ESPR — Ecodesign for Sustainable Products Regulation
Full citation: Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Regulation (EU) 2023/1542 and Directive 2009/125/EC, and repealing Directive 2009/125/EC.
Published in the Official Journal of the European Union on 28 June 2024 (OJ L 2024/1781). Entered into force: 18 July 2024.
This documentation is informational only and does not constitute legal advice. ESPR delegated acts are still being developed — specific requirements, timelines, and product categories are subject to change. Consult qualified legal counsel for compliance decisions specific to your products and market.
Purpose
ESPR replaces the Ecodesign Directive (2009/125/EC) — the previous framework under which the EU set energy efficiency and design requirements for energy-related products (boilers, lighting, washing machines, etc.). While the old directive focused almost entirely on energy efficiency, ESPR takes a far broader approach. Its objectives are to:
- Improve the environmental sustainability of products placed on the EU market across their full lifecycle — from raw material use through manufacturing, distribution, use, and end of life
- Establish digital product passports as the primary information instrument for product sustainability data
- Create a systematic, delegated-act-based framework under which the Commission can set product-specific requirements across nearly any product category sold in the EU
- Support the circular economy by mandating requirements for durability, repairability, recycled content, and recyclability — not just energy efficiency
The regulation applies to virtually all physical products placed on the EU market, subject to certain exclusions. Food, feed, medicines, and living organisms are excluded. Military equipment is excluded. Otherwise, the scope is intentionally broad.
Key Departure from the Old Ecodesign Directive
The 2009 Ecodesign Directive applied only to energy-related products and could only regulate their energy efficiency and environmental performance during use. ESPR removes both of those constraints:
| Aspect | Old Ecodesign Directive | ESPR |
|---|---|---|
| Scope | Energy-related products only | Virtually all physical products |
| Requirements | Energy efficiency focus | Full lifecycle: durability, repairability, recycled content, recyclability, carbon footprint, DPP |
| DPP | No | Mandated by Article 9 |
| Circular economy | Limited | Central objective |
| Hazardous substances | Limited | Can restrict substances |
| Product groups | ~30 product groups | Potentially hundreds |
The ESPR Digital Product Passport Mandate
Article 9 of ESPR establishes the DPP mandate as a general mechanism applicable to all products subject to delegated acts under the regulation. Every product for which a delegated act is issued under ESPR must have a digital product passport unless the Commission determines that a DPP would not improve information availability for the product in question.
The ESPR DPP framework shares its conceptual basis with the battery passport under the EU Battery Regulation (which was in fact the first sector-specific implementation of the DPP concept and informed the ESPR DPP provisions). Key ESPR DPP requirements under Article 9:
- The DPP must be accessible via a data carrier (QR code or similar) affixed to the product, its packaging, or accompanying documentation
- The DPP must be created before the product is placed on the EU market
- The data contained in the DPP must be accurate, complete, and up to date
- Access to DPP data is tiered — some data is public, some restricted to authorised actors (economic operators, market surveillance authorities, recyclers)
- The DPP must remain accessible for the useful life of the product plus a period to be defined per product category
Product-specific DPP data requirements (which fields are mandatory, which data carrier format is required, what the access tiers contain) will be set in the delegated act for each product category.
Batteries Under ESPR
Batteries are governed by the EU Battery Regulation 2023/1542 as lex specialis — the specific regulation governing a specific product category takes precedence over the general ESPR framework. Battery manufacturers are subject to the Battery Regulation, not a separate ESPR delegated act for batteries.
Article 1(3) of ESPR explicitly acknowledges that batteries are subject to the Battery Regulation and are not governed by ESPR for their primary product-specific requirements. ESPR amended the Battery Regulation (as noted in the ESPR full citation above) to ensure the two frameworks are legally consistent.
For the purposes of using Traceable to comply with battery DPP obligations, the relevant regulatory framework is the EU Battery Regulation 2023/1542, not ESPR. See the EU Battery Regulation documentation for your battery-specific obligations.
Current Status of ESPR Delegated Acts
ESPR entered into force in July 2024 but product-specific requirements will only apply once the Commission issues delegated acts for specific product categories. Delegated acts are being developed through a work plan — the Commission has indicated priority product categories for early action.
As of the date of this documentation (April 2026), the Commission's ESPR work plan priorities include:
| Product Category | Expected Delegated Act Timeline | Notes |
|---|---|---|
| Textiles (clothing and footwear) | 2025–2026 | Highest priority; DPP expected to be included |
| Furniture | 2026–2027 | DPP likely to be included |
| Steel and aluminium products | 2026–2028 | DPP expected |
| Tyres | 2026–2027 | DPP expected |
| Mattresses | 2026–2027 | |
| Consumer electronics (smartphones, tablets) | 2026–2028 | DPP highly likely |
| Detergents and cleaning products | 2027+ | |
| Chemicals | TBD |
Important caveat: These timelines reflect Commission work programme intentions and are subject to change. Delegated acts are subject to scrutiny by the European Parliament and Council before entering into force. Operators in these product categories should monitor official Commission communications.
How Traceable Is Designed for ESPR
Traceable's core architecture — structured product data models, QR code generation, tiered access control, supply chain data management, and compliance verification — is designed to accommodate the ESPR DPP framework as delegated acts are finalised.
As each ESPR delegated act is published and enters into force, Traceable will release product category templates reflecting the mandatory and recommended fields defined in the relevant delegated act. Operators whose products fall under an active ESPR delegated act should contact support@traceable.digital to discuss template availability for their product category.
Further Reading
| Page | Contents |
|---|---|
| ESPR and Battery Regulation Intersection | How the two regulations coexist; who ESPR applies to in the context of batteries |
| EU Battery Regulation Overview | Battery-specific obligations under Regulation (EU) 2023/1542 |
| Compliance Overview | How EU Battery Regulation, ESPR, and GDPR interrelate |