What is the Ecodesign for Sustainable Products Regulation (ESPR)?
The Ecodesign for Sustainable Products Regulation (ESPR) is a flagship regulation introduced by the European Union to improve the environmental sustainability, circularity, and transparency of products placed on the EU market. It replaces and expands the Ecodesign Directive, introducing mandatory environmental performance requirements and data transparency obligations across a wide range of product categories.
The regulation exists to address the environmental sustainability of products, by focussing on design parameters including resource efficiency and waste reduction. It sets minimum standards for how products are designed, including requirements for durability, reparability, energy efficiency, and recycled content, alongside the introduction of Digital Product Passports (DPPs) to improve visibility of product performance for stakeholders across the value-chain.
Who does ESPR apply to?
ESPR will eventually apply to almost all physical products placed on the EU market, with limited exemptions (e.g. food, medicines, certain vehicles).
Organisations impacted include:
- Manufacturers (primary responsibility for provision and maintenance of the necessary data covering products)
- Importers and distributors
- Retailers and online marketplaces
- Online platforms and search engines
While there are no universal turnover or employee thresholds for scope, specific obligations (e.g. unsold goods destruction bans) apply differently depending on company size (e.g. large and medium companies first).
Priority sectors in the first working plan (2025–2030) include:
- Iron & steel
- Textiles & apparel
- Tyres
- Aluminium
- Furniture
- Mattresses
- 16 Energy-related products including mobile phones and tablets
Organisations placing products on the market in the EU, from the above product categories, will have 18 months from the date the regulation comes into force to comply. With the first product group – iron & steel – expecting clarity around requirements this year, the time to begin the data collection process is now.
What are the key requirements?
ESPR introduces a combination of performance, transparency, and compliance obligations, defined at product-group level through delegated acts.
Core requirements include:
Environmental performance standards (ecodesign requirements)
- Minimum and maximum thresholds (e.g. minimum recycled content, maximum carbon footprint)
- Requirements for durability, reparability, and energy efficiency
Digital Product Passports (DPPs)
- Structured product data accessible via QR code or a similar mechanism
- Includes material composition, environmental performance, and lifecycle data
- Conformity assessments to certify compliance of product against ESPR requirements
Disclosure and transparency obligations
- Reporting on sustainability characteristics
- Disclosure of unsold stock
Bans and restrictions
- Prohibition on destruction of unsold goods (e.g. textiles, footwear for large companies)
Compliance and documentation
- Conformity assessments and technical documentation
- Evidence of compliance for regulators and market actors
What are the timelines and deadlines?
ESPR implementation is phased by product group, with compliance timelines triggered by delegated acts.
Key milestones:
2026
- EU Central DPP Registry went live for organisation enrolment only, supported by Commission Implementing Regulation (EU) 2026/1778, as of 16 July 2026
- Ban on destruction of unsold goods begins for large companies
2026 – 2027
- Iron & steel requirements expected
- Start of 18-month compliance windows following delegated acts
2027
- Textiles and apparel
- Tyres
- Aluminium
- DPP requirements for batteries
2028 – 2029
- Furniture (2028)
- Mattresses (2029)
Important: Businesses typically have 18 months from the entry into force of a Delegated Act to comply, making early preparation critical.
What are the risks of non-compliance?
Failure to comply with ESPR creates significant financial, legal, and commercial risks. Companies may face administrative fines, product recalls, and increased compliance costs, particularly where products do not meet ecodesign performance requirements.
Non-compliance can also trigger regulatory enforcement actions, including restrictions or bans on placing products on the EU market – resulting in lost revenue and supply chain disruption.
Beyond enforcement, organisations risk reputational damage if they fail to meet transparency expectations, including Digital Product Passport requirements, potentially undermining trust with customers, investors, and regulators.
Ultimately, non-compliance may lead to loss of EU market access and long-term competitive disadvantage in a market increasingly shaped by sustainability performance.
What are the business opportunities?
ESPR presents a significant opportunity for businesses to unlock efficiency, cost savings, and competitive advantage.
By aligning with ecodesign principles, organisations can:
- Improve resource efficiency and reduce material costs
- Identify supply-chain and in-house process emissions or wastage hotspots
- Optimise product lifecycles and reduce waste
- Lower operational costs and future compliance risks
In addition:
- Strong ESPR alignment enhances brand reputation and sustainability leadership
- DPPs could become a significant opportunity for companies and brands to engage with their customer base and improve engagement
- Increased transparency builds customer trust and differentiation
- Demonstrated ESG performance improves access to capital and investor confidence
How should organisations prepare?
Organisations should take a structured, proactive approach to ESPR readiness:
1. Assess
- Conduct portfolio-level data preparedness risk assessments
- Identify data gaps and begin the process of capturing any new system/data requirements
2. Plan
- Prioritise high-risk products and sectors
- Develop a preparation roadmap aligned to delegated acts and their timelines
- Prepare design teams for re-design should products fail to meet ecodesign requirements
3. Implement
- Embed ecodesign principles into R&D and product development
- Build Digital Product Passport data systems and processes
- Engage suppliers to improve data quality and traceability
4. Disclose and optimise
- Prepare compliance documentation and reporting
- Continuously improve product performance and transparency
