Through the Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport (DPP), the European Union aims to make a wide range of physical products placed on the European market more sustainable, energy-efficient and circular over the coming years. But what exactly does the ESPR lay down, which obligations already apply and which are still to come?
The ESPR (Regulation (EU) 2024/1781) entered into force on 18 July 2024. It replaces the former Ecodesign Directive, which applied only to energy-related products, and extends the scope to a wide range of physical goods placed on the European market, including components and intermediate products.
A limited number of categories fall outside the regulation: food and feed, medicinal products, living plants and animals, vehicles and products intended exclusively for defence or national security.
Important
Only once the delegated act for your product has been adopted will you know which requirements apply and from when.
Each delegated act lays down two types of requirements:
The requirements may cover a product's entire life cycle. Broadly speaking, they revolve around four themes:
In April 2025, the European Commission adopted the Ecodesign and Energy Labelling Working Plan 2025-2030. It sets the order in which product groups will be addressed:
At the time of publication, the Commission had not yet adopted any product-specific delegated act. Between the publication of such an act and the application of the new requirements, there is usually a generous transition period of at least 18 months. In the meantime, existing ecodesign measures remain in force for energy-related products.
The Digital Product Passport (DPP) is the central instrument of the ESPR. It contains product information that can be accessed through a data carrier on the product or its packaging – usually a QR code.
In principle, the DPP will become mandatory for products covered by a delegated act. The concept is not entirely new: other EU legislation also provides for product passports or similar information requirements. The Batteries Regulation, for example, introduces the Battery Passport, which will become the EU's first mandatory digital product passport in February 2027. Sector-specific rules on product information also exist for construction products, toys and detergents.
A digital product passport typically contains the following information:
The EU declaration of conformity can also be included in the DPP. In this declaration, the manufacturer confirms that its product complies with the applicable EU legislation. The declaration also underpins the CE marking, which continues to apply where the relevant legislation requires it.
The European Commission is also developing a central registry for digital product passports, which will be linked to the customs system. Products without a valid passport will no longer be admitted to the EU market.
As mentioned above, the ban on the destruction of unsold goods follows directly from the ESPR and is already in force. In separate implementing rules, the EU has laid down derogations and the format for disclosure.
The following obligations already apply:
Enforcement is the responsibility of the Member States, which can impose national penalties. Companies operating in several EU countries therefore need to take different penalty regimes into account.
The main effort the ESPR requires lies not in complying with the rules themselves, but in the product data needed to do so. Information on material composition, origin, recycled content and reparability is currently spread across different suppliers. Collecting and structuring it takes time.
On top of that, demand for product data is growing even faster than regulation. Buyers at large retailers and original equipment manufacturers (OEMs) are already asking for product information that may also be relevant to a product passport. And now that the EmpCo Directive imposes stricter requirements on environmental claims, substantiated product information is also becoming a foundation for your sustainability communication and that of your customers.
The good news is that this need not lead to duplicate work. Companies that have already carried out a life cycle assessment (LCA) or had a product carbon footprint (PCF) calculated have already laid much of the groundwork for future performance requirements and for the content of a DPP. And companies that already collect sustainability data in a structured way, for example for the Packaging and Packaging Waste Regulation (PPWR) or the Corporate Sustainability Reporting Directive (CSRD), can integrate that activity into a single, consistent approach.
Pantarein helps companies prepare for the ESPR.
We do this in four steps:
Or are you wondering whether you have already collected the data you need for a future digital product passport? Book a no-obligation conversation with one of our experts at mail@pantarein.be. Together, we will look at where you stand today and which steps make sense now.
