ESPR: the Ecodesign Regulation, obligations and timeline to 2030

The ESPR in figures

What is the ESPR?

The ESPR is the Ecodesign for Sustainable Products Regulation. It replaces Directive 2009/125/EC, which until now covered only energy-related products. The old directive became known mainly in combination with the energy label and its A-to-G classes for electrical appliances, heating and lighting. With the ESPR, the EU extends this framework to almost all physical product groups. The aim is to design products from the drawing board onwards so that they last longer, can be repaired, reused and recycled more easily, and consume fewer resources. The Digital Product Passport (DPP) is expected to become the ESPR's central information instrument for many priority product groups, documenting product-specific requirements in a structured, verifiable way. The scope and architecture of the DPP vary by product category and are specified in the relevant delegated act.

The ESPR works as a horizontal framework. It defines which types of requirements the European Commission may set for products, not what applies to a specific product. The concrete obligations come through delegated acts, on two tracks: product-specific delegated acts regulate what applies to textiles, furniture, steel and other product groups individually. Horizontal delegated acts regulate topics that affect several product groups at once, such as general repairability requirements. The technical DPP system on which all product groups build is standardised by Joint Technical Committee 24 (JTC 24) of CEN-CENELEC on behalf of the Commission, so that not every sector develops its own solution. The first six of these DPP standards have been cited in the Official Journal of the EU since July 2026.

Three points are decisive.

First: the ESPR is product-based, not company-based. Size thresholds like those in supply chain due diligence laws exist only in some areas, such as the destruction ban. Anyone who places an affected product on the EU market must provide a DPP and meet the other ESPR requirements.

Second: the regulation is technology-neutral. It prescribes objectives (durability, repairability, recycling rate), not technologies.

Third: some requirements are already clear today and are unlikely to be fundamentally overturned by the delegated acts. For example, unique identifiers and data carriers have been described in harmonised standards since July 2026 (EN 18219 and EN 18220). The standards do not prescribe a specific technology. Whether a QR code, NFC or RFID is mandatory is set by the relevant act for its product group. This means you can already work on your data carrier strategy today, even if the product-specific act is not yet final.

Only a few categories are explicitly excluded: food, feed, medicinal and veterinary medicinal products, living plants, animals and micro-organisms, products of human origin, and products of plants and animals relating directly to their future reproduction. Vehicles are regulated by their own legislation and are therefore exempt from core ESPR obligations. Anything not explicitly excluded can be regulated under the ESPR.

The ESPR abbreviation and how it fits in

The ESPR abbreviation stands for Ecodesign for Sustainable Products Regulation. It is used interchangeably with "Ecodesign Regulation" or "EU Ecodesign Regulation". In German it is known as the "Ökodesign-Verordnung". All of these terms refer to the same legal act.

In EU legislative logic, the ESPR succeeds the Ecodesign Directive 2009/125/EC. The move from directive to regulation is not a formality but a legal step: a directive sets the direction and the objective, but each EU member state has to transpose it into national law and decides itself how to reach the objective. The result is 27 slightly different legal texts. A regulation, by contrast, applies directly in every member state, without a national transposition loop. The ESPR therefore harmonises ecodesign rules across the entire EU.

The ESPR is a cornerstone of the EU Circular Economy Action Plan within the European Green Deal. It should not be read in isolation, because other product-specific laws such as the Construction Products Regulation, the Detergents Regulation and the Toy Safety Regulation also use the DPP as an instrument to provide product conformity, product safety and instructions digitally and in a structured way. The Packaging and Packaging Waste Regulation (PPWR), by contrast, relies on digital labelling via QR code, a related but separate instrument without a DPP obligation.

The ESPR was the first to bring the DPP centre stage, and further product-specific EU acts have since built on this infrastructure. This is visible in the EU registry: since July 2026 it has been designed not only for ESPR products but also for batteries, construction products, toys and detergents, in each case once the relevant act requires registration for a product group. Whether the DPP will also be anchored in general product law depends on the European Product Act, which has so far only been announced politically. The Commission proposal is expected by the end of 2026. Under the motto "one tool, digitalise once", the Commission is linking these initiatives with the DPP as a single data infrastructure.

What does the Ecodesign Regulation require?

The ESPR allows the European Commission to set two types of requirements per product category: performance requirements, i.e. design specifications for the product itself (materials, durability, repairability, and in future also thresholds such as a minimum recycled content), and information requirements, which define which product data must be provided in a structured way via the DPP. What is required in concrete terms is set out in the relevant delegated act. The range of possible requirements is outlined in Articles 5 and 7 of the ESPR. Product-specific laws (such as the Textile Labelling Regulation) can add further mandatory data points. The following nine requirement clusters show the spectrum.

Two points are central in practice.

First: the requirements are cumulative. A delegated act can introduce several requirements at once, such as durability plus repairability plus a DPP. For manufacturers, this means compliance is a bundle of data, not a single test certificate.

Second: information requirements and performance requirements interlock. If you have to prove durability, you also have to provide the evidence in a structured way in the DPP. Technical data capture and organisational data maintenance therefore become the critical path.

Ban on destroying unsold products

A separate chapter of the ESPR deals with the destruction of unsold consumer goods. Article 25 introduces, for the first time, a direct destruction ban that applies independently of product-specific delegated acts. Since 19 July 2026, large enterprises may no longer destroy unsold apparel, clothing accessories and footwear. For medium-sized enterprises, the ban applies from 19 July 2030; micro and small enterprises are exempt. According to the European Commission, an estimated 4 to 9 percent of unsold textiles in Europe are destroyed every year before ever being worn.

When destruction is still permitted

The Commission set out the exemptions on 9 February 2026 in Delegated Regulation (EU) 2026/296, which has also applied since 19 July 2026. Destruction remains permitted only in narrowly defined cases, including:

• where the product is unsafe, for example within the meaning of the General Product Safety Regulation (GPSR),
• where it infringes intellectual property rights, for example counterfeits,
• where it is damaged and can no longer be repaired economically,
• where offers to donate it to social economy organisations have demonstrably been unsuccessful.

Anyone relying on an exemption must be able to prove it. The evidence must be retained and presented to market surveillance authorities on request. For the compliance organisation, this means every act of destruction needs a documented justification at product or batch level, not just a lump-sum warehouse entry.

Disclosure obligation

In parallel, Article 24 of the ESPR requires medium-sized and large enterprises that discard unsold consumer goods to disclose this annually: number, weight, reasons and the waste treatment routes chosen. The obligation already applies to large enterprises and will apply to medium-sized enterprises from 2030; micro and small enterprises are exempt. The Commission also set a uniform reporting format by implementing act on 9 February 2026, to be applied from spring 2027. These data feed into EU-wide Commission reports, on the basis of which the Commission can add further product categories to the destruction ban by delegated act. Fashion is only the beginning.

For companies, the consequences are twofold. On the one hand, operational logistics change: returns, overproduction and seasonal goods have to be rerouted to resale, donation or recycling instead of destruction. On the other hand, reputational pressure increases: the annual reports are public. Companies reporting high destruction rates will be challenged by NGOs, investors and the media. The strategic answer does not lie in reporting technology, but in product and purchasing planning that structurally reduces overproduction. What this means for fashion brands is shown on the page on the Digital Product Passport for textiles and fashion.

The delegated act as the core mechanism

The ESPR sets the framework; the ESPR delegated act sets the concrete obligation. Without understanding this mechanism, the regulation cannot be planned operationally.

A delegated act is a secondary EU legal act that the European Commission may adopt on the basis of an empowerment in the basic act. For the ESPR, this means the Commission may determine per product category which ecodesign requirements apply, which data points must appear in the DPP, which thresholds must be met and how testing works. The Council and the European Parliament can reject the act within a set period, but they cannot amend it. This speeds up legislation considerably.

Alongside delegated acts, there are implementing acts, which govern technical implementation. The most prominent example is Implementing Regulation (EU) 2026/1778, which governs the operation of the EU registry for Digital Product Passports, live since July 2026 (applicable since 6 August 2026).

The process has four stages. First, the European Commission prioritises product categories in the working plan. The first working plan for 2025 to 2030 was published on 16 April 2025. Building on this, the Commission commissions a preparatory study and consults industry, member states and stakeholders, including through a public call for evidence and the Ecodesign Forum. It then drafts the delegated act for the specific product group. After adoption and scrutiny by the Council and Parliament, a transition period of usually at least 18 months follows before the requirements become binding. Shorter periods are only provided for in justified cases; longer ones are possible.

For corporate planning, the mechanism has three consequences.

First: if you are affected, you know the date. Once the delegated act is published, the deadline is fixed. Instead of waiting, you can already take key preparatory steps today, such as building the data structure and deciding on data carriers.

Second: 18 months is a tight schedule in production cycles. If you prepare your data landscape, supplier connection and system integration in parallel with the adoption of the act, you gain room to manoeuvre. If you only start afterwards, you work without a buffer.

Third: the consultation is the real early warning signal. The working plan names indicative years; the call for evidence shows which requirements the Commission is actually examining. For the iron and steel act, around six months lay between the start of the consultation and the targeted adoption.

Implementation status 2026: what already applies and what comes next

2026 is the year in which the ESPR moves from framework to practice. Three building blocks have been binding since the summer: the destruction ban, the EU registry and the first harmonised DPP standards. The product-specific obligations, by contrast, are still pending. The following overview shows the status as of October 2026.

Sources: ESPR working plan 2025–2030, Delegated Regulation (EU) 2026/296, CEN-CENELEC on the DPP standards, Implementing Decision (EU) 2026/1736, Implementing Regulation (EU) 2026/1778. Indicative dates may shift.

The EU registry for Digital Product Passports

The registry is not a central data store for product passports. It records the unique product identifier, the responsible economic operator, where applicable the commodity code, and a check value for the respective passport version. The passport data itself remains with the company or its DPP service provider. Only verified economic operators may register, with identity proven via eIDAS-compliant methods such as qualified electronic seals. For imports, the registry is linked to customs: on release for free circulation, the product identifier and commodity code are matched.

Important for context: the implementing regulation does not create a DPP obligation of its own. Whether and from when a product must be registered still follows from the relevant act, i.e. the Battery Regulation or an ESPR act. Verifying your own company is, however, already possible today. How the registry works and what you can prepare now is explained on the page on the EU DPP registry.

The harmonised DPP standards

Six standards from JTC 24 have been cited in the Official Journal of the EU since 15 July 2026 (CEN-CENELEC): EN 18216 (data exchange protocols), EN 18219 (unique identifiers), EN 18220 (data carriers), EN 18221 (data storage, archiving and data persistence), EN 18222 (APIs for life cycle management and searchability) and EN 18223 (system interoperability). Not yet cited are the standards on access rights and confidentiality (EN 18239) and on data authentication, reliability and integrity (EN 18246). What each of the eight standards defines is set out in the overview of DPP standards.

For system selection, this is the most important progress of the year: whether a DPP solution works in line with the standards can now be verified rather than merely claimed. Thomas Rödding, founder and CEO of Narravero, is personally involved as Co-Chair of JTC 24, the committee that developed these standards.

The first product-specific act: iron and steel

The Commission's consultation on iron and steel ran from 19 May to 12 August 2026. According to the consultation documents, the Commission is examining information obligations on carbon footprint, recycled content and substances that hinder recycling, as well as performance classes and minimum requirements based on the carbon footprint, and a Digital Product Passport for all actors in the supply chain. Adoption is targeted for the fourth quarter of 2026.

Even if you do not produce steel, this act is worth reading. It shows how the Commission combines performance and information requirements, and as an intermediate product it affects the supply chains of machinery, furniture, electrical goods and construction.

ESPR product categories and timeline

The first ESPR working plan (April 2025) prioritises product groups for the first delegated acts and gives indicative years for them. In addition, several sector-specific regulations with their own DPP obligations apply, which are not activated by an ESPR act but come directly from the respective regulation. The following table shows both. For ESPR product groups, the "Obligation expected" column is an estimate based on the minimum transition period of 18 months.

Sources: ESPR rows based on the ESPR working plan 2025–2030 (COM(2025) 187). The years given there are indicative; an obligation only becomes binding with the relevant delegated act. Parallel regulations: each linked regulation on EUR-Lex. Status: October 2026.

Two points are often misunderstood in practice. Electronics does not get its own product-specific ESPR act in the current working plan. It is covered by horizontal requirements (repairability 2027, recyclability 2029) and by the revision of existing ecodesign and energy label measures. And footwear, while covered by the destruction ban, is not on the priority list for its own ecodesign act.

A common misconception should be addressed right away. If you are not in the first wave, you might conclude there is nothing to do yet. That is formally correct but operationally dangerous. In practice, implementing full ESPR compliance including the DPP takes 6 to 12 months. If your obligation starts in 2029 and you only begin after the act is published in 2027, you have hardly any buffer. If you start now, you have time for a strategic build-up that goes beyond the legal minimum.

Sector-specific entry points with concrete requirements and examples are available for battery and energy storage manufacturers, the textile and fashion industry, the furniture industry, the electrical and electronics industry, construction products and toys.

Are you affected?

The ESPR addresses every economic operator that places physical products on the EU market or puts them into service. Being based in the EU is not a requirement. What matters is market access, not the company's registered office.

The regulation distinguishes between several roles. Manufacturers based in the EU bear primary responsibility. Importers take responsibility for products from third countries. Authorised representatives of manufacturers from third countries act as the party placing products on the EU market. Fulfilment service providers are covered as economic operators where they act as the last instance before placing on the market. Distributors share responsibility for not listing products without valid ecodesign documentation.

B2B business models are fully covered too. The ESPR makes no distinction between consumer and business products. If you supply components, machinery or industrial products, you may be just as affected as a consumer brand in retail, depending on the product category. The iron and steel act makes this clear: it targets intermediate products that no end customer ever sees.

Conformity and market surveillance. The ESPR is embedded in the logic of CE conformity and the New Legislative Framework. Those placing products on the market must maintain technical documentation, issue an EU declaration of conformity and be able to demonstrate the conformity of their products to national market surveillance authorities. The authorities can order spot checks, audits and market surveillance measures; in the event of non-conformity, sanctions range from fines and sales bans to market withdrawal. For imports, customs also play a role and can match product identifiers and commodity codes via the EU registry. In many product groups, the DPP becomes part of this conformity documentation.

ESPR, Battery Regulation and DPP: how do they fit together?

The DPP is the ESPR's main instrument, but it is not the only ecodesign requirement. Conversely, the ESPR is not the only legal basis for the DPP. Sector-specific regulations such as the EU Battery Regulation have their own DPP variants. Understanding the relationship clearly helps you avoid duplicate structures during implementation.

At the regulatory level: the ESPR is the horizontal framework for ecodesign. It introduces the DPP for almost all product groups not already covered by sector-specific regulation. The EU Battery Regulation (Reg. 2023/1542) is the first sector-specific act with its own DPP variant, the battery passport. In addition, the Construction Products Regulation, the Detergents Regulation and the Toy Safety Regulation contain their own DPP obligations that come directly from the respective regulation. The PPWR regulates a related instrument with digital packaging labelling, but not a Digital Product Passport.

At the system level, all DPP variants build on the same infrastructure. Since July 2026 this is no longer a declaration of intent: the EU registry is designed for product passports under the ESPR and the Battery, Construction Products, Toy Safety and Detergents Regulations, insofar as the relevant act requires registration for a product group, and the harmonised standards EN 18216 and EN 18219 to EN 18223 describe identifiers, data carriers, storage, interfaces and interoperability in the same way for all product groups. They were developed by CEN-CENELEC's Joint Technical Committee 24 (JTC 24). Thomas Rödding, founder and CEO of Narravero, is involved there in a personal capacity, not in his role as CEO, as Co-Chair, and in parallel as Vice Chairman at DIN.

Three rules follow for practice.

First: point solutions for a single sector will have to be reworked when further delegated acts extend the scope.

Second: building a battery passport also lays the technical foundation for later ESPR DPPs: the same registry, the same standards, the same verification.

Third: besides the DPP, the ESPR regulates performance requirements for the products themselves, i.e. design decisions on durability, modular repairability, material choice and recyclability. These are resolved in the product development process; the DPP then makes the results visible in a structured way.

You can find the overall perspective on the DPP under Digital Product Passport, and the sector-specific implementation for batteries under battery passport.

ESPR, energy label and European Product Act: drawing the lines

Several sets of rules run in parallel to the ESPR and are often confused in practice. The distinction matters for planning, because it determines which obligations already apply today and which data structures can be reused.

The European Product Act is worth watching. Its presentation was planned for 6 October 2026 and was postponed so that the Commission can present the general rules together with amendments to sectoral legislation. Until Parliament and Council reach agreement, it creates no obligations, and nothing changes for ESPR implementation in the short term. Should the proposal follow the leaked draft, product identity, proof of conformity and registration would apply to significantly more products than today, regardless of whether there is an ecodesign act for them.

Implementation challenges

Companies starting ESPR preparation typically run into four core problems. None of them is purely technical, but all have technical consequences.

Data availability from the supply chain

Ecodesign requirements presuppose that data on materials, origin, carbon footprint and durability is available in a structured way along the value chain. In practice, it sits with upstream suppliers, often in Excel or not at all. Data exchange between OEMs and suppliers has to be reorganised, often via frameworks such as Catena-X or GS1 Digital Link. Point solutions on the OEM side fail if suppliers are not connected.

Heterogeneous requirements across product categories

A company with several product lines usually falls under several delegated acts that differ in depth of requirements and deadlines. The compliance organisation has to map this heterogeneity without introducing a separate tool for each product group. That only works with a horizontal platform that can parameterise product-group-specific requirements.

Governance and responsibilities

Who is responsible for data quality per product? Who updates entries when products change? Who keeps compliance stable over 10 to 15 years of product life? Who verifies the company in the EU registry and manages access? These questions are not technical, but they decide whether a project scales or ends as an isolated solution. Those responsible for compliance should clarify governance early, ideally before selecting a platform.

Integration into existing systems

Product data today lives in ERP, PIM, PLM, MES, QA and document systems. ESPR compliance has to consolidate these sources, not replace them. Depth of integration is the main capability to examine when choosing a platform. If you compare superficially here, you pay twice later: once for the tool licence and once for retrofitting the integration.

The good news: these hurdles are not new. Narravero now serves more than 200 corporate customers in 12 industries that have already answered exactly these questions. There are proven patterns.

The 5-step roadmap

The ESPR deadlines sound far away, but they are tight in project cycles. The following roadmap is aimed at those responsible for compliance and the business who want to be ready to act within the next 9 to 12 months.

Before you start the five steps: a lot can already be prepared today without waiting for final delegated acts. Since the registry and standards have been in place, the left-hand column has even grown. The following quick reference shows the dividing line between preparatory work that is possible without a final act and detailed decisions that require a final delegated act.

Tackling the left-hand column today significantly shortens implementation time after the delegated act is published – without the risk of making the wrong decisions.

The order matters. If you start with platform selection before the scope is clear, you make a long-term decision blind. If you start data collection before the requirements mapping is in place, you produce idle work.

Implementing with the Narravero DPP platform

The Narravero DPP platform is the product data infrastructure on which you implement regulatory requirements and which at the same time turns the product into a direct communication channel between brand and customer. You do not need to build your own compliance architecture or develop ESPR software yourself. We provide the production-ready platform and support you throughout implementation. You do not walk the 5-step roadmap above alone, but with us as your partner.

What we take off your hands

Along the five steps of the roadmap, we take on exactly the tasks that would require the most build-up internally.

Regulatory responsibility remains with whoever places the product on the market, i.e. with you. We provide the platform and support implementation. That is the difference between in-house development and a DPP platform partnership.

What sets the Narravero DPP platform apart

One foundation for several acts. Product identity, data carriers, interfaces and access rights are the same for all DPP acts. If you set them up cleanly once, you add the required data points for a new act instead of starting a new project. As soon as an act sets its data requirements, we map them in the platform. You do not need to program anything yourself.

Ready to start. Product passports can be created right away, without prior full integration. Open interfaces let the platform scale quickly. As an official GS1 Germany Solution Partner, we ensure maximum interoperability.

The product as a communication channel. Via the DPP, the physical product becomes a direct line to the customer: storytelling, personalisation, after-sales service, customer loyalty and product data analytics. Machine-readable content is a prerequisite for visibility in AI-based procurement and search systems.

Production-proof, not pilot promises. More than 200 corporate customers in 12 industries use the platform today. It handles 300 million accesses on the Narravero platform per month, around 10 million per day on average, hosted in the EU and fully GDPR-compliant. Brands such as B&W International (specialist cases) and COR (premium furniture) use the platform not only for compliance but also for customer engagement, warranty handling and direct after-sales channels.

How to get started

Two options, depending on where you stand. If you are still working out what the ESPR means for your company, a strategic consultation is the right starting point. If you want to see the platform itself, the live demo is the better fit.

Frequently asked questions about the ESPR

Next steps

You now have the overview. Three possible next steps, depending on where you stand: