Guide to the Ecodesign for Sustainable Products Regulation (ESPR)

The Ecodesign for Sustainable Products Regulation (ESPR) represents a major advancement in the EU’s sustainability agenda. As a central component of the Circular Economy Action Plan (CEAP) and the European Green Deal, ESPR aims to accelerate the transition toward a climate-neutral economy by 2050.

Expanding on the foundation laid by the Ecodesign Directive2009/125/EC, ESPR introduces a comprehensive framework to systematically address the environmental performance of products placed on the EU market. It sets ecodesign requirements across diverse product categories, targeting resource efficiency, durability, reparability, and recyclability.

A pivotal feature of the regulation is the Digital Product Passport (DPP) initiative. By 2030, all organisations operating within regulated sectors must implement DPPs to enhance product transparency and traceability.

Early adoption will be required for certain industries as soon as 2027, making it essential for sustainability professionals to begin preparing their data infrastructure, supply chain collaboration, and compliance strategies now.

Humble Beginnings – The Ecodesign Directive 2009/125/EC

The original Ecodesign Directive, established in 2009, served as a framework aimed primarily at reducing energy consumption in specific categories of products - particularly electrical devices involved in energy-intensive operations, such as boilers, food preparation equipment, and audio-visual systems.

As a framework directive, it did not impose direct minimum ecological requirements on products. Instead, these requirements were defined individually for each product category through implementing acts. Manufacturers seeking to market products within the EU had to stay informed about the relevant implementing acts and comply with the specific rules they introduced.

In March 2022, the European Commission proposed a new regulation to build upon and eventually replace the 2009 directive. This new initiative, known as the Ecodesign for Sustainable Products Regulation (ESPR), aims to broaden the scope and strengthen sustainability requirements across a wider range of products.

What is the ESPR?

The European Union adopted the Circular Economy Action Plan (CEAP) in March 2020 to tackle issues related to consumption and waste across the region.

As part of this initiative, the Ecodesign for Sustainable Products Regulation (ESPR) came into effect on July 18, 2024. This comprehensive legislation sets out sustainability requirements for physical products entering the EU market.

The ESPR significantly broadens the scope of the original directive, covering a wide array of products across various industries. Its goal is to enhance product circularity and environmental performance throughout the entire lifecycle.

The regulation applies to all physical goods sold within the EU, including those manufactured outside its borders. As a result, companies with global supply chains are still subject to its requirements.

Importantly, the ESPR’s reach extends beyond manufacturers. It encompasses the entire value chain - from retailers and distributors to waste management and recycling operators - ensuring that sustainability is addressed at every stage of a product’s journey.

Which industries does the ESPR affect?

It highlights an initial set of 33 product categories across various industry sectors to spearhead the implementation of the legislation. Of these, 18 have been prioritised due to their high potential for reducing environmental impact.

Highlighted end-user product categories include:

• Textiles and footwear
• Furniture
• Tyres
• Mattresses
• Detergents
• Paints and varnishes
• Lubricants
• Cosmetics
• Toys
• Fishing gear
• Absorbent hygiene products

Highlighted intermediate product categories include:

• Iron and steel
• Commodity chemicals
• Non-ferrous, non-aluminium metal products
• Aluminium
• Plastics and polymers
• Pulp and paper
• Glass

These product groups were selected based on the significant environmental harm associated with their production and disposal. Over time, additional industries will be incorporated, with specific ecodesign requirements introduced through delegated acts tailored to each sector.

SMEs (Small to Medium Enterprises)

Although the ESPR has a broad scope, it acknowledges that small and medium-sized enterprises (SMEs) may face greater challenges in meeting its requirements compared to larger companies.

To support SMEs, Article 19 of the regulation mandates that both EU Member States and the European Commission implement a range of supportive measures. These include tailored guidelines, financial aid, and training programs, which will be delivered through supplementary legislative acts.

Exemptions

Although the Ecodesign for Sustainable Products Regulation(ESPR) covers a wide range of product categories, certain items are excluded from its scope.

For instance, food products, animal feed, and specific medical goods are not subject to ESPR requirements. However, these products may still fall under other relevant EU legislation.

What Are the ESPR’s Sustainability Criteria?

The Ecodesign for Sustainable Products Regulation (ESPR)sets minimum sustainability standards for products manufactured or sold within the EU. These criteria aim to improve environmental performance across various product categories and focus on the following key attributes:

1. Durability
   • Products must be designed to last longer, helping to reduce waste.
   • Specific durability targets will be defined through delegated acts for each product group (e.g., electronics, textiles)
2. Reusability
   • Products should be suitable for repeated use.
   • Clear usage information must be provided to encourage reuse by end users.
3. Recyclability and Recycled Content
   • Packaging must contain at least 25% recycled plastic by 2025, rising to 30% by 2030.
   • Electronics and textiles will need to meet recycled content thresholds outlined in the Circular Economy Action Plan.
4. Upgradability
   • Products should be designed to allow upgrades with new components.
   • This helps combat planned obsolescence and extends product lifespans.
5. Reparability
   • Products must be easier for consumers to repair themselves or return for repair.
   • This supports a more circular product lifecycle.
6. Resource Efficiency
   • Manufacturing processes should minimise waste.
   • Use of rare earth elements and other scarce resources should be reduced.
7. Energy Efficiency
   • Building on the 2009 Ecodesign Directive, the ESPR continues to push for lower energy consumption.
   • For example, household appliances saved 230 million tons of oil equivalent (Mtoe) annually by 2020.
   • Future delegated acts will extend these targets to ICT and other product categories.
8. Reduction of Hazardous Substances
   • The ESPR aligns with REACH regulations to limit the use of harmful chemicals that hinder recycling and reuse.

Energy Labelling Regulation

Complementing the Ecodesign for Sustainable Products Regulation (ESPR), the Energy Labelling Regulation ensures that energy-related products are clearly labelled with their energy efficiency ratings, enabling consumers to make informed comparisons.

Originally introduced under Directive 92/75/EECin 1992, the regulation has undergone several updates. The most recent version- Regulation (EU)2017/1369 - was adopted in August 2017 and came into effect in 2021. This revision introduced a simplified energy rating scale from A to G, with colour coding from green (most efficient) to red (least efficient), replacing the older, more complex system.

To further support transparency, the European Product Registry for Energy Labelling (EPREL)was launched in 2022. This online database allows consumers to compare energy efficiency classes across different products.

Together with the ESPR, the Energy Labelling Regulation provides a more complete picture of a product’s environmental impact. These measures empower consumers to make eco-conscious choices and support the EU’s broader circular economy objectives.

Ban on Destruction of Unsold Goods

To reduce unnecessary resource waste, the ESPR introduces a ban on destroying unsold and returned products:

• Effective Dates: 2026 for large enterprises and 2030 for SMEs
• Initial Focus: The ban primarily targets textiles and footwear, with potential expansion to other categories if proven effective.
• Transparency Requirement: Large companies must publicly disclose the volume of unsold products discarded each year and the reasons for doing so.

Green Public Procurement

The ESPR also sets mandatory sustainability standards for public procurement:

• Public authorities must purchase products that meet top-tier sustainability and circularity criteria.
• Procurement contracts must comply with the principles outlined in Directives 2014/24/EU and 2014/25/EU, ensuring alignment with EU sustainability goals.

Industry Example: Mobile Phones and Tablets

One of the first product categories to receive specific ecodesign requirements under the ESPR is mobile phones and tablets. From 20 June 2025, the following rules will apply to smartphones, feature phones, cordless phones, and slate tablets sold in the EU:

• Durability and Protection: Devices must be resistant to accidental drops, scratches, dust, and water.
• Battery Performance: Batteries must endure at least 800 charge/discharge cycles while retaining 80% of their original capacity.
• Repairability and Spare Parts: Manufacturers must ensure critical spare parts are available within 5–10 working days, and for 7 years after the product model is no longer sold in the EU.
• Software Support: Operating system updates must be provided for at least 5 years after the last unit of a product model is placed on the market.
• Access for Repair Professionals: Professional repairers must be granted non-discriminatory access to necessary software and firmware for component replacement.
• Transparency for Consumers: Products must clearly display information on energy efficiency, battery longevity, and a reparability score, helping consumers make informed, sustainable choices.

Similar detailed requirements are expected to be introduced for other product categories under the ESPR.

Supporting Circularity Goals

Together, these measures aim to help the EU double its circular material use rate by 2030, up from 11.5% in 2022. To facilitate implementation, the ESPR requires the use of Digital Product Passports for all regulated products, ensuring traceability and transparency throughout the product lifecycle.

Understanding Digital Product Passports (DPPs)

Digital Product Passports (DPPs) are a groundbreaking innovation designed to track and share essential information about a product throughout its entire lifecycle - from raw materials to end-of-life recycling.

Using smart data carriers like QR codes, RFID tags, or NFC chips, DPPs are physically linked to products, enabling instant access to a rich dataset that evolves as the product moves through manufacturing, distribution, use, and disposal.

What Information Can DPPs Contain?

Each passport can include:

• Material composition – What the product is made of
• Manufacturing details – Where and how it was produced
• Supply chain history – Its journey from origin to market
• Environmental impact – Carbon footprint and sustainability metrics
• Recyclability – How and where it can be recycled
• Ownership and warranty – Who owns it and coverage details

This data is structured to meet regulatory standards while also being practical for businesses to use in improving sustainability and operational efficiency.

Why Are DPPs Important?

DPPs are designed to be interoperable, meaning they can integrate with existing digital systems and databases. This ensures that manufacturers, retailers, repairers, recyclers, and regulators all have access to consistent, reliable, and actionable information.

By making product data transparent and verifiable, DPPs:

• Empower consumers to make informed, eco-conscious choices
• Enhance product traceability and circularity
• Support compliance with the ESPR, CSRD, and other sustainability regulations
• Help businesses reduce waste and improve resource efficiency

A Cornerstone of the ESPR

As a central feature of the Ecodesign for Sustainable Products Regulation, DPPs are not just a compliance tool - they’re a catalyst for change. They enable a more circular economy by ensuring every product carries a digital identity that supports sustainability from start to finish.

Key Milestones in the ESPR Rollout (2025–2030)

The implementation of the Ecodesign for Sustainable Products Regulation (ESPR) is being phased in through a series of strategic milestones leading up to full compliance by 2030. Here's a breakdown of the major developments:

1. April 2025 – ESPR Working Plan Released: On 16 April 2025, the European Commission published the first official ESPR Working Plan. This document outlines which product categories will be prioritised in the coming years, setting the stage for the development of specific rules, impact assessments, and stakeholder engagement processes.
2. Late 2025 – Public Consultation on Delegated Acts: A public consultation is expected by the end of 2025, focusing on the Delegated Acts - the legal instruments that will define detailed sustainability requirements for each priority product group.
3. December 2025 – Digital Product Passport Standards Finalised: One of the most anticipated milestones is the release of harmonised technical standards for Digital Product Passports (DPPs). These standards, aligned with CEN/CENELEC frameworks, will define how DPPs are structured, shared, and integrated across industries.
4. July 2026 – Launch of Central DPP Registry: A centralised registry and digital portal for DPPs will be established, enabling real-time tracking, data access, and lifecycle transparency for regulated products.
5. Early 2027 – First Delegated Acts Published: The first formal Delegated Acts will be issued for key sectors such as Textiles, Steel, and Furniture. The Batteries sector will also reach its implementation deadline in February 2027, marking the start of mandatory compliance for those products.
6. 2030 – Full Compliance Deadline: By 2030, large and medium-sized enterprises that place products in the outlined industries must fully comply with the ESPR and DPP-related requirements. This includes meeting ecodesign standards, implementing DPPs, and adhering to transparency and sustainability obligations across the value chain.

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The priority product categories set out in the ESPR Working Plan

A central purpose of the ESPR’s latest communication is to clearly define which product categories will be subject to regulation.  

While the original regulation outlined a broad scope, the newly published Working Plan provides clarity by identifying priority product groups, setting timelines, and explaining the rationale behind these choices.

The selection process was informed by three key inputs:

• A comprehensive screening by the Joint Research Centre (JRC)
• A public consultation held in 2023
• Insights from the Ecodesign Forum convened in February 2025

These efforts assessed products based on market relevance, environmental impact, and potential for improvement. The result is a focused list comprising:

• Four priority product groups
• Two intermediate categories
• Two horizontal requirements that apply across multiple sectors

This targeted approach ensures that regulatory efforts are directed where they can deliver the greatest sustainability gains.

End User Product Groups

Although initially listed as priorities under the ESPR, several product categories have been excluded from the 2025 Working Plan due to various complexities and considerations. Here's a summary of the reasons behind their exclusion:

Chemicals

• The category includes a wide range of complex subgroups - such as petrochemicals, polymers, speciality chemicals, and plastics - with significant regulatory overlap.
• A dedicated study to better define and assess chemicals as a product group is scheduled to begin by the end of 2025.

Detergents, Paints and Lubricants

• These products were found to have a relatively lower environmental impact and limited potential for improvement compared to those prioritised in the current plan.
• They continue to be regulated under other targeted legislation, such as the EU Detergent Regulation.

Footwear

• Separated from the broader Textiles category due to its more complex design, supply chains, and functional components.
• Initially assessed as having a lower environmental impact, but a new study will be commissioned and completed by the end of 2027 to reassess its prioritisation.

Horizontal Requirements in the ESPR Working Plan

Beyond identifying priority product categories, the ESPR Working Plan also highlights key horizontal requirements - cross-cutting sustainability measures that apply to multiple product types sharing similar characteristics. These requirements are designed to streamline regulation and amplify impact across sectors.

The ESPR originally proposed the use of horizontal ecodesign rules to address common challenges across product groups. The Working Plan now confirms which of these will be prioritised first:

1. Repairability and Repair Scoring (Target: 2027)

• Recognised as having high potential for improvement, this measure aims to boost product longevity and reduce waste.
• It may include additional requirements around durability, resource use, and climate impact.
• The scope, currently under preparatory study, could cover items such as consumer electronics and small household appliances.

2. Recycled Content and Recyclability of Electrical and Electronic Equipment (Target: 2029)

• Also identified as a high-impact area, this requirement focuses on increasing the use of recycled materials and improving end-of-life recyclability.
• It supports circularity for critical raw materials, contributes to climate goals, and helps prevent waste.

These horizontal measures are expected to play a pivotal role in achieving the ESPR’s broader sustainability objectives by applying consistent standards across diverse product categories.

Energy-Related Products Under the ESPR

Going forward, energy-related products, including those previously regulated under the Ecodesign Directive, will fall under the scope of the Ecodesign for Sustainable Products Regulation (ESPR).

The Ecodesign and Energy Labelling Working Plan (2022–2024) identified 35 energy-related product categories, with 19 of them granted a transition period until 31 December 2026. These include:

1. Photovoltaic panels
2. Space and combination heaters
3. Water heaters
4. Solid fuel local space heaters
5. Air conditioners, including air-to-air heat pumps and comfort fans
6. Solid fuel boilers
7. Air heating and cooling products
8. Ventilation units
9. Vacuum cleaners
10. Cooking appliances
11. Water pumps
12. Industrial fans
13. Circulators
14. External power supplies
15. Computers
16. Servers and data storage products
17. Power transformers
18. Professional refrigeration equipment
19. Imaging equipment

The remaining 16 product categories have been carried forward into the current ESPR Working Plan for continued regulation, based on efficiency and alignment with broader sustainability goals.

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Projected Impacts of the ESPR by 2030

The European Commission has outlined the anticipated benefits of the Ecodesign for Sustainable Products Regulation (ESPR) and the Energy Labelling Regulation across households, industry, the environment, and the job market by 2030:

Households

• EU citizens are expected to save a combined €473,736 annually on energy bills, thanks to more efficient products and clearer labelling.

Industry

• Over €1 trillion in annual EU sales will benefit from harmonised single market rules.
• Early adopters in sectors like green steel, aluminium recycling, repair services, and traceability technologies will gain a competitive edge.

Environment

• Maintains the 145 Mt CO₂ annual reduction achieved under previous ecodesign rules.
• Expands environmental savings to include material footprint reductions, covering 31% of climate impacts and 34% of fossil resource use within the EU consumption basket.

Jobs & Competitiveness

• Builds on the 346,000 jobs already created through earlier ecodesign initiatives.
• Aligns with broader EU strategies, including the 2025 Clean Industrial Deal, the Competitiveness Compass, and the upcoming Circular Economy Act.

Preparing for ESPR Compliance: What Businesses Should Do Next

With Digital Product Passports (DPPs) set to become a cornerstone of the ESPR, businesses should make DPP readiness a top priority in their compliance strategy.

1. Start Mapping Product Data Now: Depending on your company’s size and the number of products affected by the ESPR, you may need to manage hundreds or even thousands of data points. Begin by auditing and organising your product information - materials, manufacturing details, lifecycle data, and more.
2. Engage Stakeholders Across the Value Chain: Successful DPP implementation requires collaboration. Involve internal teams (e.g. product, compliance, IT) and external partners (e.g. suppliers, recyclers, repair services) early to ensure smooth data flow and alignment with ESPR standards.
3. Build the Right Digital Infrastructure: Develop or upgrade your systems to collect, manage, and share product data in line with ESPR requirements. Your infrastructure must support interoperability and integrate with the upcoming central DPP registry.
4. Seek Expert Support: To streamline the process, consider partnering with a Digital Product Passport consulting firm and a technology provider, such as Provenant, to guide your strategy, ensure technical compliance, and accelerate implementation.

First Steps Towards Compliance

You may have determined that you’re organisation will need to comply with the ESPR and implement DPPs in the near future. Now you need an expert technical partner to ensure that your organisation gets a robust, future-proof DPP implementation.

At Provenant, we can guarantee that your organisation will gain access to a powerful Digital Product Passport platform and tailored technical advice and support for rolling out DPPs across all of your organisation’s products.

Provenant enables you to create, validate and manage EU Digital Product Passports at scale – on a specialist platform built for compliance readiness, product traceability and circularity.

Alongside our internal expertise, Provenant has a dedicated, extensive partner ecosystem to support your organisation’s DPP implementation, from flawless system integration to expert DPP Consultancy.

With compliance deadlines closing in, the time is now – reach out to Provenant today.

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