ESPR Compliance Guide: Ecodesign for Sustainable Products Regulation 2026

What is the ESPR regulation?

The Ecodesign for Sustainable Products Regulation (ESPR, Regulation EU 2024/1781) is the EU's main product sustainability law. It replaced the old Ecodesign Directive and entered into force in July 2024. ESPR sets ecodesign requirements and mandates Digital Product Passports for virtually all physical products sold in the EU. It covers energy performance, material efficiency, repairability, recyclability, recycled content, carbon footprint, and supply chain transparency.

ESPR works as a framework. Product-specific rules are published separately in delegated acts for each product category. Each delegated act defines the exact ecodesign requirements, DPP data fields, and compliance deadlines for that category.

How ESPR differs from the old Ecodesign Directive

• Broader scope - the old directive focused mainly on energy-related products. ESPR covers almost all physical products: textiles, furniture, electronics, chemicals, packaging, and more. Roughly 70 to 80% of all products sold in the EU fall under its scope.

• Digital Product Passport - ESPR introduces a mandatory DPP for regulated product categories. This was entirely absent from the old directive.

• Circularity requirements - ESPR adds rules on recycled content, durability, repairability, and end-of-life design. This goes well beyond energy efficiency.

• Supply chain transparency - ESPR requires brands to disclose supply chain data that was previously voluntary.

• Destruction ban - ESPR prohibits the destruction of unsold consumer goods, with limited exceptions, to reduce overproduction and waste.

Which products are covered by ESPR?

Almost all physical products sold in the EU are in scope, except food, feed, and medicinal products. The European Commission publishes a working plan identifying which product groups are prioritised and when. Here is the current picture:

Key obligations for businesses

• Ecodesign requirements - product-specific performance thresholds for energy use, durability, repairability and recyclability, set in each delegated act

• Digital Product Passport - mandatory for regulated categories, accessible via QR code or NFC, containing standardised data on sustainability, materials and lifecycle

• Product information sheet - standardised technical documentation for market surveillance authorities

• Declaration of Conformity - manufacturers must formally declare compliance before placing products on the market

• EU Product Registry - DPP data must be registered in a centralised EU database

• Destruction ban - prohibition on destroying unsold consumer goods, with derogations for SMEs and safety or hygiene reasons

Who must comply?

ESPR applies to any company placing regulated products on the EU market, regardless of where they are based:

• EU manufacturers - directly responsible for meeting ecodesign requirements and maintaining a compliant DPP

• Non-EU manufacturers - must appoint an EU Authorised Representative. Being based outside the EU is not an exemption.

• Importers - responsible for checking that products comply before placing them on the market

• Distributors - cannot supply products without the required DPP once the obligation applies

• Online marketplaces - must ensure sellers on their platforms provide compliant DPPs for regulated categories

SME exemptions exist in limited cases, but the conditions vary by delegated act. Most SMEs placing regulated products on the EU market remain in scope.

ESPR compliance timeline

Delegated act timelines are indicative and subject to revision by the European Commission. Check the Compliance Navigator for the current status of your product category.

How ESPR connects to other EU regulations

• EU Battery Regulation (2023/1542) - runs alongside ESPR with its own DPP requirements for batteries. The Battery Passport is the earliest EU DPP deadline at February 2027.

• CPR 2024 (Construction Products Regulation) - introduces DPP obligations for construction products through a separate regulation aligned with ESPR principles.

• PPWR (Packaging Regulation) - packaging sustainability rules including recycled content requirements and recyclability labelling.

• CSRD (Corporate Sustainability Reporting Directive) - product data collected under ESPR can feed directly into CSRD sustainability reporting, reducing duplication for companies subject to both.

• EU Taxonomy - product sustainability data from DPPs supports green finance disclosures required under the Taxonomy Regulation.

How to build your ESPR compliance programme

1. Map your products against delegated acts - identify which categories fall under active or upcoming ESPR delegated acts. Use the DPP Pro Compliance Navigator to assess your exposure.

2. Run a data readiness assessment - compare your current product data against anticipated DPP requirements. Most manufacturers find significant gaps, particularly for upstream material and chemical data.

3. Engage your supply chain early - DPP data typically requires input from Tier 2 and Tier 3 suppliers. Data collection is the longest lead item in most DPP projects, often 6 to 12 months.

4. Select a DPP platform - choose a solution suited to your product category, data volume, and IT setup. See our DPP software buyer guide and browse verified providers.

5. Run a pilot - start with one product line 12 to 18 months before your compliance deadline to catch technical issues before scaling.

6. Plan for ongoing maintenance - DPPs must stay accurate and accessible throughout the product lifetime. Build update processes into your workflows from day one.

Written by the DPP Pro Team. Last updated June 2026.