What is the ESPR? The EU Ecodesign Regulation explained

The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 or ESPR, is the EU's framework law for ecodesign requirements: the rules a product must meet before it can be placed on the EU market. It was adopted on 13 June 2024, published in the Official Journal on 28 June 2024, and entered into force on 18 July 2024.¹

Its scope is broad. It applies to any physical goods placed on the market, including components and intermediate products, with a short list of exclusions such as food, feed, medicines, and living plants and animals. Besides ecodesign requirements, it establishes the Digital Product Passport, provides for mandatory green public procurement requirements, and sets up a framework to stop unsold consumer products from being destroyed.¹

The word framework matters. ESPR itself sets almost no requirement for any particular product. It says what kinds of rules the Commission may set and how, and the rules for each product group arrive later, in their own acts.¹

Before ESPR, EU ecodesign rules came from Directive 2009/125/EC, which set a framework for energy-related products: appliances, heaters, lighting, electronics. The regulation's own recitals call that directive generally successful at improving energy efficiency and some circularity aspects, and say the same approach should now reach the widest possible range of products, not only energy-related ones.¹

ESPR repealed the directive with effect from 18 July 2024, with transitional exceptions. For a listed set of energy-related products, among them heaters, vacuum cleaners, computers and servers, parts of the directive continue to apply until 31 December 2026. Implementing measures already adopted under the directive stay in force until they are repealed by acts made under ESPR.¹

ESPR empowers the Commission to set ecodesign requirements by delegated act. Requirements are set for a specific product group, such as textiles or furniture, or, where several groups share a problem, as horizontal requirements across them, such as one rule on repairability for many kinds of product.¹

A delegated act can contain two kinds of requirement. Performance requirements set minimum or maximum levels, such as a minimum share of recycled content or a minimum lifetime. Information requirements say what must be disclosed about the product, and for a product group's act they include, as a minimum, the requirements for its Digital Product Passport.¹

Before adopting an act, the Commission must carry out an impact assessment and consult experts designated by each Member State. Once adopted, the act goes to the European Parliament and the Council, and it enters into force only if neither objects within two months, a period either can extend by two more. The first delegated act could not enter into force before 19 July 2025.¹

Then comes the transition. The date an act applies may not be earlier than 18 months after it enters into force, except in duly justified cases, so that businesses, and small and micro enterprises in particular, have time to comply. An act adopted in a given year therefore does not bind products in that year.¹

ESPR lists 16 product aspects that requirements can improve, where they are relevant to the product group:¹

• How long it lasts and how it holds up: durability, reliability, reusability and upgradability.
• How it is kept in use: repairability, and the possibility of maintenance, refurbishment and remanufacturing.
• What it is made of: the presence of substances of concern, recycled content, and resource use and efficiency.
• What it uses: energy use and efficiency, and water use and efficiency.
• What happens at the end: recyclability, the recovery of materials, and the expected generation of waste.
• Its footprint: environmental impacts, including carbon footprint and environmental footprint.

Requirements must also, where relevant, keep products from becoming obsolete early through design choices, missing repair information or spare parts, or software that stops working. And they come with limits on the Commission: no significant harm to the product's function, no disproportionate burden on smaller businesses, and no proprietary technology imposed on manufacturers.¹

ESPR required the Commission to adopt a first working plan by 19 April 2025, prioritizing a list of product groups the regulation names, among them iron and steel, aluminum, textiles (in particular garments and footwear), furniture and tires. The Commission adopted it on 16 April 2025, as COM(2025) 187. It runs from 2025 to 2030, with a mid-term review in 2028.^1,3

The plan includes four final products, two intermediate products and two horizontal measures, each with an indicative year for adopting its act. Textiles and apparel rank first among the final products, with 2027; tires also 2027; furniture 2028; mattresses 2029. Iron and steel are set for 2026 and aluminum for 2027. The horizontal measures are repairability, including scoring, in 2027, and the recycled content and recyclability of electrical and electronic equipment in 2029.³

These are planning dates for adopting rules, not compliance dates. The Commission's textile passport page gives the planned adoption of the textiles act as the fourth quarter of 2027; with the 18-month transition, that places general application in 2029 at the earliest.^4,1

Some named groups are not in the plan. Footwear is treated as a separate category from textiles; instead of an act, the plan commissions a study of footwear under ESPR, to be completed by the end of 2027. Detergents, paints and lubricants were left out as having lower impacts and lower improvement potential, and chemicals get a scoping study first.³

The passport is how ESPR's information requirements reach the product. Where an act requires one, products in that group may only be placed on the market if a Digital Product Passport is available. Each act decides what data it holds, which data carriers are used and where they sit, whether it is kept per model, per batch or per item, who may read and update it, and how long it stays available, which must be at least the product's expected lifetime.¹

The working plan says every product for which ecodesign measures are adopted will have a passport, unless another digital system already provides the same information, such as the EU's energy-label database. The Commission also had to set up a registry by 19 July 2026 that stores at least each passport's unique identifier, and it has been operational since 20 July 2026. Batteries have their own passport under the Batteries Regulation, (EU) 2023/1542, which ESPR amends so that battery identifiers go into the same registry.^2,3,1

The Digital Product Passport explainer covers what a passport must contain and when it is required. The textile and battery passport explainers cover those two product groups in detail.

One part of ESPR applies without waiting for a product act. Since 19 July 2026, the destruction of unsold consumer products listed in Annex VII has been prohibited. The list covers apparel and clothing accessories, including those of leather, hats, and footwear. Micro and small enterprises are exempt, and medium-sized enterprises are covered from 19 July 2030, so for now the ban falls on large companies, as the Commission's announcement of 17 July 2026 put it.^1,5

Destruction remains allowed in defined cases, which the regulation lets the Commission set out by delegated act: for health, hygiene and safety; for goods damaged beyond cost-effective repair; for goods unfit for their purpose; for goods offered for donation and refused; for goods unsuitable for reuse; for goods that infringe intellectual property, including counterfeits; and where destruction has the least environmental impact. The Commission's announcement lists that delegated regulation alongside an implementing regulation on how companies report.^1,5

Reporting is the other half. Companies that discard unsold consumer products must disclose every year, on an easily accessible page of their website, how many they discarded and their weight, why, what share went to reuse, recycling, other recovery or disposal, and what they are doing to prevent it. Micro and small enterprises are exempt here too, and medium-sized ones are covered from 19 July 2030. Every company is also under a general duty to take reasonable measures to avoid having to destroy unsold goods at all.¹

The list may grow, but not yet. The working plan says the Commission does not intend to add products to the ban in this plan, because the disclosures that would justify a new ban are not yet available.³

ESPR asks for information that travels with a product and stays available for as long as the product is expected to last. Vera provides the item-level identity and lifecycle record a Digital Product Passport is built on: the tag on the product, and a record of every transfer, scan and resale.

The record starts before the sale. Tags can be bound to their products before a box leaves the factory, and each transfer, scan and resale is then written to the same certificate, through every owner after the first. Vera's record is per item, the finest of the three levels an act can choose. Products made of separately tagged parts are recorded as parts, and the brand can export its product, ownership and event data in full. A passport also carries the product-group data each act sets, such as composition and compliance information, and those requirements are written act by act.

• Which of our products fall in a working plan group, and in which year is that group's act expected?
• Are we a large, medium-sized or small company under the unsold-goods rules, and are we publishing the yearly disclosure?
• Where does our unsold stock go today, and can we show where each item went?
• At what level do we record products: per model, per batch or per item?
• Is there a data carrier on the product itself, made to stay for the product's whole life?
• Who holds our product data, and can we take all of it elsewhere?