What is the ESPR?
The Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781) is the central EU regulation for sustainable product design. It entered into force on 18 July 2024 and applies directly in all EU member states — without national implementing legislation. The ESPR replaces the previous Ecodesign Directive and extends its scope to cover nearly all physical products on the EU market.
The three core instruments of the ESPR are: ecodesign requirements for durability, repairability and recyclability; the Digital Product Passport (DPP) as a machine-readable data record accessed through a data carrier; and a destruction ban for unsold goods. More about the Digital Product Passport →
Destruction ban from July 2026
From 19 July 2026, the destruction ban for unsold apparel, clothing accessories and footwear starts for large companies. Medium-sized companies receive a longer transition period; micro and small enterprises are exempt. Affected companies must also disclose information on the number, weight and treatment of unsold products.
Delegated act timeline
ESPR requirements are specified per product category through delegated acts. The 2025–2030 working plan shows priorities; binding data fields, deadlines and transition rules appear only in each legal act:
- Iron & Steel — Listed in the working plan as a priority intermediate product group.
- Textiles & Tyres — Priority product groups; the destruction ban for unsold textiles and footwear starts separately.
- Furniture & Aluminium — Priority product groups for future ecodesign and information requirements.
- Electrical and electronic products — Horizontal measures on repairability, recyclability and recycled content are planned.
- Further product groups — The working plan includes further assessments; concrete duties arise only after impact assessment and legal act.
Company obligations
- Meet ecodesign requirements — Products must meet the durability, repairability, energy efficiency and recyclability requirements of the relevant delegated act.
- Create a Digital Product Passport — A DPP with the prescribed data points must be made available for regulated product groups once the relevant legal act requires it.
- Comply with the destruction ban — Unsold textiles and footwear may no longer be destroyed from July 2026. Disclosure obligations for disposal routes.
- Provide conformity documentation — On request from market surveillance authorities, companies must be able to provide complete compliance documentation.
Penalties for non-compliance
Non-compliant products may not be sold on the EU market. Market surveillance authorities can recall products and issue distribution bans. Fines are set individually by member states (ESPR Art. 74). The EU coordinates market surveillance across borders.
Conformity assessment & CE marking
Before being placed on the market, every ESPR-regulated product must undergo a conformity assessment. The manufacturer issues an EU Declaration of Conformity and affixes the CE marking. The declaration must be retained for ten years and made available to market surveillance authorities on request. Where harmonized product standards apply (e.g. EN standards), conformity is presumed — otherwise the burden of proof rests with the manufacturer.
ESPR vs. the old Ecodesign Directive 2009/125/EC
The old Ecodesign Directive 2009/125/EC only covered energy-related products (household appliances, lighting, heating). The ESPR extends the scope to nearly all physical products on the EU market and adds three core innovations: the Digital Product Passport, the destruction ban and requirements for repairability, recycled content and supply chain transparency. Unlike a directive, the regulation applies directly — no national transposition act required.
Obligations for online marketplaces
A key difference from the old directive is that ESPR also considers digital distribution, online marketplaces and fulfilment structures. For manufacturers and importers, this means product data, CE-related evidence and product-passport access need to be maintained so they can be checked beyond internal teams across the digital sales chain.
Sources