The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, entered into force on 18 July 2024 and lets the Commission set performance and information requirements, including digital product passports, for almost all physical products. Requirements apply per product group through delegated acts, none of which had been adopted under the working plan by 17 October 2026. A ban on destroying unsold apparel and footwear has applied to large enterprises since 19 July 2026.
The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, is the EU framework that allows the Commission to set sustainability performance and information requirements, including digital product passports, for almost all physical products placed on the EU market. It entered into force on 18 July 2024, and its requirements apply per product group through delegated acts, none of which had been adopted under the first working plan as of 17 October 2026.
What is the ESPR?
ESPR replaces the Ecodesign Directive 2009/125/EC as the general framework and extends ecodesign from energy-related products to nearly all physical goods. Existing energy-related ecodesign measures continue until replaced. Exclusions in Article 1 include food, feed, medicinal products, living plants and animals and vehicles under type approval rules.
ESPR works through three instruments:
- Delegated acts per product group, setting performance requirements (for example durability or recycled content) and information requirements.
- Digital product passports for product groups where a delegated act requires one (Articles 9 to 15).
- Direct obligations in the Regulation itself, such as disclosure and the ban on destroying unsold consumer products (Articles 24 and 25).
What can ecodesign requirements cover?
Article 5 lists the aspects delegated acts may address: durability, reliability, reusability, upgradability, repairability, maintenance and refurbishment, substances of concern, energy and water use, resource efficiency, recycled content, remanufacturing, recyclability, recovery, carbon and environmental footprint, and expected waste. Information requirements may be delivered through a passport, a label, product instructions or a free-access website. The engineering implications are covered in PLM and ecodesign data.
What is the ESPR timeline?
The table combines dates fixed in the Regulation with indicative dates from the working plan adopted on 16 April 2025.
| Date | Milestone | Status (17 October 2026) |
|---|---|---|
| 18 July 2024 | Entry into force | Done |
| 16 April 2025 | First ESPR working plan (2025 to 2030) | Adopted |
| First full financial year after 18 July 2024 | Annual disclosure of discarded unsold consumer products by large enterprises (Article 24) | Applies |
| 19 July 2026 | Ban on destroying unsold apparel, clothing accessories and footwear (large enterprises); DPP registry deadline | Applies; registry live since 20 July 2026 |
| 2 March 2027 | Standard disclosure format, Implementing Regulation (EU) 2026/2 | Adopted, applies from this date |
| Q4 2026 (indicative) | Delegated act on iron and steel | Pending |
| 2027 (indicative) | Textiles (apparel first), tyres, aluminium | Pending |
| 2028 and 2029 (indicative) | Furniture, then mattresses | Pending |
| 19 July 2030 | Destruction ban extends to medium-sized enterprises | Scheduled |
A delegated act on derogations from the destruction ban (for example for unsafe, damaged or counterfeit goods, or where donation fails) was published in April 2026. For data owners, the ban and disclosure rules require reliable records of unsold stock by product category, the quantity and weight discarded, the reason and the waste treatment route. This data usually sits in ERP, warehouse and returns systems, and it needs the same product classification used in PIM so that reported categories match the catalogue.
What does ESPR require for digital product passports?
Where a delegated act requires a passport, it specifies the content, the identifier level (model, batch or item), the data carrier, access rights and retention. The Commission launched the EU DPP registry on 20 July 2026, and Commission Implementing Regulation (EU) 2026/1778 has governed its use since 6 August 2026. Six harmonised standards on identifiers, carriers, storage, APIs and interoperability were cited in July 2026. These building blocks are explained in digital product passport explained and DPP data architecture.
What does ESPR mean for product data owners?
ESPR turns sustainability claims into structured, verifiable product data. Data owners should plan for:
- New attributes for composition, substances of concern, recycled content, repairability and footprint, defined per product group.
- Evidence links to test reports, certificates and calculations, kept for market surveillance.
- Identifier discipline at model, batch or item level.
- Disclosure data on discarded unsold products, which links product data to inventory and reverse logistics systems.
- Consistency with other reporting, such as sustainability statements under CSRD and product data.
Because each delegated act defines its own schema, a configurable PIM or passport data model is easier to adapt than hard-coded fields.
Practical next steps
- Map the product portfolio against working plan product groups and track each draft delegated act.
- Check whether the organisation is a large or medium-sized enterprise for the destruction ban and disclosure obligations.
- Start collecting composition, substance and recycled content data from suppliers for priority groups.
- Prepare identifier and passport hosting decisions ahead of the first applicable delegated act.
For independent PIM vendor overviews, see PIM Vendors.
Frequently asked questions
When does ESPR apply to my products?
ESPR product requirements apply only once a delegated act for the relevant product group is adopted and its transition period ends, generally at least 18 months later. As of 17 October 2026 no product-group delegated act under the working plan had been adopted.
Which products are excluded from ESPR?
ESPR excludes food, feed, medicinal products, veterinary medicinal products, living plants and animals, products of human origin and vehicles covered by type approval rules, among other exclusions in Article 1.
Does the ESPR destruction ban apply to SMEs?
Micro and small enterprises are exempt. Medium-sized enterprises are covered from 19 July 2030, while large enterprises have been covered since 19 July 2026.
Sources
- Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation), EUR-Lex
- European Commission: Ecodesign for Sustainable Products Regulation
- European Commission: Digital Product Passport for iron and steel
- Commission Implementing Regulation (EU) 2026/1778 on the digital product passport registry, EUR-Lex