What is the ESPR?

What does ESPR stand for?

ESPR stands for the Ecodesign for Sustainable Products Regulation. Its full legal citation is 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.

The regulation is sometimes referred to informally as the "new Ecodesign Regulation" or "Ecodesign Regulation recast," as it replaces and significantly expands the scope of the earlier Ecodesign Directive 2009/125/EC. Unlike the directive it replaces, the ESPR is a regulation — meaning it applies directly in all EU member states without requiring national transposition.

What is the purpose of the ESPR?

The ESPR creates a comprehensive legal framework for making products sold in the EU more sustainable throughout their entire lifecycle. It addresses the environmental impact of products from design and manufacturing through use and end-of-life.

The regulation pursues six core objectives:

• Ecodesign requirements — mandatory sustainability standards covering durability, reparability, recyclability, energy and resource efficiency, carbon footprint, and restrictions on substances of concern
• Digital Product Passports — structured digital records making product sustainability data transparent and accessible to consumers, businesses, and regulators
• Consumer empowerment — better product information enabling informed purchasing decisions, supporting the EU's right-to-repair and green claims agenda
• Destruction ban — rules prohibiting or requiring disclosure of the destruction of unsold consumer products, initially targeting textiles and footwear
• Circular economy acceleration — requirements for recycled content, design for disassembly, and component reuse that create market pull for secondary raw materials
• Climate alignment — product-level carbon footprint declarations contributing to the EU's Fit for 55 and Green Deal targets

The ESPR is a cornerstone of the European Green Deal and the EU Circular Economy Action Plan. It shifts the regulatory approach from purely energy-efficiency focused (under the old directive) to a holistic sustainability framework covering the full product lifecycle.

Which products does the ESPR cover?

The ESPR covers nearly all physical products placed on the EU market, a dramatic expansion from the old Ecodesign Directive which only covered energy-related products. Specific requirements are set through product-category delegated acts adopted by the European Commission.

The ESPR Working Plan (COM/2025/187), published in April 2025, identifies priority product groups in two waves:

First wave (delegated acts in preparation):

• Textiles (including footwear)
• Iron and steel
• Detergents
• Furniture
• Tyres
• Washing machines and washer-dryers
• Dishwashers
• Aluminium
• Electronic displays
• Photovoltaic panels, inverters, and systems

Second wave (planned for future delegated acts):

• Mattresses
• Light sources
• EV chargers
• Electric motors
• Tumble dryers
• Mobile phones and tablets
• Welding equipment

Additionally, 19 product groups currently regulated under the Ecodesign Directive (including computers, air conditioners, vacuum cleaners, and solar panels) are transitioning to the ESPR under Article 79. Existing implementing measures remain in force until 31 December 2026.

Excluded from the ESPR scope are food, feed, medicinal products, and certain product categories covered by separate EU regulations (such as vehicles and medical devices).

How does the ESPR relate to Digital Product Passports?

The ESPR is the primary EU regulation establishing the framework for DPPs (Digital Product Passports). Articles 9 to 14 of the regulation set out the DPP architecture, data requirements, access rights, and governance structure.

Key DPP provisions in the ESPR include:

• Article 9 — establishes that delegated acts may require a DPP for any product category, specifying what data must be included
• Article 10 — defines the technical requirements for DPPs, including unique identifiers, data carriers (QR codes, RFID), and interoperability standards
• Article 11 — establishes tiered access rights: consumers see environmental and product data, market surveillance authorities access full compliance information, and supply chain actors access data relevant to their role
• Article 12 — mandates the creation of a centralised EU DPP registry, enabling cross-border market surveillance and preventing false or duplicate passports
• Article 14 — requires DPPs to remain accessible for at least 10 years after the last unit of a product model is placed on the market

While the ESPR provides the overarching DPP framework, other EU regulations introduce their own product-specific DPP requirements. The EU Battery Regulation requires battery passports from February 2027, the PPWR mandates packaging DPPs from August 2028, and the CPR introduces digital product information for construction products. Read our detailed guides on the CPR and Digital Product Passports and the expected ESPR textile delegated act.

When does the ESPR take effect?

The ESPR entered into force on 18 July 2024. However, the regulation works through a phased implementation — the framework itself is in force, but product-specific requirements only apply once delegated acts are adopted for each product category.

Key dates and milestones:

• 18 July 2024 — ESPR enters into force (framework provisions apply)
• April 2025 — ESPR Working Plan (COM/2025/187) published, setting product group priorities
• 19 July 2025 — Destruction ban on unsold textiles and footwear takes effect for large enterprises
• 2026–2027 (expected) — First delegated acts adopted for textiles, iron & steel, and other priority products
• 31 December 2026 — Transition deadline for Ecodesign Directive product groups (Article 79)
• 2028–2030 (expected) — Product-specific requirements (including DPPs) begin applying, approximately 18–24 months after delegated act adoption

The implementing acts specifying the technical details of the DPP registry, data formats, and interoperability requirements are being developed in parallel and are expected by 2026–2027.

What is the ESPR Working Plan?

The ESPR Working Plan (COM/2025/187) is a Commission document published in April 2025 that sets out which product groups will receive delegated acts and in what sequence. Article 18 of the ESPR requires the Commission to adopt such a plan to prioritise products based on their environmental impact and potential for improvement.

The working plan is significant because it signals to industry which products will be regulated first, enabling companies to begin preparation. Key features include:

• Product prioritisation criteria — products are selected based on EU-wide environmental impact, volume placed on the market, improvement potential, and existing regulatory gaps
• Two-wave approach — a first wave of products with delegated acts in active preparation (textiles, iron & steel, detergents, furniture, tyres, etc.) and a second wave planned for subsequent years
• Horizontal measures — cross-cutting requirements that may apply to multiple product groups simultaneously, including the DPP registry, substance of concern reporting, and green claims substantiation
• Stakeholder consultation — each delegated act goes through an impact assessment and public consultation process before adoption

The working plan is a living document — the Commission may update it based on new evidence, emerging environmental priorities, or political developments. Organisations should monitor its evolution and engage in public consultations for their product categories.

How does the ESPR differ from the old Ecodesign Directive?

The ESPR represents a fundamental expansion of EU ecodesign policy compared to the Ecodesign Directive 2009/125/EC. The differences span legal form, product scope, and the types of requirements that can be set.

• Legal instrument — the ESPR is a regulation (directly applicable in all member states), while the Ecodesign Directive required national transposition, leading to implementation variations
• Product scope — the directive covered only energy-related products (~31 product groups); the ESPR covers nearly all physical products placed on the EU market
• Digital Product Passports — the directive had no DPP framework; the ESPR introduces mandatory DPPs with a centralised EU registry
• Sustainability requirements — the directive focused primarily on energy efficiency; the ESPR adds durability, reparability, recyclability, recycled content, carbon footprint, and substance of concern restrictions
• Destruction ban — the ESPR prohibits or requires disclosure of the destruction of unsold consumer products; the directive had no such provision
• Circular economy design — the ESPR includes requirements for design for disassembly, component reuse, and material recovery that were absent from the directive
• Market surveillance — the ESPR strengthens enforcement through the DPP registry, enabling cross-border digital market surveillance

Products regulated under the old directive transition to the ESPR under Article 79. Existing implementing measures remain in force until 31 December 2026, after which new ESPR delegated acts will set updated requirements including DPPs.

How can organisations prepare for ESPR compliance?

Organisations should begin preparing for ESPR compliance now, even before their product category's delegated act is adopted. Building DPP-ready data infrastructure takes 12–24 months for most organisations, and early movers gain competitive advantage.

Recommended preparation steps:

1. Gap analysis — assess current product data availability against expected ESPR requirements, identifying where material composition, environmental footprint, and supply chain data is missing
2. Supply chain mapping — map data flows from raw materials through manufacturing and distribution, identifying which suppliers need to contribute DPP data and what data exchange formats to use
3. Data governance — establish internal processes for collecting, validating, and maintaining sustainability data at the product level, including responsibilities and quality controls
4. Technology evaluation — assess DPP platform options, data carrier technologies, and system integration requirements — ideally with vendor-neutral guidance to avoid lock-in
5. Stakeholder engagement — participate in sector-specific standardisation initiatives (CEN/CENELEC), industry association working groups, and EU public consultations on relevant delegated acts
6. Pilot projects — start with a limited product range or market to test DPP data collection, carrier placement, and consumer-facing presentation before full-scale roll-out
7. Regulatory monitoring — track the progress of delegated acts, implementing acts, and standardisation mandates relevant to your product categories

Regen Studio provides independent ESPR advisory — from readiness assessments and compliance roadmaps to data architecture design and vendor-neutral technology selection. We work with brands, governments, supply chain partners, and industry associations across the EU and beyond.