What is the Ecodesign for Sustainable Products Regulation (ESPR)?
The Ecodesign for Sustainable Products Regulation (ESPR) is a major EU policy within the European Green Deal that repeals the Ecodesign Directive (2009/125/EC) with a transitional regime. While the previous Ecodesign Directive focused on energy-related products, ESPR applies to almost all physical goods sold in the EU, including textiles, furniture, and electronics.
Its goal is to reduce environmental impact across the entire product lifecycle while strengthening the circular economy, from raw material extraction to end-of-life disposal. This ecodesign regulation sets performance and information requirements that make products more durable, repairable, reusable, and recyclable. It also introduces the Digital Product Passport (DPP) to ensure transparency and traceability of product data.
Why is the ESPR important?
- Reduces waste – By promoting durable and repairable products, ESPR helps decrease landfill waste and pollution.
- Encourages sustainable innovation – Manufacturers are incentivised to create environmentally friendly products, driving technological advancements in green materials and design.
- Enhances transparency – Introducing DPPs provides consumers, businesses, and regulators easy access to product sustainability data.
- Improves market competitiveness – Businesses that comply with the ESPR gain a competitive advantage by meeting the growing demand for sustainable products.
- Reduces carbon footprint – By optimising resource use, the ESPR helps lower emissions and aligns with global climate goals.
- Consumer benefits – Consumers benefit from more durable, repairable, and environmentally friendly products.
What is the scope of the ESPR?
In principle, the ESPR applies to nearly any physical goods placed and sold in the EU market. This includes:
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However, some product categories are excluded, including:
- Food and animal feed
- Medicinal products and veterinary medicinal products
- Living plants, animals, and micro-organisms
- Products of human origin, as well as products of plants and animals, directly related to their future reproduction
- Vehicles, which are covered by separate regulations
With a wide range of product categories impacted, the EU will gradually determine priority product groups and implement the ESPR. Details of affected product groups are regulated by delegated acts of the EU Commission.
First working plan
On 16 April 2025, the EU Commission adopted the first working plan for 2025-2030. This latest working plan provides a list of products that should be prioritized to introduce the ecodesign requirements and energy labelling over the next 5 years.
Based on the potential to deliver on the circular economy, the priority products for ecodesign and energy labelling requirements are steel and aluminium, textiles (with a focus on apparel), furniture, tyres, and mattresses.
The first group of product requirements are expected to apply in 2027. For businesses, this means the time to start preparing is now.
Extended scope of economic operators
The ESPR impacts not only manufacturers, importers, and distributors but also authorized representatives, fulfilment service providers, providers of online marketplaces, and online search engines. Ensuring compliance across all economic operators is crucial.
Timeline for ESPR
What are the key aspects of the ESPR?
The ESPR focuses on several key sustainability aspects, including:
1. Ecodesign requirements
As a framework regulation, the requirements will be set through delegated acts and can be horizontal (i.e., for multiple product groups) or specific. According to these ecodesign requirements, products must meet strict sustainability criteria, including:
According to the 2025-2030 working plan, the Commission will introduce horizontal measures on repairability for products such as consumer electronics and small household appliances. This will include the introduction of a repairability score for products with the most potential, and requirements on the recyclability of electrical and electronic equipment.
Products must undergo conformity assessment procedures, and manufacturers must provide an EU declaration of conformity. EU member-states are responsible for market surveillance and enforcement, with corresponding penalties for non-compliance. However, existing ecodesign measures for energy-related products will remain in force until replaced by new rules.
2. Digital Product Passport (DPP)
The ESPR also introduces the Digital Product Passport (DPP), a digital record that stores key product information for consumers, regulators, and recyclers, improving transparency and circularity. This may include sustainability and compliance data such as:
- Material composition
- Carbon footprint
- Repair and recycling instructions
3. Provision on the destruction of unsold goods
To reduce the generation of waste and to disincentivise overproduction, the ESPR includes provisions to prevent the destruction of unsold goods. Starting in the first financial year after the regulation enters into force, companies must disclose what happens to unsold items and their sustainable alternatives on their websites.
Additionally, a ban on destroying unsold textiles and footwear will apply from July 19, 2026. The Commission can expand the product scope of the ban in the future.
4. Penalties for non-compliance
EU member-states will enforce the ESPR and determine penalties for non-compliance, including heavy fines and exclusion from public contracts. Businesses must take proactive steps to avoid these risks as early as possible.How can businesses prepare for the ESPR?
Here’s how manufacturers and retailers can get ready for the ESPR:
1. Assess your products.
Review your current products and conduct a product lifecycle assessment (LCA) to identify areas for improvement in durability, repairability, and recyclability. Look at product materials, energy efficiency, and waste generation. Use sustainability assessment tools and work with third-party auditors to get a clearer picture of your products.
2. Gather and organise product data.
To start preparing for the Digital Product Passport (DPP), document your supply chain information, including materials, production methods, and energy consumption. You can also work with suppliers and technology providers to help you gather and organise data, helping ensure products are ready for the DPP.
3. Redesign products for sustainability.
Invest in eco-friendly materials, modular designs, and recyclable packaging. Consider using bio-based or recycled content and designing products with easier disassembly and repair options.
4. Collaborate with industry experts.
Work with certification bodies, such as TÜV SÜD, for guidance on compliance, claim verification, and market readiness. Conduct regular third-party audits to ensure continuous compliance with ESPR requirements.
How can TÜV SÜD help businesses comply with the ESPR?
Since it’s a new regulation, the ESPR can be challenging to navigate. Manufacturers are encouraged to collaborate with TÜV SÜD early in the product development process to strategically plan the necessary steps and begin evaluating their products ahead of time. Proactive preparation and early action are critical to staying ahead of compliance requirements.
Our team of experts can support you in:
- Assessing if your product is within the scope of the ESPR
- Understanding the key requirements, scope, and timeline
- Staying updated on the present status of standardisation
- Explaining what your company needs to do to be ready
Contact TÜV SÜD today to learn how we can help your business navigate ESPR’s technical standards and deadlines. By partnering with TÜV SÜD, manufacturers can streamline and pre-assess their ESPR compliance process, avoid regulatory pitfalls, and enhance their market competitiveness with sustainable, compliant products.
