ESPR: The EU Ecodesign Regulation that changes how you sell physical products
The Ecodesign for Sustainable Products Regulation requires most physical goods sold in Europe to carry a Digital Product Passport. Here’s what it means, when it applies, and what you need to do.
What is ESPR?
ESPR (Ecodesign for Sustainable Products Regulation, EU 2024/1781) is the EU’s overhaul of product sustainability law. It replaces the 2009 Ecodesign Directive, which only covered energy-related products, and extends mandatory eco-requirements to almost all physical goods placed on the EU market.
The centrepiece of ESPR is the Digital Product Passport (DPP): a machine-readable, QR-linked record that travels with each product and makes sustainability data — materials, repairability, chemical content, recycling guidance — available to anyone who scans it.
ESPR also sets mandatory requirements for durability, repairability, recyclability, and the prohibition of destroying unsold goods. But for most brands, the first concrete obligation they will encounter is the DPP.
Who does ESPR apply to?
Any economic operator that places products in the EU market — manufacturers, importers, and brand owners. This includes:
There is no turnover threshold or SME exemption in the core regulation. Micro-enterprises may receive proportionate measures in some delegated acts, but should not assume they are excluded.
ESPR timeline — key dates
Regulation (EU) 2024/1781 published. Commission begins working programme for delegated acts.
The Commission adopts the first ESPR secondary acts, setting disclosure rules for businesses that destroy unsold goods.
Destroying unsold apparel and footwear is banned in the EU (micro and small enterprises exempt; medium-sized from 2030). Same day: the Commission's deadline to set up the central EU DPP registry — an infrastructure milestone, not yet a product-level duty.
Batteries Regulation (EU) 2023/1542 requires DPPs for EV, LMT and industrial batteries — the first products that must actually register in the EU registry.
Commission proposal expected late 2026, adoption around 2027. The act sets the exact DPP data fields for clothing and textiles.
DPPs become mandatory at least 18 months after the delegated act is adopted — realistically 2028–2029. Brands selling in the EU must have the passport attached to the product.
Iron and steel lead the industrial categories (act expected 2026, compliance around 2028). Furniture follows (act expected 2028, mandatory around 2029–2030). Consumer electronics are not in the current Working Plan — the 2028 review is their earliest entry point.
What does ESPR compliance require from brands?
By your category’s compliance date, you need:
- 01A Digital Product Passport for each productContaining the required data fields for your category — materials, certifications, care, end-of-life guidance.
- 02A unique product identifier (UID)A persistent, unique ID per SKU. Format is defined per delegated act — often GS1 GTIN or similar.
- 03A data carrier on the productA QR code, NFC chip or equivalent that links to the passport. Must be on the product or its label.
- 04A publicly accessible passport pageAnyone with a smartphone must be able to scan and read the passport. No login or app required.
- 05Durability and repairability dataDepending on category: expected lifespan, spare parts availability, repairability score.
Frequently asked questions
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