Ecodesign for Sustainable Products Regulation (ESPR)

The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, is one of the EU’s most important new product sustainability laws. It entered into force on 18 July 2024 and creates a framework for setting ecodesign requirements for almost all physical products placed on the EU market.

The purpose is clear: products sold in the EU should become more durable, repairable, reusable, energy-efficient, recyclable, and transparent throughout their lifecycle. For manufacturers, importers, distributors, online sellers, and brand owners, the ESPR is not only an environmental regulation. It is becoming a market access requirement.

What Is the ESPR?

The ESPR replaces and expands the earlier Ecodesign Directive 2009/125/EC. The old framework mainly applied to energy-related products. The ESPR goes much further. It can apply to nearly all categories of physical goods, with limited exemptions such as food, feed, medicinal products, and certain living products.

Rather than setting one single rule for every product immediately, the ESPR creates a legal framework. The European Commission will adopt product-specific and horizontal requirements through delegated acts. This means that detailed obligations will be introduced step by step for selected product groups.

Main Objectives of the ESPR

The ESPR is designed to improve product sustainability before products reach consumers. Instead of focusing only on waste at the end of life, it looks at the full product lifecycle, from design and material selection to repair, reuse, recycling, and disposal.

Future ecodesign requirements may cover:

• Product durability and expected lifetime
• Reusability, upgradability, and repairability
• Energy and resource efficiency
• Recycled content requirements
• Use of substances that may affect recyclability or circularity
• Availability of spare parts
• Recyclability and remanufacturing potential
• Carbon footprint and environmental footprint information
• Waste reduction
• Product sustainability information for consumers and authorities
  
  

Who Is Affected?

The ESPR can affect any business placing relevant products on the EU market. This includes EU manufacturers, non-EU manufacturers exporting to the EU, importers, distributors, online sellers, and marketplaces.

The regulation applies to products placed on the EU market whether they are manufactured inside or outside the EU. This is especially important for international sellers. A non-EU supplier may still need to provide product sustainability data, technical information, material details, and traceability information if the product falls under a future ESPR delegated act.

Digital Product Passport (DPP)

One of the most important changes under the ESPR is the introduction of the Digital Product Passport (DPP). The DPP is a digital record linked to a product, component, or material. It is intended to make sustainability, circularity, compliance, and traceability information available electronically.

The exact content of the DPP will depend on the product category and the relevant delegated act. However, DPP information may include:

• Product identification data
• Manufacturer, importer, or responsible economic operator details
• Material composition
• Information on origin of materials
• Technical performance data
• Repair and maintenance information
• Recycling and end-of-life information
• Substance-related information
• Environmental impact data
• Compliance documentation or references

The DPP is expected to support several users at the same time. Consumers may use it to understand product sustainability and repair options. Repairers and recyclers may use it to access technical and material information. Market surveillance authorities and customs authorities may use it to check whether products meet EU requirements.

How Will the DPP Be Accessed?

The ESPR foresees that DPP information will be accessible electronically, usually through a data carrier such as a QR code, barcode, or similar digital link placed on the product, packaging, or accompanying documentation. The final access method will depend on the product-specific rules.

Businesses should not treat the DPP as a simple marketing page. It is a structured compliance tool. The information must be accurate, reliable, and aligned with the technical documentation behind the product.

Product Groups Prioritised Under the ESPR

The European Commission adopted the first ESPR and Energy Labelling Working Plan in April 2025. It covers the period 2025 to 2030 and identifies priority product groups for future ecodesign work.

The priority areas include:

• Steel and aluminium
• Textiles, with a focus on apparel
• Furniture
• Tyres
• Mattresses
• Certain energy-related products

The Commission also plans horizontal measures, including repairability requirements and recyclability requirements for electrical and electronic equipment.

Rules on Destruction of Unsold Consumer Products

The ESPR also introduces rules addressing the destruction of unsold consumer products. This is particularly relevant for sectors with high inventory turnover, seasonal products, fashion items, footwear, and e-commerce returns.

The regulation introduces a ban on the destruction of unsold textiles and footwear, with specific derogations to be defined. It also requires certain companies to disclose information about discarded unsold consumer products, including quantities and reasons for disposal.

This means companies should review how they handle returns, excess stock, damaged stock, discontinued products, and unsold seasonal goods.

ESPR and GPSR: Different but Connected

The ESPR and the General Product Safety Regulation (GPSR) are separate laws, but they are closely connected in practice.

The GPSR focuses on product safety, traceability, responsible economic operators, technical documentation, warnings, and market surveillance cooperation. The ESPR focuses on sustainability, circularity, durability, repairability, environmental performance, and digital product information.

For many consumer products, businesses will need to manage both areas together. A product may need GPSR technical documentation for safety and ESPR-related data for sustainability and Digital Product Passport requirements.

EaseCert supports businesses with GPSR compliance, technical documentation, label review, EU Responsible Person coverage, and related product compliance preparation. Learn more about our GPSR compliance services, the GPSR technical file documentation guide, the EU GPSR technical file and product compliance guide, and the GPSR risk analysis process.

What Businesses Should Prepare Now

Many ESPR obligations will become practical only once delegated acts are adopted for specific product groups. However, companies should not wait until the final deadline. ESPR readiness depends on product data, supplier cooperation, documentation, and internal systems. These cannot usually be built overnight.

1. Review Your Product Portfolio

Start by identifying which products may fall into the first priority groups, especially textiles, apparel, furniture, mattresses, tyres, steel, aluminium, and electrical or electronic products.

2. Map Materials and Components

Businesses should collect accurate material and component data from suppliers. This includes composition, origin, recycled content, substances of concern, coatings, treatments, and packaging materials where relevant.

3. Strengthen Supplier Documentation

Future ESPR and DPP obligations will rely heavily on supplier data. Companies should request declarations, test reports, bills of materials, safety data sheets where applicable, and technical specifications.

For chemical documentation, see our guides on chemical testing for EU compliance and Safety Data Sheets (SDS).

4. Check Labelling and Traceability

ESPR does not remove existing product labelling duties. Businesses still need to comply with applicable safety, traceability, textile, chemical, sector-specific, and consumer information rules.

For GPSR-related labelling, see our GPSR labelling requirements guide, our GPSR warning examples guide, and our EU compliance guide for selling consumer products.

5. Prepare for Digital Product Passport Data

Companies should begin identifying which product data they already have and which data is missing. The DPP will likely require structured, product-level information. Generic sustainability claims will not be enough.

6. Align Compliance, Sustainability, and IT Teams

The DPP is not only a legal topic. It also involves data management, access rights, product identifiers, supplier systems, website or platform infrastructure, and customer-facing information. Legal, compliance, sustainability, product development, procurement, and IT teams should work together.

Common Mistakes to Avoid

Businesses should avoid treating ESPR as a future-only issue. The framework is already in force, the first working plan has been adopted, and technical preparation for the DPP is underway.

Common mistakes include:

• Assuming ESPR only applies to EU manufacturers
• Waiting until product-specific rules are final before collecting supplier data
• Treating the DPP as a marketing webpage instead of a compliance tool
• Using sustainability claims without supporting documentation
• Ignoring repairability, spare parts, and end-of-life information
• Keeping GPSR documentation and sustainability documentation completely separate
• Failing to assign internal responsibility for product data management
  
  

Why ESPR Matters for Market Access

The ESPR will change how products are designed, documented, labelled, and presented in the EU market. It will also increase the importance of reliable technical documentation and supplier traceability.

For many businesses, the practical challenge will not be only understanding the law. The real challenge will be proving that each product meets the applicable requirements and that the required information is available, accurate, and consistent across labels, technical files, online listings, and digital systems.

Businesses selling through marketplaces should also understand how sustainability and compliance obligations interact with online platform requirements. See our guide on Amazon EU sales and GPSR compliance.

How EaseCert Can Support

EaseCert supports companies with EU product compliance documentation, GPSR risk assessments, technical file preparation, labelling review, EU Responsible Person coverage, and Safety Gate registration support.

Although ESPR-specific delegated acts will define the final product-by-product requirements, companies can already strengthen their compliance position by building reliable product files, improving supplier documentation, and aligning product safety, traceability, and sustainability data.

For online sellers, EU Safety Gate registration may also be relevant under GPSR. More information is available in our EU Safety Gate registration guide and our review of the EU Safety Gate 2025 report.

Businesses should also understand the broader enforcement environment surrounding EU compliance, including the EU Product Liability Directive 2024/2853, GPSR penalties and enforcement risks, what happens if you do not comply with GPSR, and why an EU Responsible Person matters.

Companies should also prepare internal procedures for incident handling and recalls. See our guides on handling a product recall under GPSR and the new EU product recall requirements under GPSR.

Additional operational topics such as EU packaging EPR compliance and our EU product launch checklist may also become relevant when preparing products for the EU market.

Conclusion

The ESPR is a major step toward making sustainable products the standard in the EU. It will affect product design, material selection, repairability, recyclability, sustainability claims, digital information, and market surveillance.

Businesses that sell physical products in the EU should begin preparing now. The best starting point is a structured product compliance file that combines safety, traceability, material, supplier, and lifecycle information. This will make future ESPR and Digital Product Passport compliance easier to manage when product-specific requirements become mandatory.

Official EU Resources

• European Commission: Ecodesign for Sustainable Products Regulation (ESPR)
• Regulation (EU) 2024/1781 on ecodesign requirements for sustainable products
• European Commission: Implementing the Ecodesign for Sustainable Products Regulation
• European Commission: ESPR and Energy Labelling Working Plan 2025-2030
• Joint Research Centre: Methodology for defining data requirements for the Digital Product Passport under the ESPR framework
• European Commission: Circular Economy
• European Commission: Digital Product Passport Information