ESPR Regulation: Ecodesign Requirements for Sustainable Products
Key point: The ESPR is the EU's framework for setting mandatory sustainability requirements on virtually any product sold in Europe. It replaces the old Ecodesign Directive and introduces Digital Product Passports, minimum recycled content, repairability standards, and carbon footprint limits. First delegated acts are being drafted now, with compliance expected from 2028-2030.
If the old Ecodesign Directive was a targeted rifle (covering only energy-related products like washing machines and lightbulbs), the ESPR is a net. It catches virtually every physical product sold in the EU and gives the Commission power to set sustainability requirements for each category through delegated acts.
This is not theoretical regulation — the Commission has already begun drafting the first delegated acts, and businesses need to understand what is coming.
From Ecodesign Directive to ESPR: what changed
| Aspect | Old Ecodesign Directive (2009) | New ESPR (2024) |
|---|---|---|
| Product scope | Energy-related products only | Almost all physical products |
| Requirements type | Energy efficiency only | Durability, repairability, recyclability, carbon footprint, recycled content |
| Digital Product Passport | Not included | Mandatory for regulated products |
| Destruction ban | Not included | Ban on destroying unsold goods (textiles, footwear first) |
| Substances of concern | Limited (RoHS separate) | Integrated substance restrictions |
Priority product categories
The Commission has identified priority categories for the first wave of delegated acts. Based on the ESPR working plan published in 2024:
- Textiles and footwear — durability, fibre composition transparency, microplastic shedding limits, recycled content minimums, DPP requirements
- Iron and steel — recycled content, carbon footprint declaration, Environmental Product Declaration
- Aluminium — similar to iron/steel, with recycled content thresholds
- Furniture — durability testing, repairability, disassembly instructions
- Tyres — abrasion rate limits, retreading requirements
- Detergents and cosmetics — refill requirements, biodegradability thresholds
- ICT equipment — repairability, battery replaceability, software update guarantees
Key ESPR requirements explained
Durability and repairability
Products must meet minimum durability standards (e.g., number of wash cycles for textiles, battery cycle life for electronics). Manufacturers must provide spare parts for a defined period and make repair information available to independent repairers.
Recycled content
Delegated acts will set minimum percentages of recycled content for specific materials. For example, the Battery Regulation already requires 16% recycled cobalt, 6% recycled lithium, and 6% recycled nickel in new batteries from 2031.
Carbon footprint
Products will need to declare their carbon footprint using standardised Product Environmental Footprint (PEF) methodology. Some categories may have maximum carbon footprint thresholds.
Substances of concern
Products must track and disclose substances of concern above defined thresholds. This enables recyclers to handle materials safely and supports circular economy goals.
Destruction ban
The ESPR prohibits the destruction of unsold consumer products, starting with textiles and footwear. Companies must disclose the volume of unsold products and how they are handled. SMEs are exempt during an initial transition period.
Implementation timeline
| Date | Milestone |
|---|---|
| July 2024 | ESPR enters into force |
| 2025-2026 | First delegated acts published (textiles, iron/steel expected first) |
| 2027 | Battery DPP requirements apply (under Battery Regulation) |
| 2027-2028 | Destruction ban for textiles and footwear takes effect |
| 2028-2030 | First ESPR delegated acts enter application (18-24 months after publication) |
| 2030+ | Expanded product categories added through additional delegated acts |
How to prepare for ESPR compliance
- Monitor delegated acts — follow the European Commission's ESPR working plan and stakeholder consultations for your product category
- Start collecting product data — materials composition, supplier information, lifecycle carbon footprint data. This is the foundation for both DPP and performance requirements
- Assess repairability — review your product design for repairability. Can components be replaced? Are spare parts available? Is disassembly non-destructive?
- Map recycled content — quantify how much recycled material your products currently contain. Identify where you can increase it
- Prepare for the DPP — the DPP is mandatory for all ESPR-regulated products. Start building the data infrastructure now
Impact on non-EU companies
The ESPR applies to all products placed on the EU market, regardless of where they are manufactured. If you export to Europe, you must comply. Importers and authorised representatives in the EU bear responsibility for ensuring compliance.
This mirrors the approach of REACH, RoHS, and the Battery Regulation — the EU is effectively setting global product standards through market access requirements.
Frequently asked questions
What is the ESPR regulation?
The Ecodesign for Sustainable Products Regulation enables the EU to set mandatory sustainability requirements for virtually any physical product, including durability, repairability, recyclability, recycled content, carbon footprint, and Digital Product Passport requirements.
Which products does ESPR cover?
Almost all physical products on the EU market, excluding food, feed, and medicines. Priority categories: textiles, furniture, electronics, tyres, iron/steel, aluminium, detergents.
When does ESPR take effect?
The framework entered into force July 2024. Product-specific requirements come via delegated acts expected 2025-2026, with compliance deadlines 18-24 months later (2028-2030).