ESPR and Digital Product Passport
The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR) creates an EU framework for sustainable products: it allows product-group requirements on durability, reparability and circularity, and makes the underlying data visible through a Digital Product Passport.
The Ecodesign for Sustainable Products Regulation – Regulation (EU) 2024/1781, known as the ESPR – entered into force on 18 July 2024 and replaces the earlier Ecodesign Directive 2009/125/EC. Unlike its predecessor, it is not limited to energy-related products: in principle it covers almost every physical good placed on the EU market, with carve-outs for food and feed, medicinal products, living organisms and type-approved vehicles, among others. The ESPR is a framework regulation, which means that concrete obligations only arise once the European Commission adopts a delegated act for a specific product group. The first working plan (April 2025) names iron and steel, aluminium, textiles – especially apparel and footwear –, furniture, tyres and mattresses as priority groups, alongside horizontal requirements on the reparability of electronics and ICT products.
The Commission can set two kinds of rules: performance requirements and information requirements. Performance requirements cover durability and reliability, reparability and spare-part availability, upgradability and reusability, recycled content and recyclability, energy and resource efficiency, and a product's carbon and environmental footprint. Information requirements concern matters such as substances of concern, repair instructions or expected lifetime. In addition, the ESPR restricts the destruction of unsold consumer products: for textiles and footwear the ban applies to large companies from 19 July 2026, medium-sized companies follow later and micro-enterprises are exempt. Companies must also disclose the type and volume of unsold goods they discard.
The key implementing instrument is the Digital Product Passport (DPP, Chapter III of the ESPR, Art. 9 et seq.). It links each covered product, batch or model – via a data carrier such as a QR code, barcode or NFC tag – to a structured, machine-readable data set covering material composition, origin, repair and end-of-life instructions and sustainability metrics. Access is tiered: consumers, repairers, recyclers, market surveillance authorities and customs each see the scope intended for them, and an EU registry plus a web portal are meant to make passports findable. Which product group needs a passport, and when, is decided by the respective delegated act; first applications are expected from roughly 2027/2028, but the timelines are not fully fixed and may shift – as the EU simplification and Omnibus debate illustrates. For companies the practical consequence is the same either way: product-level sustainability data has to be collected, evidenced and maintained across the entire value chain – the very same data base that ESRS E5 (Circular economy) reporting and credible environmental claims depend on.
Legal Basis
Regulation (EU) 2024/1781 (ESPR), in particular Art. 4–6 (ecodesign requirements) and Chapter III, Art. 9 et seq. (Digital Product Passport); complemented by ESRS E5 (Circular economy) and the European Commission ecodesign working plans
Practical Example
A sustainability manager at a mid-sized furniture manufacturer sees furniture listed as a priority group in the first ESPR working plan and starts preparing without waiting for the final delegated act. She begins by mapping the data situation for the three highest-revenue product families: what are the parts made of, how much recycled content is in the particleboard, which fittings are available as spare parts and for how long, which substances of concern are in the lacquers and adhesives? Because suppliers only deliver parts of that information today, she adds a data clause to the supplier code of conduct and builds the request into supplier assessments. In parallel she works with IT to check whether the item master data in the ERP system can be extended with DPP-ready fields and who owns their upkeep. Six months later the outcome is a documented data-gap list with owners and deadlines – plus a repair guide per product family that also turns the marketing claim "durable and repairable" into something the company can actually evidence.