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Innovation & transformation
With the introduction of the Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport (DPP), the European Union is heralding a new era of sustainable product policy. The aim is to make sustainable, recyclable, and transparent products the standard in the EU market. For companies, this represents not only a regulatory challenge, but also a strategic opportunity to position themselves as pioneers in the field of sustainability.
The ESPR, adopted in 2024, replaces the previous Ecodesign Directive and significantly extends its scope beyond energy-related products. It specifies how products should be designed in an environmentally friendly manner, with a focus on durability, reparability, recyclability, and environmental impact.
A key tool is the Digital Product Passport (DPP). In the future, this passport will accompany products and digitally demonstrate important sustainability information, such as material composition, carbon footprint, and traceability. It will be accessible via technologies such as QR codes or RFID. The DPP will be mandatory for products manufactured, traded, and imported in the EU.
In April 2025, the European Commission published the first ESPR implementation work plan for 2025–2030. It identified the first product groups that environmental design requirements and DPPs will be developed for. It also includes horizontal requirements that apply to similar product groups.
The ESPR requirements were implemented through delegated acts of the EU Commission – either for individual products, including end products and intermediate products, or in the form of horizontal measures that apply to groups of similar products:
The Commission is setting up specific working groups for each prioritized product group and horizontal measure. These groups will support the development of delegated acts, including preliminary studies, stakeholder consultations, and impact assessments. The first list of prioritized products was established in April 2025. At the same time, the Commission made it clear that further working groups would follow. The aim is to cover the majority of products available on the EU market.
The product groups were selected through a technical analysis and broad consultations, including with Member States and the Ecodesign Forum. Key criteria were environmental and climate impact, circularity potential, market relevance, and alignment with policy objectives such as the Green Deal.
The prioritized product groups and horizontal measures according to the ESPR work plan (2025–2030) are:
Note: The years in parentheses indicate when the requirements for the respective product groups are expected to come into force.
Final products:
Intermediate products:
Horizontal measures:
In addition, other energy-related products such as dishwashers, refrigerators, chargers for electric vehicles, and smartphones are covered by ongoing or planned acts.
Each delegated act will contain two main types of requirements: information requirements and performance requirements.
The ESPR does not replace existing product regulations, but supplements them where sustainability aspects have not yet been sufficiently taken into account. For example, construction products remain primarily regulated by the revised Construction Products Regulation (CPR). However, the ESPR can act as a safety net—especially for intermediate products or when CPR sustainability targets are not met.
Batteries are also already subject to regulation, falling under the Battery Regulation (EU 2023/1542), which mandates a battery passport for electric vehicle and industrial batteries from 2027. This will be fully compatible with the DPP framework. For electronic products, existing ecodesign and energy labeling requirements will be integrated into the DPP in the future.
Ecodesign is more than just a legal requirement. It opens up opportunities for value creation, innovation, and business resilience. Sustainable product design means that fewer materials and less energy are needed, products last longer, and less waste is generated. This results in efficiency gains, lower risks, and more robust supply chains.
At the same time, ecodesign promotes new business models—such as product-as-a-service, remanufacturing, and repair services. It responds to growing customer demand for transparency, durability, and responsible sourcing.
Companies that embrace eco-design early on strengthen their brand reputation, differentiate themselves from the competition, and are more likely to attract investment. Sustainability is no longer a niche issue, it is becoming a key purchasing criterion.
Is the ESPR relevant for you? We are happy to support you with our in-depth expertise in environmental assessment of products and implementation of regulatory requirements. Even though details on the practical implementation of the regulation are still being worked out, now is the right time to set the course for a future-proof product strategy. We provide step-by-step support for the following challenges:
The EU ESPR regulation replaces the previous Ecodesign Directive and broadens the focus to include environmentally friendly product design with a focus on durability, reparability, and recyclability. A key element is the digital product passport, which provides important sustainability data in digital form. ESPR requirements for the first prioritized products will come into force in 2026.
However, companies should already start preparing with corporate carbon footprints (CCF) and product carbon footprints (PCF) in order to ready themselves for the new information and performance requirements. Early implementation brings a clear regulatory strategy, a reliable database, targeted communication with suppliers, and careful implementation planning.
