Ecodesign data is the set of product attributes and evidence that ESPR delegated acts will require, including durability, repairability, recycled content, substances of concern and environmental footprint. Because these values are decided during design and sourcing, PLM is usually the system of record. PIM and passport systems then publish the approved values to customers and authorities.
Ecodesign data is the set of product attributes and supporting evidence that the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) can require for a product group: durability, repairability, recycled content, substances of concern, energy and resource use, and environmental footprint. These values are decided during design and sourcing, so product lifecycle management (PLM) is normally their system of record, with PIM and passport systems publishing the approved values.
What counts as ecodesign data under ESPR?
ESPR Article 5 lists the product aspects that delegated acts may regulate. They include durability, reliability, reusability, upgradability, repairability, possibility of maintenance and refurbishment, presence of substances of concern, energy and water use, resource efficiency, recycled content, possibility of remanufacturing, recyclability, possibility of recovery, environmental impacts including carbon and environmental footprint, and expected waste generation.
Each delegated act turns some of these aspects into two kinds of rules:
- Performance requirements: minimum or maximum values, such as a minimum recycled content share or a durability threshold.
- Information requirements: data that must be disclosed through a digital product passport, a label, the user manual or a website.
Why does PLM hold most ecodesign data?
PLM holds most ecodesign data because the values are fixed by engineering and sourcing decisions. The table shows where common aspects originate.
| Ecodesign aspect | Where it is decided | Typical PLM object | Evidence |
|---|---|---|---|
| Material composition | Design, BOM | BOM, material master | Supplier declarations |
| Recycled content | Sourcing | Material and supplier records | Chain of custody certificates |
| Repairability and spare parts | Design | Part structure, service BOM | Disassembly instructions |
| Substances of concern | Material selection | Compliance attributes per part | Supplier full material declarations |
| Durability | Design and testing | Test plans and results | Test reports to named standards |
| Carbon and environmental footprint | LCA based on BOM | Linked LCA study | Calculation report, method |
PIM rarely calculates these values. Its role is to receive approved values, link them to sellable items and variants, and expose them to channels and passports, as described in PLM to PIM handoff.
How must substances of concern be tracked?
Where a delegated act sets information requirements on substances of concern, ESPR Article 7(5) requires tracking throughout the life cycle. The information covers:
- the name of the substance (with its chemical identifiers);
- its location within the product;
- its concentration, maximum concentration or concentration range;
- instructions for safe use;
- information relevant for disassembly, preparation for reuse and recycling.
Meeting this requires part-level compliance data in PLM, collected from suppliers in a structured format. Spreadsheets per product rarely scale once a full catalogue is in scope.
Which ESPR delegated acts are coming, and when?
No product-group delegated act under the ESPR working plan had been adopted as of 17 October 2026. The Commission adopted the first working plan on 16 April 2025. The dates below are indicative adoption targets from that plan and Commission pages, and compliance follows a transition period of generally at least 18 months.
| Product group | Indicative adoption | Status (October 2026) |
|---|---|---|
| Iron and steel | Q4 2026 (Commission DPP page) | Pending |
| Textiles (apparel first), tyres, aluminium | 2027 | Pending, preparatory studies running |
| Furniture | 2028 | Pending |
| Mattresses | 2029 | Pending |
The working plan also announces horizontal measures, such as repairability requirements across product groups. The regulatory framework is summarised in ESPR ecodesign regulation.
How should PLM be extended for ecodesign?
PLM can be prepared before delegated acts are final by adding structures that every likely requirement will use:
- material and substance attributes at part level, with source and date of the supplier declaration;
- a recycled content attribute with the certification scheme and certificate reference;
- service and spare part structures that support repairability information;
- document links with version control for test reports and LCA studies;
- identifiers at model and batch level that can feed a digital product passport.
Change management matters as much as structure. A material substitution must update composition, substances, recycled content and footprint values together, and trigger a republication in PIM. Clear ownership rules for each of these values, as set out in product data governance, prevent conflicting versions between PLM, PIM and the passport, which matters once authorities can compare published claims with technical documentation.
Practical next steps
- Map the ESPR Article 5 aspects against existing PLM attributes and mark the gaps.
- Collect structured supplier declarations for materials and substances, starting with product groups on the working plan.
- Agree which system masters each value (PLM, LCA tool, compliance system) and how PIM receives it.
- Track draft delegated acts for relevant product groups and adjust attribute definitions when requirements are published.
For a dedicated PLM vendor comparison, see PLM Vendors.
Frequently asked questions
Which system should master ecodesign data?
PLM is usually the master for design-determined values such as materials, repairability features and substances of concern. Measured values such as carbon footprint may come from LCA tools, with PLM or a compliance system holding the approved result.
Are ESPR ecodesign requirements already mandatory?
Product-specific requirements apply only once a delegated act for that product group is adopted and its transition period ends. As of 17 October 2026 no product-group delegated act under the working plan had been adopted.
How long is the transition after a delegated act is adopted?
ESPR delegated acts generally apply no earlier than 18 months after entry into force, unless a shorter period is justified.