The EU's Ecodesign Regulation: implications for luxury brands

The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 or ESPR, entered into force on 18 July 2024. It replaces the old Ecodesign Directive, which covered energy-related products, with a framework that can reach almost any physical good sold in the EU.¹

The word framework matters. ESPR sets out the kinds of requirements the Commission may impose, among them durability, reparability, recycled content and recyclability, and information requirements that include a Digital Product Passport. The requirements themselves arrive later, in delegated acts written for one product group at a time. Until a group's act is adopted and applies, the regulation sets that group's direction rather than its deadline.¹

The Commission's working plan for 2025 to 2030 names textiles and apparel among the first product groups, with 2027 as the indicative year for adopting their delegated act. The Commission's own textiles page describes that act as expected, with adoption planned for the fourth quarter of 2027. Both are planning dates, not legal ones.^2,3

Compliance comes later still. Under ESPR, a delegated act may not apply earlier than 18 months after it enters into force, except in duly justified cases. An act adopted at the end of 2027 therefore points to 2029 at the earliest for textile products. What the act will cover, including where accessories and leather goods fall, depends on the scope it defines, and that text does not exist yet.¹

The first product passport with a fixed date comes from a different law. Under the Batteries Regulation, (EU) 2023/1542, a battery passport is mandatory from 18 February 2027 for light means of transport batteries, industrial batteries above 2 kWh and electric vehicle batteries. Few luxury houses make batteries, but it is the first working example of what a passport holds and who may read it.⁴

ESPR also bans the destruction of certain unsold consumer products. For apparel, clothing accessories and footwear, the ban has applied to large companies since 19 July 2026, with medium-sized companies following in 2030. Destruction remains permitted in defined cases, such as unsafe, damaged or counterfeit goods, and companies must disclose what they discard and why.^1,5

For houses that have historically destroyed surplus stock to protect pricing, this changes the arithmetic. Unsold inventory has to go somewhere, and resale, donation and recycling all need a way to follow the item once it leaves the brand's hands.

Read together, these pieces ask for four things luxury has rarely needed to formalise.

• Supply chain transparency. Information requirements will draw on data from suppliers, including small ateliers, collected in a form that can be shared.
• Lifecycle documentation. Luxury goods are already built to last. The regulation's direction is toward showing it, item by item, across years and several owners.
• A route for surplus. With destruction restricted, unsold goods need a recorded path into resale, donation or recycling.
• Data infrastructure. A passport is a data system before it is a label: an identifier on the product, a record behind it, and rules about who sees what.

None of this has to undermine the codes of luxury. Craft, heritage and longevity are exactly what a well-kept product record shows. The real challenges are cost and coordination, particularly for smaller suppliers, and deciding how much of a product's history to share publicly and how much to keep for the brand.

Some houses are moving ahead of the rules. In February 2023, Gucci, with Kering's support, announced a Circular Hub in Tuscany focused on recycled materials, durability, repairability and work with local suppliers. Initiatives like it suggest the industry's own direction and the regulation's are converging.⁶

Vera gives each product a tag on the item itself and a certificate behind it. Every transfer, scan and resale is recorded against that one item, so a brand holds a per-product history from the moment the product is tagged to every later owner. That item-level record is groundwork a Digital Product Passport would be built on.

For what a passport must contain and the dates that apply, our guides to the Digital Product Passport and to textile passports go further.