ESPR: the Ecodesign Regulation, obligations and timeline to 2030

The ESPR in numbers

What is the ESPR?

The ESPR is the Ecodesign for Sustainable Products Regulation. It replaces Directive 2009/125/EC, which until now only covered energy-related products. The old directive became known above all through the energy label with its A-to-G classifications for electrical appliances, heating and lighting. With the ESPR, the EU extends this framework to almost every physical product group. The aim is to design products from the drawing board so that they are more durable, more repairable, more reusable and more recyclable, and consume fewer resources. The Digital Product Passport (DPP) is expected to become the central information instrument of the ESPR for many prioritised product groups, the instrument through which product-specific requirements are documented in a structured and verifiable way. The scope and architecture of the DPP vary by product category and are specified in the respective delegated act.

The ESPR works as a horizontal framework. It defines which kinds of requirements the European Commission may set for products, not what applies to a specific product. The concrete obligations come through delegated acts. This works on two tracks: product-group-specific delegated acts govern what applies individually to textiles, furniture, electronics and other product groups. Horizontal delegated acts govern topics that affect several product groups at once, for example general repairability requirements. In parallel, the ESPR defines the technical DPP system through the Joint Technical Committee 24 (JTC 24) of CEN-CENELEC, the system on which all product groups build, so that not every sector develops its own solution.

Three points are decisive here.

First: the ESPR applies on a product basis, not a company basis. Size thresholds, as in supply-chain laws, exist only in parts, for example in the destruction ban. Anyone who places an affected product on the EU market is obliged to provide a DPP and the remaining ESPR requirements.

Second: the regulation is technology-neutral. It prescribes goals (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: for many DPP applications, digital data carriers such as QR codes are foreseen; other technologies such as NFC or RFID come into play as a complement depending on the product category. The concrete technical determination is made through later implementing and standardisation acts. This means the data-carrier strategy can already be worked on today, even if the sector-specific legal act is not yet final.

Only a few categories are explicitly exempt: food, feed, medicinal products and veterinary medicinal products, living plants, animals and micro-organisms, products of human origin and products directly related to the future reproduction of plants and animals. Vehicles are regulated through their own legal acts and are therefore exempt from central ESPR obligations. Everything that is not explicitly exempt can be regulated through the ESPR.

Key point The ESPR is a framework regulation with a horizontal system: one DPP standard for all product groups, plus product-group-specific and horizontal delegated acts for the concrete requirements.

ESPR abbreviation and context

The ESPR abbreviation stands for Ecodesign for Sustainable Products Regulation. It is also referred to as the Ecodesign Regulation or the "Regulation on ecodesign requirements for sustainable products" (German: Ökodesign-Verordnung). All refer to the same legal act.

In EU legislative logic, the ESPR is the successor to the Ecodesign Directive 2009/125/EC. The jump from directive to regulation is not a formality but a legal-technical step: a directive sets the direction and the goal but must be transposed into national law by each EU member state. Each member state decides for itself how to reach the goal. The result is 27 slightly different legal texts. A regulation, by contrast, applies directly in every member state without a national transposition loop. This is how the ESPR harmonises ecodesign rules across the entire EU.

The ESPR is a core element of the EU's Circular Economy Action Plan within the European Green Deal. It cannot be read in isolation, because other product-specific laws such as the Packaging Regulation (PPWR), 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 for use in a digital and structured way.

The ESPR was the first to bring the DPP onto the big stage; further product-specific EU legal acts have since built on this infrastructure. This harmonisation is being driven further through additional horizontal EU initiatives on product data and conformity regulation, as well as the existing New Legislative Framework. Under the guiding principle of "one tool, digitise once", the Commission interlinks these efforts with the DPP as a single data infrastructure.

Key point The ESPR is the directly applicable, EU-wide successor to the Ecodesign Directive. It has made the DPP the single data infrastructure on which other product-specific EU legal acts build.

Which requirements does the Ecodesign Regulation bring?

The ESPR allows the European Commission to set two kinds of requirements per product category: performance requirements, that is design specifications for the product itself (materials, durability, repairability, and prospectively also thresholds such as a minimum recycled-content share), and information requirements, which define which product data must be provided in a structured way through the DPP. What is concretely required is set out in the respective 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 for practice.

First: the requirements apply cumulatively. A delegated act can introduce several requirements at once, for example durability plus repairability plus DPP. For manufacturers this means compliance is a data bundle, not a single test certificate.

Second: information requirements and performance requirements interlock. Anyone who has to prove durability must also provide the supporting data in a structured way in the DPP. The technical capture and the organisational data maintenance thus become the critical path.

Key point ESPR compliance is a data bundle of several parallel requirements. Without an integrated data structure, every delegated act creates island work all over again.

Destruction ban on unsold products

A dedicated chapter of the ESPR concerns the destruction of unsold consumer goods. Article 25 introduces, for the first time, a direct destruction ban that works independently of the delegated acts. From 19 July 2026, large companies are prohibited from destroying unsold textiles and footwear. Medium-sized companies have a transition period of six years, micro and small companies are exempt.

Size classes per EU Recommendation 2003/361/EC: micro enterprises up to 10 employees (up to EUR 2m turnover), small enterprises up to 50 employees (up to EUR 10m turnover), medium-sized enterprises up to 250 employees (up to EUR 50m turnover). Anything above counts as a large company.

In parallel, the ESPR introduces a reporting obligation for medium-sized and large companies that discard unsold consumer goods. The number, weight, reasons for destruction and the chosen disposal routes must be made public on an annual basis. Micro and small companies are also exempt here. This data feeds 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 consequence is twofold. On the one hand, operational logistics change: returns, overproduction and seasonal goods must be steered anew, with resale, donation or recycling instead of destruction. On the other hand, reputational pressure intensifies: the annual reports are public. Anyone reporting high destruction rates will be addressed by NGOs, investors and the media. The strategic answer lies not in reporting technology but in product and purchasing planning that structurally reduces overproduction.

Key point The destruction ban works independently of delegated acts. Fashion is the first sector; more follow through the EU reporting obligation.

The delegated act as the central mechanism

The ESPR governs the framework, the ESPR delegated act governs 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 legal act. For the ESPR this means: the Commission may set, per product category, which ecodesign requirements apply, which data points must appear in the DPP, which thresholds must be met and how verification works. The Council and the European Parliament can reject the act within a deadline, but they cannot amend it. This speeds up legislation considerably.

Alongside the delegated acts there are implementing acts, which govern the technical implementation. The technical implementation of the DPP infrastructure – for example the planned EU DPP registry – is specified through complementary implementing acts.

The process has three stages. First, the European Commission prioritises product categories in the so-called working plan. The first working plan was published in April 2025. Building on this, the European Commission develops the delegated act for a concrete product group, in close coordination with industry, member states and stakeholders. After the act is adopted, a transition period of around 18 months usually runs, shorter or longer depending on the act, before the requirements become binding.

For planning within the company, the mechanism has three consequences.

First: those who are affected know the date. Once the delegated act is published, the deadline is fixed. Instead of waiting for it, central preparatory steps can already be taken today, for example building the data structure and deciding on data carriers.

Second: 18 months is a tight schedule in production cycles. Anyone who prepares their data landscape, supplier connection and system integration in parallel with the adoption of the act gains room to manoeuvre. Anyone who starts only afterwards works without a buffer.

Third: the working plans are early-warning systems. Anyone who finds their own product category in the working plan has, on average, 12 to 24 months of lead time before the actual legal act. This time is enough for a structured build-up if it is used actively.

Key point The delegated act is the operational control point of the ESPR. Anyone who reads the working plan sees, 12 to 24 months earlier, when their obligation becomes real.

ESPR product categories and timeline

The first ESPR working plan (April 2025) prioritises product groups for the first delegated acts. Alongside it, several sector-specific regulations apply with their own DPP obligations that are not activated through a delegated act but come directly from the respective regulation. The following table shows the planned sequence. The dates refer to the expected point from which the obligations take effect after the transition period.

Sources: European Commission ESPR Working Plan 2025-2030, EUR-Lex EU Battery Regulation

One common misconception should be cleared up directly here. Anyone who is not in the first wave often concludes that there is nothing to do yet. That is formally true but operationally dangerous. In practice, the implementation time for full ESPR compliance including the DPP is 6 to 12 months. Anyone obliged in 2028 who starts in 2027 has only narrow headroom. Anyone who starts in 2026 has time for a strategic build-up that goes beyond the bare 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 and the electrical and electronics industry.

Key point The first wave means compliance from 2027/2028, the second wave 2029/2030. The implementation time does not shift with it. A later cut-off date does not mean less preparation.

Are you affected?

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

The regulation distinguishes between several roles. Manufacturers based in the EU are primarily responsible. Importers take on responsibility for products from third countries. Authorised representatives of manufacturers from third countries count as the party placing the product on the EU market. Fulfilment service providers are covered as economic operators when 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 in scope too. The ESPR knows no distinction between consumer and business-customer products. Anyone supplying components, machinery or industrial products can be just as affected, depending on the product category, as a branded-goods manufacturer in retail.

Conformity and market surveillance. The ESPR is embedded in the logic of CE conformity and the New Legislative Framework. Parties 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 the national market surveillance authorities. The authorities can order spot checks, audits and market surveillance measures; in case of non-conformity, sanctions range from fines to sales bans to product recalls. In many product groups, the DPP becomes part of this conformity documentation.

Key point Market access is the decisive criterion, not the registered office. B2B manufacturers, importers and platforms are equally obliged – including technical documentation and proof to the market surveillance authorities.

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

The DPP is the main instrument of the ESPR, but it is not the only ecodesign requirement. And 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. Anyone who understands the relationship clearly avoids duplicate structures during implementation.

At the regulatory level: the ESPR is the horizontal framework for ecodesign. It introduces the DPP for almost every product group not already covered by sector-specific regulation. The EU Battery Regulation (Reg. 2023/1542) is the first sector-specific legal act with its own DPP variant, the Battery Passport. Alongside it, the PPWR, the Construction Products Regulation, the Detergents Regulation and the Toy Safety Regulation contain their own DPP obligations that come directly from the respective regulation.

At the system level, all DPP variants build on the same infrastructure. The central EU DPP registry, the identification and data-carrier standards, the role-based access models and the semantic data models are standardised horizontally. Responsible for this is the Joint Technical Committee 24 (JTC 24) of CEN-CENELEC, which develops the horizontal DPP standards. Thomas Roedding, founder and CEO of Narravero, is involved there as a private individual, not in his role as CEO, as Co-Chair and at the same time as Vice Chairman at DIN.

Three rules follow from this for practice.

First: point solutions for just one industry will be touched a second time when scope expands through further delegated acts.

Second: anyone who builds a Battery Passport builds the technical foundation for later ESPR DPPs at the same time.

Third: alongside the DPP, the ESPR governs performance requirements for the product itself, that is design decisions for durability, modular repairability, material choice and recyclability. These topics are solved in the product development process; the DPP then makes the results visible in a structured way.

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

Key point The DPP is the main instrument of the ESPR. It maps performance requirements for the product and information requirements for the supply chain in one structured data infrastructure.

Challenges in implementation

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

Data availability from the supply chain

Ecodesign requirements assume 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 OEM and suppliers must be reorganised, often through frameworks such as Catena-X or GS1 Digital Link. Point solutions on the OEM side fail when the suppliers are not connected.

Heterogeneity of 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 must reflect this heterogeneity without introducing a separate tool per product group. That only works through 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? These questions are not technical, but they decide whether a project scales or ends as a one-off solution. Compliance leads should clarify governance early, ideally before selecting a platform.

Integration into existing systems

Today, product data sits in ERP, PIM, PLM, MES, QA and document systems. ESPR compliance must consolidate these sources, not replace them. The depth of integration is the main capability to check when selecting a platform. Anyone who compares superficially here pays twice later: once for the tool licence, once for the subsequent integration.

The good news: these hurdles are not new. Narravero now serves over 200 enterprise customers across 12 sectors that have already answered exactly these questions. There are proven patterns.

Key point The critical path of ESPR implementation lies not in technology but in data availability, governance and the heterogeneity of requirements.

The 5-step roadmap

The ESPR cut-off dates sound far off but are tight in project cycles. The following roadmap is aimed at compliance and business leads who want to become operational within the next 9 to 12 months.

Before you go into the five steps: much can already be prepared today, without waiting for final delegated acts. The following quick reference shows the dividing line between preparatory work that is possible without a final legal act, and detailed determinations that require a final delegated act.

Anyone who tackles the left-hand column today significantly shortens the implementation time after publication of the delegated act – without the risk of making the wrong determinations.

The order matters. Anyone who starts with platform selection before exposure is clear makes a long-term decision blind. Anyone who starts data capture before the requirement mapping is in place produces wasted effort.

Key point Exposure, requirements, data, platform, pilot. In this order, an 18-month window becomes a corridor with a buffer.

Implementing with the Narravero DPP platform

The Narravero DPP platform is the infrastructure for product data that ensures compliance and, at the same time, turns the product into a direct communication channel between brand and customer. You do not have to build your own compliance architecture or develop ESPR software yourself. We deliver the production-ready platform and support you on the way to the cut-off date. You do not walk the 5-step roadmap above alone but with us as a partner.

What we concretely take off your plate

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

The regulatory responsibility stays with the party placing the product on the market, that is with you. The operational delivery runs on our side. That is the difference between an in-house build and a DPP platform partnership.

What sets the Narravero DPP platform apart

Regulation-centric logic. The platform maps the data requirements of product-specific regulations into concrete data points. ESPR, EU Battery Regulation, PPWR and further sector-specific legal acts are natively supported. New delegated acts are added through configuration.

Ready to go. Product passports can be created directly, without prior full integration. Through open interfaces the platform scales quickly. As an official GS1 Germany Solution Partner, maximum interoperability is assured.

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

End to end instead of island solution. One platform covers the Battery Passport, the ESPR DPPs for textiles, furniture, electronics and household appliances, as well as the DPPs from the PPWR, the Construction Products Regulation and the Detergents and Toy Safety Regulations. At every new wave, nothing needs to be set up again.

Regulatory depth plus implementation experience. CEO Thomas Roedding is involved as a private individual in European standardisation bodies for the Digital Product Passport, currently as Co-Chair of the CEN-CENELEC JTC 24, as Vice Chairman at DIN and in the work of ISO/IEC JC5. Within the Narravero team, deep regulatory knowledge meets practical implementation experience from over 200 customer projects across 12 sectors.

Production-proof, not pilot promise. Over 200 enterprise customers from 12 sectors use the platform today. It processes 300 million DPP accesses per month, with 10 million peak operations per day, 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 for customer engagement, warranty handling and after-sales direct channels.

How to get started

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

Frequently asked questions about the ESPR

Next steps

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