Ecodesign for Sustainable Products Regulation (ESPR)

Technical documentation under ESPR is tied to the applicable product requirements and conformity procedure. The file must support verification that the product satisfies the ecodesign requirements established by the relevant delegated act.

Depending on that act, the documentation can include product identification, design and manufacturing information, the applicable requirements, harmonised standards or common specifications used, technical solutions, calculations, measurements, assessments, test reports and information required under the applicable information obligations.

Where an EU Declaration of Conformity is required under the ESPR framework, Article 44 and Annex V govern its structure. The declaration must identify the applicable ESPR delegated act and be supported by the technical documentation.

The specific documentation content and any deviations from the general retention framework must always be checked against the applicable product measure.

ESPR implementation is progressive rather than based on one universal product deadline. Key framework milestones include:

18 July 2024 — Regulation (EU) 2024/1781 entered into force.

16 April 2025 — the Commission adopted the first ESPR and Energy Labelling Working Plan for 2025–2030.

19 July 2026 — the Article 25 prohibition on destroying the defined unsold apparel and footwear applies to the economic operators covered by that rule.

20 July 2026 — the EU Digital Product Passport Registry became operational following the Registry implementation framework established under ESPR.

Product-specific ecodesign and DPP obligations follow the relevant delegated acts and their transition periods. Under Article 4, application is normally no earlier than 18 months after the delegated act enters into force, except in the justified cases provided by the Regulation.

For this reason, ESPR readiness must be mapped by product group and legal measure rather than by using a single ESPR compliance date.

ESPR has a broad potential product scope, but Article 1 contains specific exclusions. The framework can cover final products, components and intermediate products.

It does not apply, among other exclusions, to food, feed, medicinal products, veterinary medicinal products, living plants, animals and microorganisms, products of human origin and certain products directly related to reproduction. Certain vehicle aspects are also excluded where those aspects are regulated under the relevant sector-specific Union vehicle legislation.

Even where a product falls within the general scope of ESPR, concrete ecodesign obligations normally depend on whether an applicable delegated act or horizontal measure covers that product.

ESPR is a framework regulation, not one uniform product specification.

Under Article 4, the European Commission can adopt delegated acts establishing ecodesign requirements for specified product groups. Those acts define the products covered, the requirements that apply, assessment methods, conformity arrangements, information requirements and the relevant transition period.

Article 4 generally requires economic operators to receive sufficient implementation time. The application date of a delegated act must normally be at least 18 months after its entry into force, except in the justified cases provided by the Regulation.

Compliance must therefore be assessed against the applicable product-specific or horizontal measure rather than against a generic ESPR checklist alone.

Article 5 identifies the product aspects that future ecodesign requirements may address where relevant to a product group. These include, among others: durability; reliability; reusability; upgradability; repairability; maintenance and refurbishment; substances of concern; energy and water efficiency; resource efficiency; recycled content; remanufacturing; recyclability and material recovery; carbon and environmental footprint; and expected waste generation.

A delegated act can establish performance requirements, information requirements or both. The actual requirements, measurement methods and thresholds are determined for the product group concerned.

The Article 5 list must therefore not be presented as if every listed requirement already applies to every ESPR product.

ESPR distinguishes performance requirements from information requirements.

Performance requirements can establish quantitative or qualitative product-performance conditions relating to relevant sustainability parameters.

Information requirements can require sustainability or product information to be made available in the form specified for the relevant product group. Where required by the applicable framework, this information can be provided through the Digital Product Passport.

The two categories can apply together or separately depending on the delegated act.

The first Ecodesign for Sustainable Products and Energy Labelling Working Plan for 2025–2030 was adopted by the European Commission on 16 April 2025.

Its new ESPR priorities include textiles and apparel, furniture, tyres, mattresses, iron and steel, and aluminium.

The Working Plan also identifies horizontal work on repairability, including repairability scoring, and on recycled-content requirements for electrical and electronic equipment.

Work on several energy-related product groups is also carried forward from the previous ecodesign framework.

A Working Plan priority is not itself a binding product requirement. The relevant preparatory work, delegated act and transition period must be completed before the corresponding product-specific obligations apply.

Electrical and electronic equipment can be relevant to ESPR in several ways. Specific EEE or energy-related product groups can become subject to ecodesign requirements through applicable product measures, and the 2025–2030 Working Plan also includes horizontal work concerning recycled content of electrical and electronic equipment.

This ESPR product-compliance layer is separate from WEEE extended producer responsibility. WEEE registration, take-back, collection, treatment and reporting obligations are not replaced by an ESPR delegated act or Digital Product Passport.

Batteries must be distinguished from the general ESPR product-specific implementation route. Battery sustainability, conformity, labelling and Battery Passport requirements are established principally by Regulation (EU) 2023/1542 on batteries and waste batteries.

The Battery Passport required from 18 February 2027 for the battery categories defined in Article 77 of that Regulation is therefore not dependent on the adoption of an ESPR product-specific delegated act.

ESPR nevertheless provides important shared Digital Product Passport infrastructure. Regulation (EU) 2024/1781 links Battery Passport unique identifiers to the ESPR DPP Registry and requires interoperability between the relevant digital-passport systems.

Packaging compliance under Regulation (EU) 2025/40 (PPWR) must also be distinguished from product-specific ESPR implementation. PPWR establishes its own packaging sustainability, conformity, documentation, labelling and EPR framework.

A product supplied in packaging can therefore have ESPR obligations for the product, PPWR obligations for the packaging and national EPR obligations for one or both compliance streams.

These legal layers should be mapped separately even where they use overlapping material or product data.

The Digital Product Passport is a core part of the ESPR architecture, but ESPR does not impose one identical DPP data set on every physical product simply by entering into force.

Article 9 links the DPP requirement to the applicable delegated acts adopted under Article 4. Those product measures determine the relevant product scope and information requirements, while Articles 9 to 15 establish the common DPP architecture.

The DPP can contain product identification, sustainability information, compliance documentation and other information required for the relevant product group.

The detailed DPP requirements are covered on the dedicated Digital Product Passport page.

ESPR also establishes the EU Digital Product Passport Registry under Article 13. The Registry became operational on 20 July 2026. Commission Implementing Regulation (EU) 2026/1778 sets out the implementation arrangements for the Registry.

The Registry stores required identifiers and registration data; the broader DPP architecture remains decentralised, with product data remaining under the responsibility of the relevant economic operators and, where used, authorised DPP service providers.

The existence of the operational Registry does not by itself mean that every product already requires a DPP. The substantive product obligation still depends on the applicable Union legal measure.

For products covered by an ESPR delegated act, conformity must be demonstrated using the procedure specified for that product or requirement. The applicable delegated act determines the conformity-assessment module and relevant technical-documentation requirements.

ESPR also provides an EU Declaration of Conformity framework under Article 44 and Annex V for products covered by applicable delegated acts. The manufacturer assumes responsibility for conformity by drawing up that declaration.

The applicable conformity procedure must therefore be checked against the product-specific act rather than assumed to use one universal module.

ESPR contains a conformity-marking framework for products subject to applicable ecodesign requirements. Where the ESPR conformity framework requires CE marking, Articles 45 and 46 govern its use.

The Regulation also allows delegated acts to establish alternative conformity markings for products not otherwise subject to a CE-marking requirement.

The applicable delegated act must therefore be checked before determining the marking route.

ESPR also contains obligations that are not dependent on a product-specific ecodesign delegated act.

Article 25 prohibits the destruction of the unsold consumer products listed in Annex VII from 19 July 2026 for economic operators covered by the rule. The initial prohibition concerns defined apparel, clothing accessories and footwear.

Micro and small enterprises are exempt from the Article 25(1) prohibition, while the Regulation provides for its application to medium-sized enterprises from 19 July 2030.

Separate disclosure requirements for discarded unsold consumer products also apply according to the scope and timetable established by ESPR and its implementing measures.

ESPR product compliance does not replace national EPR obligations. A product can simultaneously be subject to ESPR product requirements, a Digital Product Passport requirement under the applicable product measure, packaging EPR, EEE/WEEE EPR or another applicable producer-responsibility regime.

Registration, authorised representation, collective or individual fulfilment, records and reporting must therefore be assessed separately from ESPR conformity.