurement, and IT teams. ESPR requirements span multiple business functions and require integrated implementation approaches.
Supply Chain Transparency: Assess current visibility into material composition and chemical content across product portfolios. Limited supplier data represents the highest implementation risk for most companies.
Data Quality and Completeness: Evaluate existing product data quality against anticipated DPP requirements. Incomplete or inaccurate data will require significant remediation before delegated acts take effect.
Market Surveillance Exposure: Review current compliance documentation and market surveillance preparedness. Enhanced enforcement capabilities through Digital Product Passports may increase audit frequency and depth.
Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for setting ecodesign requirements for sustainable products
Official Journal of the European Union, L 2024/1781, 28 June 2024
https://eur-lex.europa.eu/eli/reg/2024/1781/oj
Implementing the Ecodesign for Sustainable Products Regulation
European Commission Green Forum
https://green-forum.ec.europa.eu/implementing-ecodesign-sustainable-products-regulation_en
Ecodesign for Sustainable Products
Department of Enterprise, Trade and Employment (Ireland)
https://enterprise.gov.ie/en/what-we-do/the-business-environment/ecodesign-for-sustainable-products/