ESPR

The Ecodesign for Sustainable Products Regulation (ESPR) is the EU framework for setting ecodesign requirements for sustainable products. It supports the transition to a circular economy by encouraging products that last longer, are easier to repair and recycle, and provide clearer sustainability information, including through the Digital Product Passport (DPP).

• Regulation (EU) 2024/1781 entered into force on 18 July 2024 and repeals Directive 2009/125/EC.
• ESPR is a framework regulation. Product-specific requirements will be introduced gradually through delegated acts.
• The scope has expanded from energy-related products to a wider range of physical goods. Food, feed and medicinal products are generally excluded.
• Key topics include durability, repairability, upgradability, recyclability, recycled content, resource efficiency, environmental footprint and product information disclosure.
• The Digital Product Passport (DPP) will help make product sustainability information more transparent, standardised and traceable across the value chain.
• Businesses should start reviewing product categories, materials and supply chain data, and strengthen product data management capabilities for future DPP requirements.

ESPR is the EU framework regulation for setting ecodesign requirements for sustainable products. It aims to improve resource efficiency, circularity and environmental performance throughout a product’s lifecycle, from design and manufacturing to use, repair, recycling and end-of-life management.

ESPR goes beyond traditional product testing. It encourages businesses to look at product design, material sourcing, supply chain data, environmental performance and product information as one connected compliance system.

ESPR is a framework regulation. This means that not all products will be subject to the same requirements at once. The European Commission will set product-specific rules through working plans, preparatory studies and delegated acts, based on product category, environmental impact and policy priorities.

In practice, businesses should not wait for product-specific delegated acts to be published before taking action. If your products are in sectors likely to be prioritised by the EU, it is worth reviewing materials, supply chain data, test reports, carbon footprint information and recycling data early. This can help reduce cost and pressure when future requirements take effect.

Therefore, ESPR is not a regulation only for electronics. It is a key EU framework for sustainable product design and the circular economy across different industries. Businesses should continue to monitor whether their products are included in future Working Plans and product-specific Delegated Acts

With the European Commission’s ESPR 2025–2030 Working Plan now published, the EU will first develop ecodesign requirements for selected product groups and gradually roll out product information tools such as the Digital Product Passport (DPP).

According to the Working Plan, the first priority product groups include textiles, furniture, tyres, mattresses, iron and steel, and aluminium. Related work is expected to move forward gradually from 2026. ESPR also includes two important horizontal requirements: repairability, and recycled content and recyclability for electrical and electronic equipment.

Companies involved in these product supply chains should start reviewing product data, material information and sustainability performance early, so they are better prepared for future compliance requirements.

• Iron and Steel | Delegated Act Expected in 2026

  Iron and steel are among the intermediate products expected to move forward earlier under the Working Plan, with related requirements expected in 2026.

  Future requirements may cover climate change, energy and water use, air emissions, material efficiency and supply chain resilience. In addition to product environmental information, companies in the iron and steel sector should also pay attention to material origin and the completeness of supply chain data.

• Textiles | Delegated Act Expected in 2027

  Textiles, especially apparel, are one of the priority product groups. Related requirements are expected to move forward in 2027.

  Future requirements may focus on product durability, material efficiency, recycled content and environmental information, and may also be linked to DPP product information requirements.

  For brands and manufacturers, it is important to understand not only product design, but also raw material sources, recycled content and product lifecycle information.

• Tyres | Delegated Act Expected in 2027

  Tyres are expected to be addressed under future ecodesign requirements in 2027.

  Future requirements may focus on material efficiency, recyclability, recycled content and end-of-life tyre management. Companies can start by checking the sources of recycled materials and whether related product information is traceable.

• Aluminium | Delegated Act Expected in 2027

  Aluminium is also one of the priority intermediate products, with related requirements expected to move forward in 2027.

  Future requirements may focus on climate change, energy and water use, air emissions and the efficient use of raw materials. In particular, the use of recycled aluminium and information on material origin may become important for product environmental and material management.

• Furniture | Delegated Act Expected in 2028

  Furniture products are expected to be addressed in 2028. The main focus may be on extending product life, reducing waste and improving material circularity.

  Future requirements may cover product durability, repair, disassembly, recycling and material information, which may affect product design and material management across the furniture supply chain.

• Mattresses | Delegated Act Expected in 2029

  Mattresses are expected to be addressed in 2029. Because mattresses often contain many different materials and can be difficult to disassemble and recycle, future requirements may focus on reducing waste, extending product life and improving material efficiency.

  ---

  In addition to these six priority product groups, the ESPR Working Plan also includes two important horizontal requirements. These requirements may apply across different product groups, not only to one specific type of product.

  2027 | Repairability

  The EU is expected to introduce cross-product repairability requirements, potentially covering consumer electronics and small household appliances. Companies in the electrical and electronics sector should start paying attention to product repair, spare parts availability and product lifetime information.

  2029 | Recycled Content and Recyclability of Electrical and Electronic Equipment

  Another important horizontal requirement focuses on recycled content and recyclability of electrical and electronic equipment. ICT products are included in the preparatory work for this requirement.

  Businesses should not only check whether their products are listed as priorities. They should also start building systems for managing material data, carbon data, recycled content information and supply chain data, so they are ready for future ESPR and DPP requirements.

At the heart of ESPR is the creation of sustainable product design requirements. Future product-specific Delegated Acts may set detailed requirements in the areas below. Businesses can use this table as a starting point to review their internal data and supply chain capabilities.

The Digital Product Passport (DPP) is one of the core tools under ESPR. It can be understood as a digital record for a product, designed to store and share key lifecycle information. This helps brands, manufacturers, repairers, recyclers, consumers and public authorities access product sustainability information in a more transparent, standardised and traceable way.

ESPR will gradually shift product compliance from single-material or hazardous substance checks towards lifecycle-based sustainability management. Businesses may need stronger capabilities in product design, material sourcing, supply chain data, environmental performance and digital product information.

1. Check whether your products fall under the product groups prioritised by the EU under ESPR, and follow the progress of the Working Plan and Delegated Acts.
2. Build a product materials and substances database, including BOMs, supplier declarations, test reports and restricted substance information.
3. Collect existing sustainability data, such as recycled content, product carbon footprint, life cycle assessment, energy efficiency and recycling information.
4. Review whether product design supports durability, repairability, disassembly, upgradability and recyclability.
5. Plan the data fields, data sources, update frequency and responsibilities needed for the Digital Product Passport.
6. Work with a third-party verification body to check whether testing, audits, environmental data and compliance documents are sufficient to support future regulatory requirements.

As ESPR broadens product compliance from chemical testing to sustainable design, supply chain data and digital product information, SGS brings together global technical resources to support businesses. We help you review product applicability, material testing needs, ecodesign considerations, recycled material verification, carbon footprint data and DPP data structures, so your organisation can prepare a more robust response strategy.