Your Next Steps Toward Compliance
A practical starting framework for assessing your ESPR exposure, preparing for Digital Product Passport requirements, and building a defensible compliance path.
Start here
Most companies that will be affected by Regulation (EU) 2024/1781 (ESPR) are not yet in compliance programs. Some do not yet know they are affected. The difference between a manageable compliance project and a crisis remediation is almost entirely a function of when you start.
This guide gives you a concrete starting framework. It is not exhaustive — every product category has specific requirements that will be defined by delegated acts. But these steps apply universally.
Step 1: Determine whether ESPR applies to your products
ESPR applies to physical products placed on the EU market. The initial product categories being prioritized by the European Commission include:
- Textiles (including apparel and footwear)
- Electronics and ICT equipment
- Furniture
- Steel, aluminium, and cement
- Chemicals and paints
- Mattresses and tyres
- Batteries (already covered separately under Regulation (EU) 2023/1542)
If your products fall into any of these categories, or if you sell physical goods into the EU market under any brand, you should assume ESPR applies and plan accordingly.
The European Commission maintains the ESPR Working Plan, updated periodically, which defines the timeline for product-specific delegated acts. Monitor it for your product category.
Step 2: Identify your role in the supply chain
Your obligations depend on whether you are the manufacturer, importer, or distributor. Review the "Who is Affected" guide if you are uncertain.
If you source finished products from a non-EU manufacturer, you may carry full manufacturer obligations — including DPP creation — unless the manufacturer has appointed an Authorised Representative in the EU.
Confirm this in writing with your suppliers now.
Step 3: Audit your product data readiness
A Digital Product Passport requires structured data about each product. The required data elements (defined per product category in delegated acts) typically include:
- Material composition: What the product is made of, including percentages
- Substances of concern: Any SVHCs above 0.1% by weight (REACH threshold)
- Carbon footprint: Manufacturing and logistics emissions data
- Recycled content: Percentage of recycled material used
- Repairability information: Repair scores, spare part availability, disassembly instructions
- End-of-life guidance: Recycling instructions and material recovery rates
Run a gap analysis: for each required data element, do you have the data today? If not, who in your supply chain holds it — and do you have a contractual right to receive it?
Most companies find that tier-2 and tier-3 supplier data is the biggest gap. This is the hardest part to remediate quickly, which is why early action matters.
Step 4: Review and update supplier contracts
Supplier agreements that predate ESPR typically contain no data-sharing obligations relevant to DPPs. You need to:
- Add a data provision clause requiring suppliers to provide the material and substance data needed for your DPP
- Specify the format (structured, machine-readable) and delivery timeline
- Assign liability if a supplier provides inaccurate data that results in a non-compliant DPP
This is not a quick process. Suppliers need to update their own internal systems. Plan for a 6–12 month supplier onboarding cycle for complex product categories.
Step 5: Assess your technology readiness
A DPP is not a PDF — it is a machine-readable digital record accessible via a data carrier (QR code, RFID, NFC, or barcode) linked to an EU-recognized registry.
Your technology stack needs to support:
- Data collection: Aggregating material and substance data from suppliers into a structured format
- DPP generation: Creating valid DPP records that meet the EU registry schema
- Registry submission: Submitting DPPs to the EU DPP registry (going live July 2026)
- Data carrier attachment: Linking physical products to their DPP via QR or RFID
- Data maintenance: Updating DPP records when product specs change
Assess whether your current ERP, PLM, or product information management system can support this, or whether you need a specialist DPP platform.
Step 6: Map your enforcement timeline
Not all ESPR requirements apply at the same time. Work backwards from the dates that matter for your product category:
- July 2026: EU DPP registry goes live; initial product categories begin phased compliance
- February 2027: Battery passports mandatory under Regulation (EU) 2023/1542 for EV and industrial batteries
- 2027–2030: Delegated acts for most ESPR product categories enter force
Build a compliance calendar with internal milestones: supplier data collection completed, DPP records created, registry submission tested, data carriers attached to products.
Step 7: Assign internal ownership
ESPR compliance is not an IT project, a legal project, or a sustainability project alone. It requires coordination across:
- Product development: Ecodesign requirements affect how products are designed
- Procurement and supply chain: Supplier data collection is the critical path
- IT and systems: DPP infrastructure and registry integration
- Legal and compliance: Liability management and documentation
- Operations: Data carrier attachment in manufacturing or logistics
Assign a named owner for the overall compliance program. Without clear ownership, cross-functional projects stall.
What not to do
- Do not wait for your industry association to produce guidance before starting
- Do not assume a compliance consultant can fix this in 90 days if you start in 2027
- Do not treat DPP as a checkbox exercise — the data quality requirements are substantive and auditable
- Do not sign supplier contracts that assign all ESPR liability to the supplier without verifying they can actually comply
References
- Regulation (EU) 2024/1781 (ESPR), Articles 4–15 (product requirements and DPP obligations)
- EU DPP registry timeline: European Commission ESPR Working Plan 2025–2030, COM(2025) 187 final
- Battery passport requirements: Regulation (EU) 2023/1542, Articles 77–86
- REACH substance disclosure thresholds: Regulation (EC) 1907/2006, Article 33
- CSRD sustainability reporting: Directive (EU) 2022/2464