Our Senior Consultant Will Proud shares an overview of the ESPR, how affected businesses can best prepare, and the benefits of doing so.
The Ecodesign for Sustainable Products Regulation (ESPR) establishes a framework for the improvement of aspects such as recyclability, repairability, and energy performance for products placed on the EU market.
This marks a significant step in the EU’s Circular Economy Action Plan, part of the wider European Green Deal. But what does ESPR really mean in practice for businesses? Where are the opportunities for businesses? With the uncertainty over EU sustainability regulation seen in 2025, how and when should businesses start preparing?
How ESPR will affect you
The ESPR is a framework that aims to harmonise product sustainability requirements at the EU level. It expands the scope of the 2009 Ecodesign Directive to include virtually all physical goods sold on the European market, with some exceptions including food, feed, and medicinal products.
The main ESPR regulation entered into force in July 2024 and will gradually cover more product groups as part of working plans. In April 2025, the European Union confirmed which product groups will be covered by individual delegated acts within the first working plan (2025-2030). If you manufacture and place a product on the European market in the categories listed subsequently, you will likely be required to comply with ESPR’s requirements. The initial product groups in-scope of ESPR, are textiles and apparel (2027), furniture (2028), tyres (2027), and mattresses (2029), alongside iron and steel (2026) and aluminium (2027). A mid-term review is expected in 2028.
How products are affected
ESPR intends to meet its overall objectives by improving ‘product aspects’, such as durability or environmental footprint. To measure improvement, ‘product parameters’ will be defined alongside ‘ecodesign requirements’.
The product parameter will need to reach a certain threshold to be compliant with ESPR, with that threshold being the ecodesign requirement. For example, if you take durability, the product parameter may be the product’s guaranteed or technical lifetime, and the ecodesign requirement could be ten years.
To understand a product’s performance against a given ecodesign requirement, a methodology will be defined in the regulation. For instance, if environmental footprint is a selected product aspect, then a Life Cycle Assessment (LCAs) adhering to the Product Environmental Footprint methodology could be an example. Our experts have a significant track record of supporting our clients with these LCAs or other assessments that may be required under ESPR.
The ESPR also introduces the need for Digital Product Passports (DPP), green public procurement rules to encourage supply and demand for environmentally sustainable products, and rules on the destruction of unsold products. These requirements make it even more commercially attractive to develop circular businesses.
DPPs are digital ID for products that can store information on sustainability performance metrics like repairability. In January 2026, a delegated act on DPPs for textile and furniture is expected to be published, coming into force in July the following year.
Meanwhile, green public procurement rules, introduced through implementing acts by the European Commission, will impact contracting authorities awarding public contracts that acquire goods, services, or works from private companies.
Finally, companies will also have to publicly share information on the amount of products they discard, why they are discarded and what happens once discarded. The textiles industry will also be the first to be affected from July 2026, when the destruction of certain articles of clothing, accessories and footwear will be prohibited for large organisations and medium-sized organisations from July 2030. The list of products prohibited from destruction will subsequently be updated every three years.
A strategic opportunity for business
There is a significant breadth of information that could be required under ESPR and certainty is just around the corner. As part of the first working plan, the European Commission is now determining the ecodesign requirements for each product category, including what information all members of the value chain of a company operating in the EU will need to declare. If a product fails to comply in future, risks could include costly recalls and informing the market surveillance authorities.
Businesses affected by the ESPR will likely have to communicate a significant amount of product data to comply. This means comprehensively assessing the materials and components of products and their supply chains. A good place to start is conducting an ESPR readiness assessment, identifying which of your products are in scope and what data on product parameters will be required.
The good news is this analysis is also an opportunity to rethink products from the ground up and pinpoint operational inefficiencies. By considering how to minimise waste and incorporate circularity into product life cycles, businesses will simultaneously identify ways to reduce costs through materials efficiency.
Having this data readily available and accessible to the public will also present opportunities to connect with environmentally conscious consumers. According to a recent survey by pwc, consumers are willing to spend an average of 9.7% more on sustainably produced or sourced goods [1].
Additionally, more granular supply chain transparency will offer greater resilience by highlighting risks like material price spikes or shortages. In the longer term, by incorporating sustainability into the core of the design process, sustainability may become ingrained in companies’ operations, seeing it become a capability rather than a siloed function.
While timelines are uncertain on when the first delegated acts will be passed, they are coming and suggest a clear direction of travel towards a new regulatory environment in which businesses must evidence environmental claims and provide much greater transparency across the product lifecycle. The ESPR offers a pathway to credible, verifiable sustainability communications, underpinned by robust data and common standards.
[1] pwc (2024) Consumers willing to pay 9.7% sustainability premium, even as cost-of-living and inflationary concerns weigh: PwC 2024 Voice of the Consumer Survey. Available at: https://www.pwc.com/gx/en/news-room/press-releases/2024/pwc-2024-voice-of-consumer-survey.html
