Ecodesign for Sustainable Products Regulation: What Manufacturers Need to Know

What is Ecodesign and why it matters

The Ecodesign for Sustainable Products Regulation (ESPR) is redefining how products are designed and placed on the EU market. In 2024, the Volvo EX90 became the first production vehicle to ship with a battery passport. A QR code on the door frame links to full traceability data for cobalt, nickel, lithium, and graphite. The same year, Fairphone released a smartphone in which every common failure mode can be repaired by the user with a single screwdriver, earning a 10/10 repairability score from iFixit. Both products reflect a shift that is now accelerating across industries.

Ecodesign - once a voluntary sustainability practice - is now becoming a core requirement under evolving EU ecodesign regulations. Together with the Packaging and Packaging Waste Regulation (PPWR), ESPR introduces binding rules on product durability, recyclability, and lifecycle transparency. For manufacturers, compliance with ecodesign requirements is rapidly becoming essential to maintain market access in Europe.

Sources: Circle Economy (2025); European Commission (2022); European Environment Agency (2026)

Three converging drivers of Ecodesign

The business case for ecodesign is driven by three reinforcing forces: cost efficiency, market demand, and evolving ecodesign regulations.

1. Cost efficiency and resource optimisation - Reducing material inputs lowers procurement costs and exposure to commodity volatility. Designing for durability reduces warranty and after-sales expenditure. Italian packaging company Tiber Pack eliminated hot-melt glue from its cartoning process and achieved a 51% reduction in CO₂e emissions alongside 25–30% lower electricity consumption. Michelin’s e.Primacy tyre saves approximately 174 kg of CO₂ per tyre over its service life. In both cases, environmental improvement and cost improvement are the same design decision.

2. Market demand and sustainability expectations - B2B procurement increasingly requires product-level sustainability data. Retailers expect recyclable, low-impact goods. Environmental claims are under growing scrutiny, making independent third-party verification a meaningful differentiator.

3. Regulation and compliance pressure - The EU has concluded that voluntary approaches are insufficient to drive the transition at the required speed and scale. ESPR and PPWR make sustainability performance a condition for placing products on the EU market, not a reporting obligation but a market-access gate
  

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What is the Ecodesign for Sustainable Products Regulation (ESPR)?

Regulation (EU) 2024/1781, in force since July 2024, extends mandatory ecodesign requirements from energy-related products to virtually all physical goods on the EU market. Requirements will be defined through product-specific delegated acts. Article 5 identifies sixteen sustainability parameters, best understood as four design imperatives.

• Design for longevity: durability, reliability, repairability, upgradability, and maintenance. Fairphone’s modular architecture is a reference implementation.
• Design for disassembly and circularity: recyclability, material recovery, recycled content, and remanufacturing. Royal Auping redesigned its mattresses to allow full separation of materials at end of life.
• Design for transparency: environmental footprint, substances of concern, and the Digital Product Passport. Volvo’s battery passport demonstrates product-level traceability at scale.
• Design for resource efficiency: energy, water, and material efficiency. Amazon’s “Ships in Product Packaging” programme eliminated 2.7 million tonnes of packaging material.

The ESPR Working Plan 2025–2030 identifies priority product groups including textiles, tyres, furniture, mattresses, iron, steel, and aluminium. A central element is the Digital Product Passport (DPP), a structured, digitally accessible record of product-level data required for market access.
   

What does Ecodesign mean?

Ecodesign is the practice of designing products, services, and systems to reduce environmental impact across their full life cycle. It considers materials, energy use, manufacturing, packaging, transport, repairability, reuse, recycling, and disposal.

PPWR and ecodesign regulations: what manufacturers must comply with

Regulation (EU) 2025/40, in force since February 2025, applies to all packaging placed on the EU market. Main obligations take effect from August 2026, with 2030 as the key milestone. The regulation introduces recyclability performance grades, binding recycled-content targets, packaging minimisation requirements, PFAS restrictions, reuse targets, and EPR fee modulation.
  

The operational readiness gap in ecodesign compliance

The main challenge is not understanding the regulation, but building data infrastructure, supplier alignment, and internal processes required for compliance at scale. Companies that delay action will face compressed timelines, higher costs, and limited access to expertise. Those building foundations now will navigate the transition most effectively.

Ecodesign requirements: what companies should do next

1. Conduct a structured gap analysis.

2. Integrate ecodesign into product development from early design stages.

3. Strengthen data management and supplier engagement.

4. Establish verification and documentation systems.

5. Build internal capability across product, compliance, and marketing teams.

How TÜV SÜD can support ecodesign compliance

TÜV SÜD works with manufacturers across the full ecodesign cycle, helping them meet evolving Ecodesign for Sustainable Products Regulation (ESPR) and PPWR requirements: identifying regulatory exposure, quantifying product-level environmental impacts, verifying data and claims, and preparing the documentation required for market access. 

Our expertise covers: 

• Life Cycle Assessment: product carbon and water footprint, environmental impact baselining and benchmarking.
• Recyclability and recycled-content verification: recyclability grade assessment to ensure alignment with PPWR and ecodesign requirements.
• Sustainability claim verification: EPDs, green claims substantiation, independent third-party credibility.
• Digital Product Passport (DPP) and data validation: DPP data verification and technical documentation review, ensuring consistency, traceability, and compliance with upcoming EU ecodesign regulations. 
• Gap analysis and advisory: ESPR/PPWR readiness assessment, ecodesign strategy, compliance roadmaps. 
• Training and capacity building: customised programmes for product, sustainability, compliance, and marketing teams.