The EU Ecodesign Regulation for Sustainable Products (ESPR) aims to promote sustainable and innovative products and sets in motion a market mechanism in the EU internal market that clearly favors these products. It replaces the previous Ecodesign Directive (2009/125/EC) and significantly extends its scope - for example to textiles, electronics and many other product groups.
The aim is not only to reduce environmental impacts, but also to create fair competitive conditions for companies in the EU and help shape global sustainability standards. In this article, you will find out whether your products are directly or indirectly affected and what specific requirements are placed on these products.
Current schedule for the affected product categories
It is already clear when the requirements of the Ecodesign Regulation will apply to the first end products, intermediate products and horizontal requirements. In this context, end products are defined as goods that are sold directly to consumers - such as clothing, furniture, tires or mattresses. The ESPR defines specific ecodesign requirements for these product groups.Intermediate products are industrial primary products such as iron, steel or aluminum that are used in further manufacturing processes. Environmental requirements are also to be defined for them, for example with regard to the carbon footprint or the proportion of recycled material.
Horizontal requirements, on the other hand, are rules that apply across all products within a category or sector, such as repairability: instead of making separate regulations for each individual electronic device, a horizontal requirement on repairability would apply to all electronic products - e.g. smartphones, laptops and washing machines alike. This differs from vertical requirements, which only apply to one specific product.
End products:
- 2027: Textiles / Clothing
- 2027: Tires
- 2028: Furniture
- 2029: Mattresses
Intermediate products:
- 2026: Iron and steel
- 2027: Aluminum
Horizontal requirements:
- 2027: Repairability (incl. repair score) for consumer electronics and small household appliances
- 2029: Recyclate content & recyclability of electrical and electronic appliances
The above-mentioned categories will be given priority and the timetable for their introduction has already been set. However, the ESPR applies in perspective to almost all physical products made available or put into service on the EU market, with exceptions only for certain categories such as food or medical devices, where ecodesign requirements are either impractical or already covered by other regulations.
The products that could follow the first wave are cleaning agents, paints and lubricants. Shoes were initially excluded. However, due to their environmental impact, a study is already underway to investigate the potential for ecological improvement of footwear as part of the ESPR - with results by the end of 2027. Chemicals are also currently excluded. Due to their complexity, a study will be launched by the end of2025 to examine how they could be integrated into the ESPR in the future.
What are the requirements for the products concerned?
The ESPR forms the legal basis for setting ecodesign requirements - but these will vary depending on the product category. This means that each product category will have its own specific requirements. These requirements will be based on 4 overarching categories:
Requirement 1: Product design
In future, products made available on theEU market will have to meet 9 specific ecodesign requirements.
1. durability and reliability
2. reusability
3. upgradability, reparability, maintenance and refurbishment
4. avoidance of substances of concern
5. energy and resource efficiency
6. recycled content
7. reprocessing and recyclability
8. CO₂ and environmental footprint
9. waste generated over the product life cycle
These requirements are intended to make products more sustainable, durable and recyclable. Limits are successively set for these categories which they may not fall below or exceed.
Requirement 2: Digital Product Passport (DPP)
The Digital Product Passport is a central element of the ESPR and makes ecodesign requirements transparent and feasible along the entire value chain. It contains relevant information such as material composition, CO₂, pollutants, repair and recycling information - available to companies, authorities and consumers. The DPP will be mandatory for almost all regulated products, with the exception of energy-related products, which will continue to use the energy label (EPREL).
Technical requirements for the Digital Product Passport:
- Data carrier (e.g. QR code or NFC tag) with unique product identifier
- Attachment to product, packaging or accompanying documents
- Standardized format according to ISO/IEC 15459:2015
- Machine-readable & interoperable
The DPP connects data, processes and actors - and makes sustainable products realizable in practice. The DPPs are made accessible in a central EU register. They can be viewed and verified there. This portal should be available to consumers, authorities and companies by July 2026.
Requirement 3: Waste avoidance for unsold products
The ESPR obliges companies to be more transparent in their handling of unsold products and to reduce waste.
In future, companies will have to make public disclosures:
- The amount of unsold consumer products disposed of
- The reasons for their disposal
- The disposal methods used, in accordance with the waste hierarchy (e.g. reuse before destruction)
The regulation gives the EU the option of introducing a ban on the destruction of unsold products, but the current work plan does not yet make use of this option - the Commission is initially waiting for data from the new disclosure obligations in order to be able to justify future bans in a targeted manner.
Requirement 4: Criteria for green public procurement
The ESPR enables the EU to set binding minimum requirements for public procurement. This means that public bodies such as authorities could be obliged to purchase particularly environmentally friendly products - provided this makes economic sense.
For the products prioritized in the current work plan, the EU Commission is examining whether procurement criteria should also be defined in addition to the ecodesign requirements.
In the case of energy-related products, public procurement is already linked to their energy efficiency - for example via energy consumption labeling or the Energy Efficiency Directive.
Conclusion for industrial companies:
The ESPR and the Digital Product Passport mark a profound change for industrial companies in the EU. They create a clear framework for sustainable product design, require greater transparency along the supply chain and set new standards for the recyclability of products. Even if the application period is staggered, affected companies should prepare now for the upcoming requirements - especially in prioritized product groups such as textiles, furniture or metals.
The digital product passport is becoming a key tool in this process: it makes environmental and material data visible and accessible - for authorities, business partners and consumers. Companies that invest in systematic data management, ecodesign optimization and digital infrastructure at an early stage not only ensure regulatory compliance, but also a competitive advantage in an increasingly sustainability-oriented domestic market.
The ESPR is not just a compliance issue - it is an opportunity to strategically develop sustainable industrial processes and products.
