ESPR — Ecodesign for Sustainable Products Regulation
The EU's cornerstone regulation for sustainable products. Mandates Digital Product Passports, ecodesign requirements, and destruction bans across nearly all product categories.
Overview
The Ecodesign for Sustainable Products Regulation (ESPR) — Regulation (EU) 2024/1781 — is the EU's horizontal framework for setting sustainability requirements on virtually all physical products placed on the internal market. It replaces the Ecodesign Directive 2009/125/EC, extending requirements far beyond energy-related products.
ESPR is the foundational legislation for Digital Product Passports in the EU.
Legal basis
- Proposed: 30 March 2022
- Adopted: 13 June 2024
- Published in OJ: 28 June 2024
- Entered into force: 18 July 2024
- Regulation ID: EU 2024/1781
- Replaces: Ecodesign Directive 2009/125/EC
- Type: Regulation (directly applicable, no transposition needed)
Scope
Applies to nearly all physical products placed on the EU market, with product-specific requirements defined through delegated acts.
Exceptions: food, feed, medicinal products, living organisms, military equipment.
Digital Product Passport requirements
Each product regulated under ESPR must carry a DPP — a mandatory digital data record accessible via a physical data carrier (QR code). Required data includes:
- Unique product identifier (model, batch, or item level)
- Material composition and presence of substances of concern
- Carbon footprint and environmental impact data
- Durability, repairability, and recyclability information
- Instructions for use, maintenance, and end-of-life treatment
- Manufacturer/importer identity and contact details
- Compliance documentation and certifications
Technical standards: GS1 Digital Link URI syntax is the primary interoperability standard. Data must be machine-readable with role-based access controls (consumers, recyclers, regulators, customs). Data retained for product lifetime + 10 years minimum.
DPP Registry
The Commission must establish a DPP Registry by 19 July 2026. Economic operators register DPPs in the registry before placing products on the market. The registry automatically generates unique identifiers and provides access to customs and market surveillance authorities.
Working Plan 2025-2030
On 16 April 2025, the Commission adopted the first ESPR Working Plan. Priority product categories and their delegated act timelines:
| Product group | Delegated act target | DPP compliance (est.) | |---------------|---------------------|-----------------------| | Iron and steel | 2026 | ~2028 | | Textiles / Apparel | 2027 | ~mid-2028 | | Tyres | 2027 | ~2029 | | Aluminium | 2027–2028 | ~2030 | | Furniture | 2028 | ~2030 | | Mattresses | 2029 | ~2031 | | Dishwashers | 2026 | ~2028 | | Washing machines | 2026 | ~2028 | | Refrigerating appliances | 2028 | ~2030 | | Electric motors | 2028 | ~2030 | | EV chargers | 2028 | ~2030 | | Mobile phones and tablets | 2030 | ~2032 |
After a delegated act is adopted, companies typically have 18 months to comply.
Destruction of unsold goods
- 9 February 2026: First delegated acts adopted on unsold product destruction
- 19 July 2026: Destruction ban on unsold textiles/footwear for large companies
- 19 July 2028: Ban extends to medium-sized companies
- Small/micro enterprises are exempt
Key requirements
- Digital Product Passports — mandatory product-level data carriers
- Ecodesign requirements — durability, repairability, recyclability
- Substance of concern disclosure — SVHCs above 0.1% by weight
- Recycled content minimums — phased in by product category
- Destruction ban — unsold consumer products cannot be destroyed
- Green public procurement — mandatory criteria for public buyers
Penalties
Member states must set effective, proportionate, dissuasive penalties per Art. 68. No EU-wide fine figure is specified in the regulation text — financial amounts are determined at national level. Common enforcement consequences include:
- Fines (amounts determined by each member state's market surveillance authority)
- Temporary exclusion from public procurement
- Product market withdrawal and recall
- Customs blocking of imports based on DPP data
Germany, France, and the Netherlands historically operate the most active market surveillance authorities for product compliance.
Who is affected
Any economic operator placing a regulated product on the EU market bears obligations under ESPR:
- Manufacturers — primary obligation holders; must ensure DPP is created and registered
- Importers — responsible where the manufacturer is outside the EU
- Distributors — must verify DPP data carrier is present before making products available
- Authorised representatives — act on behalf of non-EU manufacturers
- Online marketplaces — must ensure products listed comply with ESPR and link to valid DPP
- Fulfilment service providers — cannot store or ship products they know to be non-compliant
No size threshold. Obligations apply from the date a product-specific delegated act enters into force.
Key articles
| Article | Subject | |---------|---------| | Art. 4 | Framework for ecodesign requirements (delegated acts mechanism) | | Art. 9 | DPP general requirements — unique identifier, data carrier, accessibility | | Art. 10 | DPP technical requirements — granularity (model/batch/item), machine-readable formats | | Art. 11 | DPP access rights — consumers, recyclers, regulators, customs | | Art. 12 | DPP Registry — Commission must establish by 19 July 2026 | | Art. 68 | Penalties — member states must set effective, proportionate, dissuasive penalties |
Enforcement
- Member states designate market surveillance authorities
- DPP Registry enables customs-level enforcement at EU borders
- Customs authorities may block import of non-compliant products based on DPP data
- Penalties set by member states: must be "effective, proportionate, and dissuasive"
- Penalties include fines, temporary exclusion from public procurement, and product withdrawal/recall
Key dates
| Date | Milestone | |------|-----------| | 30 March 2022 | Commission proposal | | 18 July 2024 | ESPR enters into force | | 16 April 2025 | First Working Plan 2025-2030 adopted | | 9 February 2026 | First delegated acts adopted (unsold goods destruction) | | 19 July 2026 | DPP Registry operational | | 19 July 2026 | Destruction ban — textiles/footwear (large companies) | | 2026-2029 | Delegated acts for priority products | | 2027-2030+ | First DPP requirements enter into force | | 19 July 2028 | Destruction ban extends to medium companies | | 2028 | Mid-term Working Plan review |
Interactions with other regulations
- Battery Regulation: First product-specific DPP under the ESPR umbrella
- PPWR: Packaging data integrated into ESPR DPP (one DPP carries both)
- REACH/SCIP: SVHC data feeds directly into DPP substance fields
- EmpCo: DPP data substantiates green claims
- Right to Repair: Repairability data required in DPP