# Ecodesign for Sustainable Products (ESPR): what brands should prepare
Regulation (EU) 2024/1781 on ecodesign for sustainable products, in force since 18 July 2024, will set durability, reparability, recycled content and carbon footprint requirements for almost all products sold in the EU. Product rules arrive through delegated acts. Brands should map their portfolio against the 2025-2030 working plan, collect supplier data, design for repair, and prepare for digital product passports.
Key facts
- Regulation (EU) 2024/1781 is a framework regulation: it sets the machinery for ecodesign rules, while the detailed product requirements arrive later in delegated acts for each product group.
- It covers almost all physical goods placed on the EU market, a major expansion from the old Ecodesign Directive, which covered only energy-related products.
- The Commission's first working plan, covering 2025-2030 and adopted in spring 2025, names the first product groups: textiles (with a focus on apparel), furniture, iron and steel, aluminium, tyres, mattresses, detergents, paints, lubricants and chemicals.
- Most product groups will need digital product passports (DPPs) carrying a defined data set; the battery passport required from 18 February 2027 under the Batteries Regulation is the working template.
- A ban on destroying unsold consumer products starts with apparel, clothing accessories and footwear: it applies from July 2026 for large enterprises, with medium-sized enterprises following from 2030, alongside transparency duties on unsold stock.
- Enforcement will sit with market surveillance authorities, who will check ecodesign documentation and product requirements like any other product rules.
1. What the ESPR is, and why it changes the scope of product regulation
The ESPR repeals and replaces Directive 2009/125/EC, the Ecodesign Directive, which applied only to energy-related products such as washing machines and televisions. The new regulation extends the ecodesign approach to almost all physical products placed on the Union market, whether manufactured in the EU or imported. Its legal base is the internal market, and its stated aim is to make sustainable products the norm by setting requirements on durability, reusability, reparability, substances of concern, energy and resource efficiency, recycled content, remanufacturing and recycling, carbon and environmental footprints.
For brands, the practical consequence is that product lines which never had to think about ecodesign, from clothing to furniture to detergents, will over the coming years face binding product requirements. The requirements do not come from the regulation itself. The regulation creates the framework: performance and information requirements for each product group are set in delegated acts adopted by the Commission, following consultation through the Ecodesign Forum and scrutiny by Parliament and Council. That makes the working plans the single most important document to watch: they tell you which product groups are addressed first and in what sequence.
The regulation also interacts with existing law rather than replacing it. Sector rules such as the Batteries Regulation, the Construction Products Regulation and the Toy Safety Regulation keep their own requirements, and ecodesign acts are designed to complement REACH substance restrictions and the EU energy label framework. Where a product is already covered by product-specific sustainability rules, the delegated act should avoid duplication, but brands should expect overlapping documentation duties and plan their data systems once, for all regimes.
2. The working plan: which product groups come first
The first ESPR working plan, covering 2025-2030, identifies the product groups the Commission will address first, chosen for their potential to deliver circular-economy gains. The named groups include textiles with a focus on apparel, furniture, iron and steel, aluminium, tyres, mattresses, detergents, paints, lubricants and chemicals. Energy-related products already regulated under the old directive are also being reviewed and carried over.
Each delegated act will set out the performance requirements (for example minimum durability or recycled content) and the information requirements (for example the data to appear in the digital product passport) for its group. The acts are adopted sequentially over several years, which means compliance deadlines arrive in waves rather than on a single date. A brand with products in several groups needs a portfolio map showing, for each product line, the likely delegated act, its expected adoption window, and the date its requirements would start to apply.
Because the sequence is public, preparation can start well before any single act is adopted. The data that almost every delegated act will need, materials composition, recycled content shares, carbon footprint data, repairability characteristics, is largely the same across groups. Brands that begin collecting it now will face each new act as a formatting exercise rather than a scramble for supplier data.
3. Digital product passports: the data backbone of the ESPR
The digital product passport is the regulation's central information tool. Each delegated act will require the passport for its product group, and the passport will carry the product's sustainability data: materials and substances, repairability information, recycled content, carbon footprint figures and the declaration of conformity data. It must be accessible via a data carrier (such as a QR code) on the product, its packaging or accompanying documentation, with access rights differentiated for consumers, repairers, recyclers and authorities.
The Commission is building a central registry of passport identifiers, expected to be operational around 2026, which will let authorities verify passports and check compliance at scale. For brands, the passport is above all a data supply-chain project: the information must flow from raw-material suppliers through manufacturers to the party that issues the passport, and it must be kept accurate over the product's life.
The most concrete template available today is the battery passport under the Batteries Regulation (EU) 2023/1542, required from 18 February 2027 for electric-vehicle batteries, light-means-of-transport batteries and industrial batteries above 2 kWh. Brands outside the battery sector can study its data model, access rules and identifier structure as the closest available preview of what their own product group's passport will demand.
4. Destruction of unsold goods: the ban and the transparency duty
The ESPR introduces two related duties for unsold consumer products. First, economic operators will have transparency obligations: they must disclose information on unsold consumer products they discard, including the number and weight of items and the reasons for discarding them. Second, the regulation empowers the Commission to ban the destruction of unsold consumer products in defined product categories.
The first category-specific ban has been set: the destruction of unsold apparel, clothing accessories and footwear is banned, applying from July 2026 for large enterprises, with medium-sized enterprises to follow from 2030. A delegated act adopted in early 2026 set out derogations, such as health and safety exceptions, from that ban. Further product categories can be added by delegated act.
For brands, this turns inventory management into a compliance topic. Clearance channels, donation programmes, take-back and remanufacturing routes, and the documentation proving that discarded stock was not destroyed, all need to be in place before the ban bites. The transparency data also creates reputational exposure: published destruction figures will be visible to journalists, NGOs and competitors.
5. Substances of concern and the wider information duties
Ecodesign requirements can restrict substances of concern where they hinder reuse and recycling, and they can require information on the presence of such substances in the product and its passport. This runs alongside, not instead of, REACH and the sector-specific chemical rules: a substance restricted under REACH stays restricted, while the ecodesign act may add product-level tracking and disclosure duties.
Information requirements are a distinct compliance layer. Beyond the passport, delegated acts can require specific markings, consumer information at the point of sale, and data for professional users such as repairers and recyclers. Green public procurement criteria are another lever: contracting authorities will be steered toward the most sustainable products, which makes strong ecodesign performance a commercial advantage in public tenders.
The practical upshot is that product data must be granular and auditable. A bill of materials that was good enough for a safety file may not be good enough for a passport: it needs substance-level detail, supplier attestations, and a version-control system that survives product changes.
6. What brands should do now: a preparation programme
Preparation divides into four workstreams. First, portfolio mapping: list every product placed on the EU market, assign each to the working-plan product groups, and rank them by the likely timing of their delegated act. Textiles, furniture, steel, aluminium, tyres and the other first-wave groups come first; everything else follows.
Second, data collection: start building the supply-chain data the delegated acts will need. That means material composition data from suppliers, recycled-content evidence, carbon footprint data where available, and repairability characteristics such as spare-part availability and disassembly steps. Supplier contracts should be updated to require this data as a deliverable, because the brand remains responsible for the passport's accuracy.
Third, design: build durability, reparability and disassembly into new product development now, since products designed today will still be on the market when their delegated act applies. Repairability scoring methods developed for other regimes, such as the smartphone repairability class, are a useful internal benchmark.
Fourth, governance: assign ownership of the ESPR programme, set up a delegated-act watch process, and prepare the digital infrastructure for passports, including the data carrier, the hosting of passport data, and access control for different user groups.
7. Enforcement and how it differs from a directive
Because the ESPR is a regulation, it applies directly in all member states without national transposition: the same text binds a brand in every market. Enforcement sits with national market surveillance authorities, who will check ecodesign requirements and passports under the framework of Regulation (EU) 2019/1020 on market surveillance, using document requests, product testing, and, where needed, withdrawal and recall orders. Penalties are set at national level and must be effective, proportionate and dissuasive.
The direct-applicability point matters for planning: unlike a directive, there is no national variation in the core duties, though enforcement practice and penalty levels will differ by member state. Treat ecodesign technical files with the same seriousness as safety files, because authorities will.
| Element | Old Ecodesign Directive (2009/125/EC) | ESPR (Regulation (EU) 2024/1781) |
|---|---|---|
| Scope | Energy-related products only | Almost all physical goods |
| Legal instrument | Directive, transposed nationally | Regulation, directly applicable |
| Product rules | Implementing measures per product | Delegated acts per product group |
| Information tool | Energy label, product fiche | Digital product passport plus labelling |
| Unsold goods | No duties | Transparency duties and destruction bans |
| First priority groups | Energy-using products | Textiles, furniture, steel, aluminium, tyres, mattresses, detergents, paints, lubricants, chemicals |
How the EU compares with other markets
The EU is building a product-level sustainability regime with binding performance and information duties per product group. The United States has no equivalent federal ecodesign framework; product sustainability rules are sectoral or state-led, and the CPSC's remit is safety rather than environmental performance. The United Kingdom has its own ecodesign and energy labelling rules for energy-related products but no ESPR equivalent; UK rules remain narrower. The Australian framework focuses on product safety and energy efficiency labelling without a general ecodesign regulation. Data collected for ESPR passports can often be reused in other markets' disclosures, but the passport obligation itself is EU-specific.
Which products does the ESPR cover?
Almost all physical products placed on the EU market, with limited exclusions such as food, feed and medicinal products. The detailed requirements for each product group arrive through delegated acts.
When will the first product-specific requirements apply?
The regulation is in force since 18 July 2024, but binding product requirements depend on delegated acts. The 2025-2030 working plan sets the sequence; the first delegated acts are expected to be adopted from 2026, with application dates set in each act.
Does the ESPR apply to importers or only EU manufacturers?
It applies to any economic operator placing products on the Union market, including importers and distributors. Non-EU manufacturers need EU-based operators who can present the required documentation and passport data.
What is the difference between the ESPR and the Batteries Regulation?
The Batteries Regulation (EU) 2023/1542 already sets product-specific sustainability rules for batteries, including the battery passport from 18 February 2027. The ESPR is the horizontal framework that will bring similar tools to other product groups.
How should a brand start preparing with limited resources?
Map the portfolio against the working plan, prioritise first-wave product groups, and start collecting supplier data on materials and recycled content. Those two steps deliver most of the value before any delegated act is adopted.
What happens if a delegated act is delayed?
The framework duties, such as the unsold-goods transparency rules, apply on the regulation's own timetable. Product-specific performance requirements only bite once the delegated act for that group applies, but waiting for adoption before collecting data compresses the preparation window.
Official sources
- Regulation (EU) 2024/1781 on EUR-Lex (ESPR)
- European Commission: Ecodesign for Sustainable Products Regulation
- Regulation (EU) 2023/1542 on EUR-Lex (Batteries Regulation)
- Regulation (EU) 2019/1020 on EUR-Lex (Market Surveillance)
Last verified: 2026-09-29. Product-specific requirements depend on delegated acts still being adopted; confirm the current working plan and act status on the Commission's pages before committing to design decisions.