European Ecodesign for Sustainable Products Regulation (ESPR)

The ESPR Regulation, European Commission proposal 2022/0095, will replace the Ecodesign Directive (2009/125/EC) to extend sustainability requirements beyond energy-related products, covering virtually all goods placed on the EU market. Final adoption is expected in 2025, with phased implementation between 2026 and 2030.

Context and strategic objectives

• Strengthen the Green Pillar of the European Green Deal and the goals of the 2020 Circular Economy Action Plan
• Reduce the material and energy footprint of products by 30% by 2030 compared to the 2020 baseline
• Save 150 TWh of final energy and avoid 250 Mt CO₂e annually through high-performance ecodesign
• Increase material circularity by 23% via minimum recycled content and mandatory durability requirements

Expanded scope

• Mandatory requirements for durability, reparability, upgradability and recyclability
• Minimum recycled content and restrictions on substances of concern across product categories
• Digital Product Passport (DPP) for each unit sold, with traceability of materials, carbon and water footprint, repairs and recycling potential
• New priority categories: textiles, furniture, mattresses, footwear, batteries, photovoltaics, steel, aluminium, cement, consumer electronics and ICT

Proposed timeline (key milestones)

• 2025 Q4 → Publication in the Official Journal + 18-month transition period
• 2026 Q2 → Delegated acts for textiles and batteries; first DPP obligations
• 2027 → Requirements for furniture, electronics and steel
• 2028–2030 → Expansion to remaining groups; full alignment of the Single Market

Regulatory and market mechanisms

• Repairability index visible at point of sale (scale 0–10); minimum ≥ 7/10 for priority categories by 2030
• Ban on the systematic destruction of unsold goods
• Expanded energy-efficiency labelling for connected devices and construction products
• Restrictions on substances aligned with the Chemicals Strategy for Sustainability; phasing out SVHCs before 2030
• Third-party conformity assessment (modules A–F) by notified bodies for DPP verification and recycled-content checks
• Market surveillance coordinated by ADCO ESPR, with fines of up to 4% of annual turnover for severe non-compliance

Digital Product Passport (DPP)

• Mandatory data: material composition at ≥ 0.1%, % recycled content, cradle-to-gate carbon footprint, water footprint, repair & disassembly instructions, end-of-life routes and collection points
• Interoperable semantic format (EPCIS 2.0 Ontology + GS1 Digital Link)
• Tiered access: consumer (QR code) vs. waste-management operators (API)
• Optional blockchain integration for traceability of critical materials (cobalt, lithium, synthetic microfibres)

Business benefits and opportunities

• Competitive advantage: early-compliant products score higher in public tenders (+10 pp in EU green procurement)
• Operational savings: modular design cuts after-sales service costs by 18%
• New service models: product-as-a-service (furniture leasing, appliance subscription)
• Access to green finance: EU Taxonomy and sustainability-linked bonds reward recycled content and durability

Challenges for SMEs and resource-intensive sectors

• Adaptation cost: initial investment estimated at 2–4% of EBITDA for redesign and certification
• Need for supply-chain digitalisation and traceability capabilities
• Limited availability of high-purity recycled materials; risk of bottlenecks
• Global consistency: competition with imports from countries lacking equivalent requirements before full CBAM implementation on embedded carbon

Corporate roadmap (2024–2027)

• Gap analysis against the draft ESPR across all product lines
• Ecodesign plan with SMART targets for recycled content, reparability and embodied CO₂ reduction
• DPP pilots using digital twins and PLM systems
• Circular-supply contracts with recyclers and secondary-material suppliers
• Internal training on circular economy and repair
• External communication emphasising durability and upgrade pathways

Legislative synergies

• CSRD / ESRS E1–E5: mandatory reporting on circularity and eco-efficiency metrics
• Right-to-Repair Directive (R2R): complements ESPR reparability requirements
• ISO 14068: aligns product- and organisation-level climate-neutrality pathways using C2G data
• CBAM & INEA (Battery Regulation): convergence around traceability and embedded-footprint disclosure

The ESPR Regulation will transform how products are designed, marketed and documented in the EU, driving circular innovation and environmental-data transparency. Companies that adopt a proactive strategy—early ecodesign, digital product passports and collaborative supply chains—will seize emerging market opportunities while mitigating regulatory and reputational risks in the transition toward a climate-neutral, resource-efficient economy.