Ecodesign for Sustainable Products Regulation (ESPR) 2024/1781
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of ecodesign requirements for sustainable products — the "Ecodesign for Sustainable Products Regulation" or ESPR — repealed and replaced Directive 2009/125/EC (the original Ecodesign Directive). It entered into force on 18 July 2024 and applies from that date for the horizontal framework. Product-specific requirements are adopted through Commission Delegated Regulations ("ecodesign requirements") covering individual product groups; until those are adopted, the predecessor's product-specific Implementing Regulations under Directive 2009/125/EC continue to apply. Published as OJ L, 2024/1781, 28.6.2024.
Legal status and timeline
- Predecessor: Directive 2009/125/EC (Ecodesign Directive).
- Adoption: 13 June 2024.
- Entry into force: 18 July 2024.
- Date of application of the horizontal framework: 18 July 2024.
- Repeal of Directive 2009/125/EC: 18 July 2024, subject to extensive transitional provisions: existing Implementing Regulations adopted under the Directive remain in force until replaced by ESPR delegated regulations (Article 79).
- Prohibition of destruction of unsold consumer products (Article 25): applies from 19 July 2026 for textiles and footwear; from 19 July 2030 for medium-sized enterprises; never for small and micro enterprises.
- Status in October 2026: applies. The Commission's ESPR and Energy Labelling Working Plan 2025–2030 (April 2025) prioritises textiles (apparel), furniture, tyres and mattresses, the intermediate products iron and steel and aluminium, and horizontal requirements on the repairability and the recycled content and recyclability of electrical and electronic equipment.
Scope: products covered
Article 1(2) applies the Regulation to "any physical goods that are placed on the market or put into service, including components and intermediate products". This is a substantial extension over Directive 2009/125/EC, which was limited to "energy-related products". The ESPR can apply, in principle, to almost any product, except those excluded in Article 1(2) (food, feed, medicinal products, living plants/animals/microorganisms, products of human/animal/plant origin directly and exclusively related to their future reproduction, vehicles within the scope of Regulation (EU) 2018/858).
The Regulation does not directly impose requirements on products; it empowers the Commission to adopt delegated regulations setting ecodesign requirements for specific product groups. Each delegated regulation defines its scope precisely.
Ecodesign requirements
Article 5 and Annex I list aspects on which ecodesign requirements may be set:
- Product durability and reliability;
- Reusability and upgradability;
- Reparability, including provision of spare parts and instructions;
- Possibility of maintenance and refurbishment;
- Presence of substances of concern;
- Energy use or energy efficiency;
- Resource efficiency, including water consumption;
- Recycled content;
- Possibility of remanufacturing and recycling;
- Possibility of recovery of materials;
- Environmental impacts including carbon and environmental footprint;
- Expected generation of waste materials.
Requirements may be either "performance requirements" (e.g., minimum durability of 10,000 cycles) or "information requirements" (e.g., disclosure of repairability score).
Digital Product Passport
Articles 9–14 of the ESPR establish the Digital Product Passport (DPP) as a central instrument. Each delegated regulation specifies the data elements of the DPP for the product group it covers. The DPP makes information accessible via a data carrier (typically QR code or NFC) linking to a digital record. Required data may include:
- Product identifiers (manufacturer, model, serial number);
- Compliance documentation (Declaration of Conformity, certificates);
- Material composition and substances of concern;
- Reparability information (manuals, spare parts identifiers);
- Environmental footprint information;
- End-of-life and recyclability information.
The DPP registry (Article 13) is interconnected with the EU Customs Single Window (Article 15(3)), and the DPP is accessible to consumers, repairers, recyclers, market surveillance authorities, and other stakeholders with appropriately tiered access rights. See Digital Product Passport.
Prohibition of destruction of unsold consumer products
Article 25 prohibits the destruction of unsold consumer products. The prohibition applies to:
- Textiles and footwear — from 19 July 2026;
- Other categories — as the Commission adopts delegated acts under Article 25;
- Medium-sized enterprises (50–249 employees) — from 19 July 2030;
- Small and micro enterprises — exempt.
Economic operators that discard unsold consumer products must disclose the number and weight discarded per year (Article 24(1)), giving rise to the first EU-wide statistics on product destruction.
Conformity assessment
Articles 4(5) and 43 require each delegated regulation to specify the conformity assessment procedure for the product group it covers. The default is Module A — internal production control (Annex IV); some product groups may require Module B + C or higher routes where third-party assessment is appropriate.
Technical documentation
Article 27 and Annex IV require technical documentation specific to each ecodesign requirement. Retention: 10 years. See technical documentation.
EU Declaration of Conformity
Article 44 and Annex V. The Declaration may be embedded in the DPP. See EU Declaration of Conformity.
Marking and labelling
Articles 45 and 46 require the CE marking. Delegated regulations may require additional marking (e.g., the Energy Label under Regulation (EU) 2017/1369, the EU Ecolabel under Regulation (EC) 66/2010, where applicable). See affixing the CE mark.
Recent and upcoming changes
- The Commission's ESPR and Energy Labelling Working Plan 2025–2030 (adopted in April 2025) identifies priority product groups for delegated regulations.
- The working plan schedules the first ESPR delegated regulations for iron and steel (2026), textiles (2027) and furniture (2028).
- The Energy Labelling Regulation (EU) 2017/1369 continues to apply in parallel for energy-related products with energy labels.
- The Commission's "Right to Repair" initiative (Directive (EU) 2024/1799) complements the ESPR's reparability requirements.
Related legislation
- Energy Labelling Regulation (EU) 2017/1369 — energy labels for in-scope products.
- Construction Products Regulation 2024/3110 — applies in parallel for construction products with sustainability requirements.
- Battery Regulation 2023/1542 — overlaps for batteries.
- RoHS Directive 2011/65/EU — applies in parallel for electrical and electronic products.
- Directive (EU) 2024/1799 ("Right to Repair") — consumer rights to repair, complementary to ESPR reparability requirements.
- Regulation (EU) 2024/1252 on critical raw materials — overlapping requirements for products containing critical raw materials.
- Waste Framework Directive 2008/98/EC — applies in parallel for end-of-life management.
Common errors
- Treating ESPR as immediately applicable. The horizontal framework applies, but product-specific requirements depend on delegated regulations. Until those are adopted, the predecessor's Implementing Regulations remain in force.
- Ignoring information requirements. Information requirements (such as repairability disclosure) are as binding as performance requirements.
- Destroying unsold products in scope of the prohibition. From 19 July 2026, the textile and footwear prohibition applies to all but micro and small enterprises; medium-sized enterprises have until 19 July 2030.
- Not preparing for DPP. Delegated regulations will require manufacturers to establish DPP infrastructure; preparation lead times are significant.
Sources
- Regulation (EU) 2024/1781 (ESPR) — EUR-Lex.
- Directive 2009/125/EC (predecessor) — EUR-Lex.
- European Commission — Ecodesign for Sustainable Products Regulation.
- ESPR and Energy Labelling Working Plan 2025–2030 — European Commission, April 2025.
- Commission Notice — Blue Guide 2022 — EUR-Lex.