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If you sell physical products in the EU, the Ecodesign for Sustainable Products Regulation (ESPR) — officially Regulation (EU) 2024/1781 — is already in force and its obligations are starting to bite. Published in the EU Official Journal on 28 June 2024, ESPR replaces the old Ecodesign Directive (2009/125/EC) and extends its reach far beyond energy-related appliances to cover almost every physical product on the EU market. The first concrete deadline, a ban on the destruction of unsold clothing and footwear for large enterprises, applied from 19 July 2026. Product-specific ecodesign rules and Digital Product Passport (DPP) requirements follow in waves through 2030. Whether you manufacture in Europe or import into it, this regulation affects how your products are designed, documented, and tracked. This guide explains exactly what ESPR requires, who it applies to, what the DPP means in practice, and what your operations team should be doing right now to stay ahead of the compliance curve.
🗝 Key Takeaways
- ESPR is already in force: Regulation (EU) 2024/1781 entered into force on 18 July 2024. The first obligations for large enterprises applied from July 2026.
- Scope is near-universal: Unlike its predecessor, ESPR covers almost all physical products placed on the EU market, not just energy-related ones. Only food, feed, medicinal products, and a handful of defence-related categories are excluded.
- Two types of requirements: Performance requirements (durability, repairability, recycled content, energy efficiency) and information requirements (principally the Digital Product Passport).
- The DPP is mandatory infrastructure: The Digital Product Passport, a machine-readable digital record linked to each product via QR code or RFID, will be compulsory once the relevant delegated act for your product group comes into force.
- Data readiness is the real deadline: Most product-specific rules won't be enforceable until 2028 or later, but building the product data infrastructure ESPR requires takes 12–18 months minimum. Start now.
📋 In this article
- What Is the ESPR Regulation?
- How ESPR Differs from the Old Ecodesign Directive
- What ESPR Actually Requires: Performance and Information Obligations
- The Digital Product Passport (DPP) Explained
- Which Products Are in Scope and When
- The Ban on Destroying Unsold Products
- How to Prepare for ESPR Compliance
- What ESPR Means for E-Commerce Logistics Teams
What Is the ESPR Regulation?
The Ecodesign for Sustainable Products Regulation (ESPR) is a framework regulation adopted by the European Parliament and Council on 13 June 2024. It establishes the legal basis for the EU to set binding sustainability and performance requirements for almost any physical product placed on the EU market, and it introduces the Digital Product Passport as a mandatory information tool.
The key word is "framework." ESPR does not specify every requirement upfront for every product. Instead, it creates the machinery, the operating system, through which the European Commission adopts delegated acts: secondary legislation that defines ecodesign requirements group by group, based on technical assessments. Think of ESPR as the constitutional layer and the delegated acts as the laws that flow from it.
The regulation's scope is deliberately broad. According to the regulation text, ESPR applies to any physical goods placed on the market or put into service, including components and intermediate products. The only significant exclusions are food, feed, medicinal products, and products covered exclusively by sector-specific legislation (such as motor vehicles, which fall under separate EU rules). If you manufacture, import, or distribute physical goods in or into the EU, ESPR almost certainly applies to some part of your portfolio.
The regulation is a central pillar of the EU's European Green Deal and Circular Economy Action Plan. Its stated aim: to make sustainable products the norm in the EU rather than the exception.
When did ESPR enter into force?
ESPR was published in the EU Official Journal on 28 June 2024 and entered into force on 18 July 2024. However, its obligations phase in over several years via delegated acts. The first concrete obligation for large enterprises — a ban on destroying unsold clothing and footwear — applied from 19 July 2026. Product-specific ecodesign requirements and DPP mandates follow on a rolling timetable from 2026 through 2030 and beyond.
Who must comply with ESPR?
ESPR applies to all economic operators placing products on the EU market: manufacturers (EU and non-EU), authorised representatives, importers, and distributors. Crucially, it applies regardless of where the product is made. If a product is sold in the EU — whether by a German manufacturer, a Chinese exporter, or a US brand — it must comply with the applicable ecodesign requirements and eventually carry a DPP once the relevant delegated act is in force.
How ESPR Differs from the Old Ecodesign Directive
To understand what ESPR demands, it helps to understand what came before it. The original Ecodesign Directive (2009/125/EC) applied exclusively to energy-related products: household appliances, lighting, motors, boilers, and similar equipment. It was effective within its narrow scope, but washing machines, furniture, textiles, and most consumer goods were simply not covered.
ESPR makes three fundamental changes:
Covered energy-related products only. Focused on energy efficiency. No Digital Product Passport requirement. No ban on destroying unsold goods. Paper-based compliance documentation. Did not address repairability, recycled content, or circularity systematically.
Covers almost all physical products. Addresses durability, repairability, recycled content, carbon footprint, and substances of concern alongside energy efficiency. Introduces the mandatory Digital Product Passport. Bans destruction of unsold clothing and footwear. Adds green public procurement obligations.
There is no regulatory gap between the two regimes. Since ESPR's entry into force in July 2024, a transition period lasting until 2030 keeps the old Ecodesign Directive operating for products already regulated under it, while ESPR progressively takes over for those categories and extends to new ones. The European Commission's Ecodesign Forum manages the transition and stakeholder consultation process.
The 20 product parameters ESPR can regulate
ESPR defines up to 20 product parameters that delegated acts can set requirements for. These are listed in Annex I of the regulation and include: durability, reliability, and repairability; energy and resource efficiency; recycled content; carbon and environmental footprint; substances of concern; waste generation; and end-of-life handling. Not every parameter applies to every product group. Each delegated act selects the parameters most material to that category.
A common misconception is that ESPR is a manufacturing regulation that only applies to factories within the EU. It is not. ESPR is a market access regulation. Any product placed on the EU market, regardless of where it was manufactured, must comply with the applicable ecodesign requirements once the relevant delegated act is in force. Non-EU brands selling into Europe via e-commerce, marketplace channels, or direct distribution are fully in scope. Non-compliance can result in products being blocked from the EU market entirely.
What ESPR Actually Requires: Performance and Information Obligations
ESPR delegates the specifics to product-level delegated acts, but the regulation defines two categories of requirements those acts can impose on any given product group.
Performance requirements
Performance requirements set minimum thresholds products must meet before they can be placed on the EU market. Depending on the product group, these can cover:
| Performance Parameter | What It Means in Practice | Example Application |
|---|---|---|
| Durability & reliability | Minimum lifespan, resistance to wear | Smartphones: battery retention ≥80% after 800 cycles |
| Repairability | Accessible spare parts, repair documentation | Electronics: spare parts available within 5–10 working days for 7 years |
| Recycled content | Minimum % of recycled materials by weight | Textiles: minimum recycled fibre requirements (to be set in delegated act) |
| Energy & resource efficiency | Maximum energy or water consumption | Household appliances: EU Energy Label classes |
| Carbon footprint | Lifecycle CO₂e disclosure, expressed in kg per lifecycle stage | Steel: embodied carbon declaration per tonne |
| Substances of concern | Restrictions on chemicals that hinder circularity | Textiles: limits on certain dyes and flame retardants |
Information requirements and the role of product data
Information requirements mandate that products carry specific data that is accessible to consumers, business customers, authorities, and recyclers. The principal mechanism is the Digital Product Passport, but information requirements can also include labelling, documentation for repair professionals, and end-of-life instructions. The regulation is clear that information requirements can be set for any parameter in Annex I regardless of whether a performance requirement exists for that same parameter.
According to the Environmental Coalition on Standards (ECOS), up to 80% of a product's environmental impacts are determined at the design stage. This is why the regulation focuses on design-stage decisions rather than end-of-pipe controls. By the time a product reaches a warehouse or a customer's doorstep, most of its lifecycle footprint is already locked in.
Does ESPR affect how your orders ship and what documentation you carry?
ShippyPro helps e-commerce and logistics teams manage multi-carrier shipping, tracking, and compliance documentation across 190+ carriers in one platform.
The Digital Product Passport (DPP) Explained
The Digital Product Passport is ESPR's most consequential new requirement for most product companies. It is a structured digital record attached to each product, typically accessible via a QR code, NFC chip, or RFID tag, that stores sustainability and compliance data throughout the product's lifecycle. The DPP must be machine-readable and comply with standardised data formats defined in the relevant delegated act.
What data does a DPP contain?
The exact data fields vary by product group and will be specified in each delegated act. However, the regulation's framework indicates that a DPP is expected to cover:
| Data Category | Examples | Who Uses It |
|---|---|---|
| Material composition | Fibre content, alloy grade, polymer type | Recyclers, customs, consumers |
| Environmental performance | Carbon footprint (kg CO₂e per lifecycle stage), energy class | Buyers, market surveillance, public procurement |
| Durability & repairability | Expected lifespan, repairability score, spare parts availability | Consumers, independent repairers |
| Substances of concern | Identity, location in product, concentration, safe handling | Recyclers, waste treatment operators, authorities |
| End-of-life instructions | Disassembly guide, recycling stream, hazardous component location | Waste operators, consumers |
| Supply chain provenance | Manufacturing location, upstream material sources | Customs, due diligence auditors |
The EU DPP Registry
The DPP Registry, a centralised EU infrastructure managed by the European Commission, began its technical roll-out in mid-2026. It is the backbone that links individual product passports to a verifiable, publicly accessible record. All DPPs must be registered, and the EU Registry stores the identifiers and access metadata even where the underlying product data is held by the manufacturer's own systems. For e-commerce operators shipping products across the EU, this means customs and market surveillance authorities will increasingly be able to scan a product's QR code and verify compliance status in real time.
DPP vs. Life Cycle Assessment (LCA): what's the difference?
A Life Cycle Assessment is the scientific methodology used to calculate a product's environmental impact across all stages, from raw material extraction through manufacturing, transport, use, and end of life. A Digital Product Passport is the secure digital infrastructure that carries that LCA data, along with other required information, permanently linked to a specific physical product. Think of the LCA as the analysis; the DPP is the auditable, machine-readable record of that analysis.
Companies that build their DPP infrastructure early gain a data advantage they can use for green public procurement bids, sustainability reporting (CSRD), buyer due diligence requests, and brand differentiation. The product data you collect to satisfy ESPR's information requirements is the same data that substantiates environmental claims under the EU Green Claims Directive. One investment, multiple uses.
Which Products Are in Scope and When
The European Commission published its first ESPR and Energy Labelling Working Plan in April 2025. This five-year plan (2025–2030, with a review in 2028) identifies the priority product groups that will receive delegated acts first. It does not regulate all products simultaneously: it sequences them by environmental impact, market size, and technical readiness.
ESPR enters into force (July 2024). Ecodesign Forum established. First ESPR Working Plan adopted (April 2025). Delegated act for iron and steel adopted (2026). Destruction ban applies to large enterprises for clothing and footwear (July 2026). DPP Registry launches (mid-2026).
Delegated act for textiles and apparel targeted for Q2 2027. Horizontal repairability rules (consumer electronics, small household appliances) targeted for 2027. Large enterprises begin mandatory disclosure of unsold product destruction volumes (February 2027 reporting cycle).
Delegated acts for aluminium and tyres targeted for 2027 (compliance ~2029). Fridges and freezers, electric vehicle chargers, and electric motors targeted for 2028. Recycled content and recyclability rules for electronics targeted for 2029.
Furniture delegated act targeted for 2028 (compliance ~2030). Mobile phones and tablets targeted for 2028–2030 (compliance 2030+). Mattresses targeted for 2029 (compliance ~2031). Commission mid-term review in 2028 may add further product groups including footwear, paints, detergents, and chemicals.
Medium-sized enterprises come under the destruction ban for clothing and footwear (July 2030). The Ecodesign Directive transition period ends. ESPR fully replaces the old Directive as the sole framework for all covered product groups.
ESPR priority product groups at a glance
| Product Group | Delegated Act (est.) | Compliance Deadline (est.) | Key Requirements Expected |
|---|---|---|---|
| Iron & Steel | 2026 | ~2028 | Recycled content, carbon footprint declaration |
| Textiles & Apparel | Q2 2027 | ~Late 2028/2029 | Recycled fibre content, durability, substances of concern, DPP |
| Aluminium | 2027 | ~2029 | Recycled content, energy in production |
| Tyres | 2027 | ~2029 | Durability, rolling resistance, recycled rubber content |
| Dishwashers | 2026 | ~2027 | Energy class update under Ecodesign Directive transition |
| Furniture | 2028 | ~2030 | Material sourcing, durability, repairability, DPP |
| EV Chargers | 2028 | ~2029 | Interoperability, energy efficiency, durability |
| Mobile Phones & Tablets | 2028–2030 | 2030+ | Repairability, software longevity, battery performance, DPP |
| Mattresses | 2029 | ~2031 | Material composition, durability, recycled content |
Timelines are indicative. Each delegated act includes a minimum 18-month transition period. Based on current regulatory patterns, 6–12 month slippage from target dates is possible.
The Ban on Destroying Unsold Products
One of ESPR's most immediate obligations does not wait for delegated acts. Article 23 of the regulation imposes a general duty on all economic operators to take reasonable measures to prevent the destruction of unsold consumer products. Article 25 goes further, setting out specific prohibitions by company size and product type.
Who is affected and when?
From 19 July 2026, large enterprises are prohibited from destroying unsold clothing, clothing accessories, and footwear listed in Annex VII of the regulation. Medium-sized enterprises have until 19 July 2030. Micro and small enterprises are permanently exempt from this prohibition.
The European Commission adopted a delegated regulation on derogations in February 2026, defining 10 permitted circumstances under which destruction may still take place, including products that are dangerous, non-compliant with law, damaged beyond economical repair, or have manufacturing defects that make them unsaleable.
The disclosure requirement for unsold goods
Alongside the destruction ban, a disclosure obligation applies. Large companies must publicly report, on their website, the quantity of unsold consumer products they discard each financial year. This reporting starts from the first full financial year after the implementing act's date of application, which the Commission confirmed is February 2027. The information must be published in the standardised format set by the implementing act.
Micro and small enterprises are exempt from the Article 25 destruction ban. However, they are still subject to the general duty in Article 23 to take reasonable measures to prevent unnecessary destruction of unsold goods. More significantly, once a delegated act for their product group is in force, SMEs are subject to the same product performance and DPP information requirements as large enterprises, unless the delegated act specifies SME derogations. Always check the specific delegated act for your product category.
How to Prepare for ESPR Compliance
ESPR's phased rollout gives product companies time. But the companies that treat "no immediate deadline" as "no urgency" will find themselves rebuilding their product data infrastructure from scratch under deadline pressure. The data requirements underpinning ESPR compliance, structured product records, supplier data, substances inventories, LCA datasets, typically take 12–18 months to build properly.
Identify which of your products fall into the priority categories in the Working Plan. Textiles, steel-containing products, electronics, furniture, and tyres are first in scope. Flag anything that uses these as primary materials.
If you are a large enterprise, the destruction ban applied from July 2026. Review your processes for handling unsold inventory, document all permitted derogations, and ensure your disclosure reporting system is operational in time for the February 2027 reporting cycle.
The DPP requires standardised, machine-readable product data: material composition, substances of concern, environmental performance indicators, and more. Centralising and structuring this data is the most important step, and it pays off immediately for existing obligations under CSRD, REACH, and GPSR too.
ESPR's information requirements mandate disclosure of substances of concern: their identity, location in the product, concentration, and safe handling instructions. Collecting this data from suppliers typically takes months. Start the supplier outreach process early.
Subscribe to the European Commission's Ecodesign Forum and track the progress of delegated acts for your product groups. Each delegated act defines the exact requirements; staying ahead means knowing what's coming before the 18-month transition period starts.
What ESPR Means for E-Commerce Logistics Teams
Most ESPR commentary focuses on product design and manufacturing. But the regulation has real implications for logistics, operations, and e-commerce teams too, particularly for brands that import into the EU or run cross-border fulfilment.
Customs and border documentation
Once DPP requirements are in force for a product group, EU customs authorities will be able to verify DPP compliance as part of customs clearance. The regulation explicitly states that the DPP must be accessible to customs authorities, and the EU DPP Registry links to customs systems. For importers shipping in volume, this creates a new layer of pre-shipment documentation: the DPP identifier must be correctly declared alongside existing customs data. An integrated multi-carrier shipping platform that connects your warehouse management, customs documentation, and carrier booking workflows becomes operationally valuable well before your first DPP deadline.
Returns, end-of-life obligations, and reverse logistics
ESPR's focus on product end-of-life has knock-on effects for returns logistics. As repairability requirements come into force, consumers gain stronger rights to repair, which affects how returns need to be triaged: repair, refurbish, resell, recycle, or discard. Logistics teams that currently treat all returns as binary (restock or write off) will need more granular returns workflows. ShippyPro's Easy Return feature supports returns management for orders originally shipped via ShippyPro, giving operations teams better visibility over return volumes and carrier performance across their return flows.
Packaging and carrier considerations
ESPR interacts with the separate Packaging and Packaging Waste Regulation (PPWR), which sets its own recycled content and recyclability requirements for packaging materials. While ESPR does not directly regulate packaging, companies managing both sets of obligations simultaneously will benefit from centralised visibility over their outbound shipment data. Tracking and shipment visibility tools that cover all your carriers also give you the data trail regulators may ask for when auditing cross-border logistics compliance.
Automation as a compliance tool
ESPR compliance is ultimately a data management challenge. The same automation capabilities that reduce manual errors in shipping, from order-level carrier assignment to label generation to customs document production, reduce the risk of incomplete or inconsistent product data reaching the market. ShippyPro's AI Shipping Automation uses trigger-condition-action workflows to manage shipping rules at scale, helping operations teams maintain consistent process execution across high volumes without manual intervention at each order. For teams preparing for ESPR, consistent process execution across fulfilment is the operational foundation that makes DPP data accuracy possible.
Managing carrier performance, costs, and compliance documentation at scale is also easier with analytical insight. ShippyPro's Optimizer gives logistics managers historical cost and performance data by carrier and geography, helping teams make informed decisions about which carriers to use for which product categories and regions as ESPR compliance requirements evolve.
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Connect 190+ carriers, generate labels, and manage your entire shipping operation in one place. Built for mid-market e-commerce teams managing cross-border EU compliance.
Explore the Platform →Easy Return
Manage returns for orders shipped via ShippyPro with automated label dispatch and returns portal functionality. Supports the more granular return triage workflows ESPR's repairability rules will require.
See Easy Return →AI Shipping Automation
Build trigger-condition-action shipping rules that execute at order level without manual intervention. Maintain consistent, auditable process execution across high-volume fulfilment.
Explore Automation →ESPR Official Regulation Text
Read Regulation (EU) 2024/1781 in full on EUR-Lex, the authoritative source for all EU legislation. The consolidated text includes all corrigenda.
Read on EUR-Lex →EU Ecodesign Forum (EC Green Forum)
The European Commission's official implementation hub for ESPR, including the Working Plan, delegated act timelines, and the Ecodesign Forum stakeholder consultation updates.
Visit Ecodesign Forum →ShippyPro Resources
Guides, webinars, and regulatory updates for e-commerce logistics teams managing EU compliance across multiple markets and carriers.
Explore Resources →What is ESPR and when does it apply?
ESPR (Ecodesign for Sustainable Products Regulation) is EU Regulation 2024/1781, which entered into force on 18 July 2024. It replaces the old Ecodesign Directive and extends ecodesign rules to almost all physical products sold in the EU. Obligations phase in gradually via delegated acts: the first concrete deadline (destruction ban on unsold clothing and footwear for large enterprises) applied from 19 July 2026. Product-specific requirements roll out between 2026 and 2030 depending on product category.
Does ESPR apply to companies outside the EU?
Yes. ESPR is a market access regulation, not a manufacturing regulation. Any product placed on the EU market — whether manufactured in the EU or imported from a third country — must comply with the applicable ecodesign requirements once they are in force for that product group. Non-EU brands selling into Europe via e-commerce, marketplace channels, or distribution partners are fully in scope. Non-compliance can result in products being blocked from the EU market or removed from sale by national market surveillance authorities.
What is the Digital Product Passport (DPP) under ESPR?
The Digital Product Passport is a structured, machine-readable digital record attached to each product, typically accessible via a QR code, NFC chip, or RFID tag. It stores sustainability and compliance data — material composition, environmental performance, substances of concern, repairability information, and end-of-life instructions — throughout the product's lifecycle. The DPP is accessible to consumers, businesses, customs authorities, and recyclers. Its exact data requirements are defined in each product-specific delegated act. The EU DPP Registry, the central infrastructure underpinning the system, began its technical roll-out in mid-2026.
Which products are covered by ESPR first?
The first ESPR Working Plan (2025–2030) prioritises iron and steel (delegated act 2026), textiles and apparel (2027), aluminium and tyres (2027), dishwashers (2026), furniture (2028), fridges and EV chargers (2028), and mobile phones and tablets (2028–2030). Energy-related products currently regulated under the old Ecodesign Directive also transition into the ESPR framework during this period. A mid-term review in 2028 may add further categories including footwear, paints, detergents, and chemicals.
What is the ESPR destruction ban and who does it affect?
Article 25 of ESPR prohibits large enterprises from destroying unsold clothing, clothing accessories, and footwear from 19 July 2026. Medium-sized enterprises face the same ban from 19 July 2030. Micro and small enterprises are permanently exempt from this prohibition, though they remain subject to the general duty to take reasonable measures to prevent unnecessary destruction of unsold goods. The European Commission has defined 10 permitted derogations including product safety issues, damage, and legal compliance requirements.
What should e-commerce and logistics teams do to prepare for ESPR?
Start by mapping your product portfolio to the Working Plan categories to identify which of your products face the earliest deadlines. If you sell clothing or footwear as a large enterprise, audit your unsold inventory processes immediately: the destruction ban and disclosure reporting requirement are already in effect. For other product categories, the priority is building the product data infrastructure ESPR requires — structured records, supplier data, substances inventories — well before the relevant delegated act enters its transition period. On the logistics side, ensure your shipping platform can generate and attach the correct customs and compliance documentation at shipment level as DPP requirements come into force for your product categories.
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As Growth Manager at ShippyPro, I help ecommerce businesses optimize fulfillment, automate logistics workflows, and scale more efficiently. My work centers on the intersection of ecommerce operations, customer experience, and technology. I write about shipping innovation, automation, and the future of ecommerce logistics.