ESPR — Ecodesign for Sustainable Products Regulation

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 registry is live. ESPR Article 13(1) required the Commission to set up the DPP Registry by 19 July 2026. The Commission launched it, together with a testing environment, technical documentation, implementation guidelines and a helpdesk, on 20 July 2026. Its operating rules are laid down in Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026, adopted under Article 13(5), published in the Official Journal on 17 July 2026 and in force since 6 August 2026. Each Member State must appoint a national registry administrator, the single contact point for managing registry access rights, by 18 February 2027. The act also confirms that the registry serves construction products, toys and detergents under their own regulations, alongside batteries.

Economic operators register DPPs in the registry before placing products on the market, and it provides access to customs and market surveillance authorities. The first mandatory registrations arrive on 18 February 2027, with batteries.

Note that the registry is Article 13. Article 12 covers unique identifiers and Article 14 covers the separate public web portal for searching and comparing passport data. Sources citing "Article 12" for the registry are misreading the regulation.

Harmonised standards

The technical rules are no longer in draft. On 14 July 2026 the Commission adopted Implementing Decision (EU) 2026/1736, published in the Official Journal on 15 July 2026, citing six harmonised standards developed by CEN-CLC/JTC 24 under standardisation request M/604:

A DPP that conforms to these standards, or parts of them, is presumed to comply with the corresponding requirements of ESPR Articles 10 and 11.

Two further standards, EN 18239 (access rights management, information system security and business confidentiality) and EN 18246 (data authentication, reliability and integrity), were published by CEN and CENELEC on 16 September 2026 (EN 18239, EN 18246). That completes the set of eight as published standards, but not as harmonised standards. As of 9 October 2026 neither is cited in the Official Journal, so neither yet gives a presumption of conformity. The Commission's indicative DPP timeline had planned the decision citing them for September 2026. Until an OJ citation appears, the security, access-control and integrity layer of a DPP has no harmonised-standard route to presumed compliance.

Proposed, not law: on 6 October 2026 the Commission proposed a new Regulation on European standardisation, COM(2026) 780, to replace Regulation (EU) No 1025/2012. If it is adopted, harmonised standards, which include the six DPP standards cited in the Official Journal, would become free to access. The proposal has no DPP-specific provisions.

Working Plan 2025-2030

On 16 April 2025, the Commission adopted the first ESPR Working Plan (COM(2025) 187). It gives an indicative adoption year for each delegated act, not a compliance date. The right-hand column is Norruva's own estimate of when DPP obligations could start, not a figure from the Working Plan.

Each delegated act sets its own date of application, normally at least 18 months after it enters into force, and a delegated act enters into force only after a scrutiny period of at least two months (Art. 4(4)).

Iron and steel, the first product-specific act, is not yet adopted. As of 11 October 2026 the draft act has not yet been published for feedback, and the Commission plans adoption for Q4 2026 (indicative), according to its Have Your Say page. Beyond ecodesign and DPP information requirements, the Commission now says the act will define low-carbon steel, linking it to the low-carbon requirements for steel in the proposed Industrial Accelerator Act.

Textiles and apparel has two different indicative adoption dates from the Commission: Q1 2027 on its Have Your Say page, and Q3 to Q4 2027 on its DPP timeline. No ESPR product group has a dated DPP obligation yet. Obligations apply only once a product group's delegated act is adopted, after a transition period of at least 18 months.

The Working Plan also notes that the plan itself gets a mid-term review in 2028.

Legacy ecodesign product groups. Under Article 79(1)(a)(i) ESPR, parts of the old Ecodesign Directive continue to apply instead of the corresponding ESPR provisions until 31 December 2026 for 19 product groups, among them photovoltaic panels, space and combination heaters, water heaters, vacuum cleaners, computers, and servers and data storage products. In practice, that date ends the old Directive's legal basis for adopting or revising measures for those groups. It is not a compliance deadline for companies: measures already adopted under the Directive keep applying until they are repealed or declared obsolete (Article 79(1)(b)).

Extension agreed, not yet law. A provisional agreement of 26 June 2026 on the digitalisation and common specifications omnibus would move the date to 31 December 2028. The European Parliament's plenary vote is indicatively scheduled for 23 November 2026, and the text still needs adoption by the Council and publication in the Official Journal. Until then, 31 December 2026 is the date in force.

Destruction of unsold goods

• 9 February 2026: The Commission adopted two acts on unsold goods: Delegated Regulation (EU) 2026/296, setting derogations from the destruction ban (Art. 25(5)), and Implementing Regulation (EU) 2026/2, setting the details and format for disclosing discarded unsold products (Art. 24(3))
• 19 July 2026: Destruction ban on unsold textiles/footwear for large companies; the 2026/296 derogations have applied from the same date
• 2 March 2027: The 2026/2 disclosure format applies. Disclosure covers products discarded in each financial year from the first full financial year after that date, and is due within 12 months of the year's end
• 19 July 2030: Ban extends to medium-sized companies (ESPR Article 25)
• Micro and small enterprises are exempt

Key requirements

1. Digital Product Passports — mandatory product-level data carriers
2. Ecodesign requirements — durability, repairability, recyclability
3. Substance of concern disclosure — SVHCs above 0.1% by weight
4. Recycled content minimums — phased in by product category
5. Destruction ban — unsold consumer products cannot be destroyed
6. Green public procurement — mandatory criteria for public buyers

Proposed, not law: the Commission's Public Procurement Act proposal of 9 September 2026, COM(2026) 590, would let public buyers require a product's declaration of conformity through its digital product passport (draft Article 92(1)). If adopted, it would apply two years after entering into force.

Penalties

Member states must set effective, proportionate, dissuasive penalties per Art. 74. 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 of application set in each product-specific delegated act, which as a rule is no earlier than 18 months after the act enters into force (Art. 4(4)).

Key articles

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

Interactions with other regulations

• Battery Regulation: First product-specific DPP under the ESPR umbrella
• PPWR: one data carrier for product and packaging information (PPWR Art. 12(5)); the PPWR recitals say an ESPR DPP should also carry the packaging information
• REACH/SCIP: SVHC data feeds directly into DPP substance fields
• EmpCo: DPP data substantiates green claims
• Right to Repair: repairability data, such as a repairability score, can be required in the DPP by ESPR delegated acts (Art. 7(2)(b)(i))

Source

• Regulation (EU) 2024/1781 — EUR-Lex
• ESPR Implementation — Green Forum
• Working Plan 2025-2030, COM(2025) 187 — EUR-Lex
• Implementing Regulation (EU) 2026/1778 (DPP registry) — EUR-Lex
• Delegated Regulation (EU) 2026/296 (destruction-ban derogations) — EUR-Lex
• Implementing Regulation (EU) 2026/2 (unsold-goods disclosure) — EUR-Lex
• CEN-CENELEC: DPP standards
• CEN-CLC/JTC 24 published standards, including EN 18239:2026 and EN 18246:2026, CEN-CENELEC
• Proposal for a Regulation on European standardisation, COM(2026) 780, EUR-Lex
• Digital Product Passport and indicative DPP timeline, European Commission
• Iron and steel delegated act — Have Your Say
• Textiles and apparel delegated act, Have Your Say
• Provisional agreement on the digitalisation and common specifications omnibus, European Parliament, 26 June 2026
• Procedure 2025/0134(COD), Legislative Observatory, European Parliament
• Public Procurement Act proposal, COM(2026) 590, EUR-Lex