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ESPR (EU) 2024/1781: Sustainable Products Regulation

The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, entered into force on 18 July 2024 and replaced Directive 2009/125/EC as the EU framework for ecodesign. It reaches almost every physical good, not only energy-related products, but it is a framework: nothing applies to a given product until a delegated act sets requirements for its product group. Two parts of it already bite without any product act. Since 19 July 2026, large enterprises may no longer destroy unsold apparel, clothing accessories and footwear, and the Commission has adopted the registry rules and the harmonised standards for the Digital Product Passport (DPP). This guide follows the text article by article, lists the acts adopted under it up to 7 October 2026, and corrects the readings that circulate most often, including some that earlier versions of this page made.

What ESPR changes compared with Directive 2009/125/EC

Section titled “What ESPR changes compared with Directive 2009/125/EC”

Directive 2009/125/EC covered energy-related products only: products that use energy, or that affect energy consumption during use. ESPR keeps that machinery (product-group measures, CE marking, market surveillance) and widens it on three axes.

DimensionDirective 2009/125/ECRegulation (EU) 2024/1781
Legal instrumentDirective, product measures adopted as Commission regulationsRegulation, product requirements set by delegated acts (Article 4)
ScopeEnergy-related productsAny physical goods, components and intermediate products, with the Article 1(2) exclusions
What requirements may addressMainly energy and resource use in the life cycleSixteen product aspects (Article 5(1)), built on twenty parameters (Annex I)
Product information channelInformation requirements; the energy label sits in a separate act, Regulation (EU) 2017/1369Digital Product Passport by default (Article 7(2)(a)), plus optional labels (Article 16)
Unsold goodsNothingDisclosure duty (Article 24) and Annex VII destruction ban from 19 July 2026 (Article 25)
Supply chain dataNothing specificArticle 38 duties on supply chain actors, when a delegated act activates them
Public procurementNothingMandatory minimum requirements may be set by implementing act (Article 65)

Article 79(1) repealed the Directive from 18 July 2024 but kept parts of it alive. Under point (a)(i), named Directive provisions, including Article 15 on implementing measures, continue to apply until 31 December 2026 for nineteen groups: photovoltaic panels, space and combination heaters, water heaters, solid fuel local space heaters, air conditioners (including air-to-air heat pumps and comfort fans), solid fuel boilers, air heating and cooling products, ventilation units, vacuum cleaners, cooking appliances, water pumps, industrial fans, circulators, external power supplies, computers, servers and data storage products, power transformers, professional refrigeration equipment and imaging equipment. Under point (a)(ii), amendments needed to fix technical issues in existing measures stay possible until 31 December 2030. Under point (b), existing measures keep applying until they are repealed or declared obsolete.

This is not a dead letter. Commission Regulation (EU) 2025/2052 of 13 October 2025, on external power supplies, wireless chargers, battery chargers and USB Type-C cables, was adopted under Article 15 of Directive 2009/125/EC, not under ESPR. It applies from 14 December 2028 and repeals Regulation (EU) 2019/1782 from the same date. Smartphones and slate tablets likewise fall under Regulation (EU) 2023/1670, a Directive-based measure applying since 20 June 2025.

The sixteen product aspects (Article 5) and twenty parameters (Annex I)

Section titled “The sixteen product aspects (Article 5) and twenty parameters (Annex I)”

Article 5(1) lists the product aspects that ecodesign requirements must improve "where those product aspects are relevant to the product group". The list has sixteen entries, not twelve.

PointProduct aspectAnnex I parameters that typically express it
(a)Durability(a) guaranteed lifetime, technical lifetime, MTBF, resistance to stresses
(b)Reliability(a)
(c)Reusability(c), (k) incorporation of used components
(d)Upgradability(c), (e) avoidance of solutions detrimental to upgrading
(e)Repairability(b) spare parts availability, delivery time, affordability, tools, repair information, access to software
(f)Maintenance and refurbishment(b), (c), (l) consumables
(g)Presence of substances of concern(f)
(h)Energy use and energy efficiency(g) including software and firmware updates
(i)Water use and water efficiency(g)
(j)Resource use and resource efficiency(g), (j) weight and packaging, (o) material footprint, (t) lightweight design
(k)Recycled content(h)
(l)Possibility of remanufacturing(c)
(m)Recyclability(d)
(n)Possibility of the recovery of materials(h) including critical raw materials
(o)Environmental impacts, including carbon and environmental footprint(m), (n), (p) microplastics, (q) emissions
(p)Expected generation of waste(r)

The mapping in the third column is ours; the Regulation does not pair aspects and parameters one to one. Annex I opens with the words "where necessary supplemented by others", so a delegated act can use parameters beyond points (a) to (t). Article 5(2) adds a specific target: requirements must, where relevant, prevent premature obsolescence, including software that stops working after an operating system update or software updates that are not provided.

Requirements come in two forms. Performance requirements (Article 6) set minimum or maximum levels or non-quantitative rules. Information requirements (Article 7) must, at a minimum, include the DPP and the tracking of substances of concern (Article 7(2)(a) and 7(5)); horizontal acts are exempt from that minimum. A substance of concern within Article 2(27)(a), meaning an SVHC identified under Article 59(1) of REACH, cannot be exempted from the tracking requirement when present above 0.1 % weight by weight (Article 7(6)(b)).

Article 2(24) defines "environmental footprint" as a quantification based on the PEF method of Recommendation (EU) 2021/2279 "or other scientific methods developed by international organisations". Annex I point (m) expresses it "in accordance with the applicable delegated act", so each product act picks the calculation rules.

Chapter III, Articles 9 to 15, sets the passport rules. The DPP is a set of product data reachable through a data carrier linked to a persistent unique product identifier (Article 10(1)(a)). The carrier sits on the product, its packaging or accompanying documentation, as the delegated act specifies (Article 10(1)(b)).

What each delegated act must decide (Article 9(2))

Section titled “What each delegated act must decide (Article 9(2))”
Article 9(2) pointDecision left to the delegated act
(a)Which data from the Annex III menu are included
(b), (c)Which data carrier, its layout and position
(d)Model, batch or item level
(e)How customers reach the passport before purchase, including distance selling
(f)Who may access which data
(g), (h)Who creates or updates the passport, and how
(i)How long it stays available: at least the expected lifetime of the product

Annex III is a menu, not a fixed structure. It covers, among others, the unique product identifier, the GTIN under ISO/IEC 15459-6, the commodity code, compliance documentation such as the declaration of conformity, user manuals and safety information, operator and facility identifiers, importer details including the EORI number, and the reference of the service provider holding the back-up copy. Identifiers and carriers must follow ISO/IEC 15459 parts 1 to 6 until harmonised standards are published.

Storage, back-up and access (Articles 10 and 11)

Section titled “Storage, back-up and access (Articles 10 and 11)”

The passport is stored by the economic operator responsible for creating it or by a DPP service provider (Article 11(c)). When placing the product on the market, the operator must make a back-up copy available through a DPP service provider (Article 10(4)). The passport must survive insolvency, liquidation or cessation of activity (Article 11(e)), and service providers may not sell or reuse the data beyond the service unless agreed (Article 11, second paragraph). Customer personal data may only be stored with explicit consent (Article 10(1)(e)). Access for customers, repairers, recyclers, authorities and other listed actors is free of charge, according to the access rights in the delegated act (Article 11(b)).

Registry, standards and customs: what was adopted in 2026

Section titled “Registry, standards and customs: what was adopted in 2026”
DateActContent
15 July 2026 (OJ)Implementing Decision (EU) 2026/1736References of EN 18216:2026 (data exchange protocols), EN 18219:2026 (unique identifiers), EN 18220:2026 (data carriers), EN 18221:2026 (storage, archiving, persistence), EN 18222:2026 (APIs) and EN 18223:2026 (system interoperability). Conformity gives a presumption of conformity with Articles 10 and 11 (Article 41(2))
19 July 2026Deadline in Article 13(1)The Commission must have set up the registry storing at least the unique identifiers, the commodity code for imports, and battery identifiers
6 August 2026Implementing Regulation (EU) 2026/1778 in forceRegistry structure (web interface, API, verification platform, semantic repository, log system), identity verification of economic operators through eIDAS qualified seals or signatures, valid three years at most, registration at model, batch or item level, proof of registration
Within four years of the 2026/1778 entry into forceArticle 15(3)Interconnection of the registry with EU CSW-CERTEX, after which customs check the unique registration identifier automatically before release for free circulation

Implementing Regulation (EU) 2026/1778 is wider than ESPR. Its Article 1(1) covers products under ESPR delegated acts, batteries under Article 77 of Regulation (EU) 2023/1542, construction products under Regulation (EU) 2024/3110, toys under Regulation (EU) 2025/2509 and detergents under Regulation (EU) 2026/405. When one product is caught by several acts at different levels, it is registered at the most granular level required (Article 8(3)).

Article 77 of the Battery Regulation requires a battery passport from 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and electric-vehicle batteries only. Article 13(6) of the same Regulation requires a QR code on all batteries from the same date. For registration purposes, Implementing Regulation (EU) 2026/1778 treats the battery passport as a digital product passport (Article 2). For the battery side, see the Battery Regulation guide; for passport architecture, see the DPP guide.

Article 18(3) requires a working plan covering at least three years; Article 18(5) required the first one by 19 April 2025 and named eleven priority groups. The Commission adopted it as Communication COM(2025) 187 on 16 April 2025, for five years with a mid-term review in 2028. The years below are the indicative adoption years given in the plan, not dates of application. Under Article 4(4), a delegated act may apply no earlier than 18 months after its entry into force, except in duly justified cases.

MeasureTypeIndicative adoption (COM(2025) 187)
Iron and steelIntermediate product2026
Textiles and apparelFinal product2027
TyresFinal product2027
AluminiumIntermediate product2027
Repairability, including scoringHorizontal; scope could include consumer electronics and small household appliances2027
FurnitureFinal product2028
MattressesFinal product2029
Recycled content and recyclability of electrical and electronic equipmentHorizontal2029

Sixteen energy-related products are carried over from the 2022-2024 plan, with these indicative adoption dates: low-temperature emitters (2026, energy label only), household dishwashers, household washing machines and washer-dryers, professional laundry appliances and professional dishwashers (2026), displays (2027), EV chargers (2028, new product, requirements to be specified), electric motors and variable speed drives, refrigerating appliances, and refrigerating appliances with a sales function (2028), light sources and separate control gears (2029), local space heaters (energy label 2026, ecodesign mid-2030), and welding equipment, mobile phones and tablets, tumble dryers, and standby and off mode consumption (end 2030).

The plan says ICT products are covered through the two horizontal measures and some energy-related items. Detergents, paints, lubricants, chemicals and footwear are named in Article 18(5) but left out (section 2.2.3): a footwear study is to be completed by the end of 2027 and a chemicals study was to be launched by the end of 2025. On unsold goods, section 4.2 says the Commission does not intend to add products to the destruction ban in this first plan, because the disclosure data that should justify new bans are not yet available.

Delegated acts follow Article 72: consultation of experts designated by each Member State, notification to Parliament and Council, entry into force only if neither objects within two months, extendable by two months. The empowerment runs for five years from 18 July 2024 and is tacitly extended unless Parliament or Council opposes. Article 4(7) barred the first delegated act from entering into force before 19 July 2025. The committee procedure of Article 73 applies to implementing acts, such as the registry and disclosure acts.

As of 7 October 2026, the acts we found in EUR-Lex that are based on ESPR are the two unsold-goods acts, the registry act and the DPP standards decision. None of them sets ecodesign requirements for a product group.

DateMilestoneSource
18 July 2024Entry into force; Directive 2009/125/EC repealed with transitional provisionsArticles 79 and 80
16 April 2025Working plan 2025-2030 adoptedCOM(2025) 187
19 July 2025Earliest entry into force of the first delegated actArticle 4(7)
9 February 2026Delegated Regulation (EU) 2026/296 (destruction derogations) and Implementing Regulation (EU) 2026/2 (disclosure format) adopted2026/296, 2026/2
15 July 2026DPP harmonised standards published in the OJDecision (EU) 2026/1736
19 July 2026Destruction ban on Annex VII products applies to large enterprises; derogations apply; registry deadlineArticles 13(1), 25(1); 2026/296 Article 6
6 August 2026Registry implementing regulation in force2026/1778 Article 24
31 December 2026End of the Article 79(1)(a)(i) window for the nineteen energy-related groupsArticle 79(1)(a)(i)
2 March 2027Disclosure format of 2026/2 applies, from the first full financial year after that date2026/2 Articles 1 and 7
19 July 2027First Commission report on destruction of unsold products, then every 36 monthsArticle 26
19 July 2028Commission evaluation of social sustainability requirementsArticle 75(4)
31 December 2028 to 1 January 2030Window for a cement delegated act, if the Construction Products Regulation leaves a gapArticle 18(6)
19 July 2030Destruction ban and disclosure duty extend to medium-sized enterprises; first ESPR evaluationArticles 24(1), 25(1), 75(2)
31 December 2030End of the Article 79(1)(a)(ii) window for technical amendmentsArticle 79(1)(a)(ii)

To place this schedule in the broader trajectory (RED, CE, CRA, batteries), see the certification timeline guide.

Unsold consumer products: disclosure and destruction ban

Section titled “Unsold consumer products: disclosure and destruction ban”

"Destruction" means "the intentional damaging or discarding of a product as waste", with one exception: discarding "for the sole purpose of delivering the discarded product for preparing for reuse, including refurbishment or remanufacturing operations" (Article 2). Handing unsold shirts to a recycler is therefore destruction. "Unsold consumer product" includes surplus stock, excess inventory, dead stock and products returned under the consumer right of withdrawal. Components and intermediate products are not consumer products.

Since 19 July 2026, destroying the unsold consumer products in Annex VII is prohibited: apparel and clothing accessories (CN 4203 leather, 61 knitted, 62 not knitted, 6504 and 6505 hats and headgear) and footwear (CN 6401 to 6405). Micro and small enterprises are outside the ban; medium-sized enterprises come within it on 19 July 2030. Article 25(2) stops operators outside the ban from destroying products supplied to them to circumvent it. The Commission may add products to Annex VII by delegated act (Article 25(3)); the working plan rules this out for now.

The ten derogations (Delegated Regulation (EU) 2026/296, Article 2)

Section titled “The ten derogations (Delegated Regulation (EU) 2026/296, Article 2)”
PointDestruction allowed whenDocumentation (Article 3)
(a)The product is dangerous under the GPSR, Regulation (EU) 2023/988Safety assessment or test report on non-compliant chemicals
(b)It is non-compliant with Union or national law and destruction is required or proportionateSelf-assessment naming the non-compliance and the law
(c)It infringes intellectual property rights (judgment, ADR decision, notification or substantiated internal investigation)The decision, notification or investigation record
(d)A licence makes further sale an infringement after a period that has expiredThe licence plus a proportionality justification
(e)Protected or inappropriate labels, logos or designs cannot be removed, so reuse or remanufacturing is unfeasibleInspection report, visual evidence or expert opinion
(f)Damage or contamination, and repair is not technically feasible or cost-effectiveQuality assessment procedure or inspection record
(g)Design or manufacturing defect that cannot be repairedAs for (f)
(h)Only if (a) to (g) do not apply: offered for donation to at least three social economy entities, or on the operator website, for at least eight weeks, without acceptanceEvidence of the offer
(i)Received as a donation by a social economy entity that found no recipientDeclaration of the entity
(j)Prepared for reuse by a waste operator and no recipient was foundDocumentation from the waste operator

Documentation is kept for five years after destruction and supplied within 30 days of a request (Article 3). The operator must give the waste treatment operator a statement naming the derogation (Article 4). "Cost-effective" has a definition: repair cost not exceeding the total cost of destroying and replacing the product (Article 1(2)). Recycling is not a derogation: Article 5 only asks the Commission to review, by 12 May 2031 at the latest, whether high-quality recycling should become one.

Economic operators that discard unsold consumer products (all products, not only Annex VII) must publish each year the number and weight discarded per category, the reasons and any derogation used, the share sent to reuse, recycling, other recovery and disposal, and their prevention measures. The duty applies to large enterprises since entry into force, the first disclosure covering the first full financial year during which the Regulation was in force; medium-sized enterprises follow from 19 July 2030; micro and small enterprises are exempt. Implementing Regulation (EU) 2026/2 fixes a mandatory template, categories by the first two digits of the CN code (four digits for the products in its Annex II), and a five-year record-keeping duty. It applies from 2 March 2027, to the first full financial year after that date, with publication within 12 months after the end of that year.

Conformity assessment, marking and economic operators

Section titled “Conformity assessment, marking and economic operators”

Article 4(5) limits each delegated act to module A, internal production control as set out in Annex IV to ESPR, or one of modules B to H1 of Annex II to Decision 768/2008/EC, adapted to the product. Modules A1 and A2 of the Decision are not on the list. Where other Union law applies a different module to the same product, the ESPR module governs the ecodesign requirement (Article 4(5), second subparagraph).

ModuleSummaryNotified body
A (ESPR Annex IV)Internal production controlNo
B with C, C1 or C2EU type examination plus conformity to typeYes
D, D1Production quality assuranceYes
E, E1Product quality assuranceYes
F, F1Product verificationYes
GUnit verificationYes
H, H1Full quality assuranceYes

The manufacturer draws up the EU declaration of conformity (Article 44, model in Annex V) and affixes the CE marking (Article 46). A delegated act may instead set a specific marking for products not otherwise subject to CE marking (Articles 4(6)(d) and 47). Where several Union acts require a declaration, a single declaration lists them all (Article 44(3)). The manufacturer keeps technical documentation and the declaration for 10 years unless the delegated act sets another period (Article 27(3)), provides digital instructions, with safety information still on paper (Article 27(7)), and shows its contact details on the public part of the DPP where applicable (Article 27(6)).

The chain of duties: manufacturer (Article 27), authorised representative (Article 28), importer (Article 29), distributor (Article 30), dealer (Article 31), label obligations (Article 32), fulfilment service providers (Article 33), and providers of online marketplaces and online search engines (Article 35). Article 38 lets a delegated act require supply chain actors to give manufacturers, notified bodies and authorities the relevant information they hold, free of charge, or else let the manufacturer assess their products and access documents or facilities. For the general module-selection logic, see the self-declaration vs notified body guide, and for CE generally the CE marking guide and the CE procedure.

Penalties are national, "effective, proportionate and dissuasive" (Article 74(1)). Member States must at least be able to impose fines and time-limited exclusion from public procurement procedures (Article 74(3)). Market surveillance runs under Regulation (EU) 2019/1020.

Battery Regulation (EU) 2023/1542. Covered above. Article 78 of ESPR itself amends the Battery Regulation, and the ESPR registry stores battery identifiers.

Cyber Resilience Act, Regulation (EU) 2024/2847. The CRA sets cybersecurity requirements for products with digital elements, with reporting obligations from 11 September 2026 and full application from 11 December 2027. ESPR is environmental. Where both apply, the single declaration of Article 44(3) covers both. Note that Annex I point (g) of ESPR lets a delegated act regulate the effect of software and firmware updates on product efficiency, and Article 5(2) targets software updates that are not provided: product requirements on updates can therefore come from both sides. See the Cyber Resilience Act guide.

Common Charger Directive (EU) 2022/2380. It harmonises the charging interface of listed radio equipment. Ecodesign rules on chargers and cables themselves are currently in Regulation (EU) 2025/2052, a Directive-based measure applying from 14 December 2028. See the USB-C guide.

Energy Labelling Regulation (EU) 2017/1369. It stays. The working plan states that energy labels remain the default for relevant energy-related products, and that EPREL can stand in for a DPP where it provides equivalent information (Article 9(4)(b) allows such exemptions). Article 16(3) ESPR allows an ESPR label to replace the energy label only after an assessment of confusion risk and burden.

REACH (EC) 1907/2006. Performance requirements under ESPR may not restrict the presence of substances for reasons relating primarily to chemical safety (Article 6(3)); substances of concern are tracked through information requirements. The REACH Article 33 duty to communicate candidate-list substances above 0.1 % in articles applies independently.

  1. Identify the act that applies today. For most electronic products this is still a Directive-based measure (for example Regulation (EU) 2023/1670 for smartphones and tablets, or 2025/2052 for external power supplies), not an ESPR delegated act.
  2. Track the horizontal repairability measure (indicative 2027) and the EEE recycled content and recyclability measure (indicative 2029). These are the working plan items most likely to reach electronics across product groups.
  3. Build a substances-of-concern map in the bill of materials. Article 7(5) asks for name, location, concentration and end-of-life information, and substances of very high concern above 0.1 % cannot be exempted.
  4. Prepare for identifiers and a data carrier that can follow ISO/IEC 15459 and the EN 18216 series, without knowing yet whether the act will require model, batch or item level.
  5. Contract supplier data (material composition, recycled content, footprint inputs). Article 38 duties only apply once a delegated act activates them.
  6. Retailers of apparel and footwear: since 19 July 2026, map unsold stock flows against the ten derogations of 2026/296, keep five years of evidence, and stop sending unsold Annex VII goods to recycling without a derogation.

For the full regulatory mapping (CE, RED, EMC, RoHS, REACH, WEEE), see the CE marking scope page. The spilma glossary lists the key terms.

Common claim (including on earlier versions of this page)What the text says
ESPR has twelve ecodesign axesArticle 5(1) lists sixteen product aspects, points (a) to (p); water, resource use, recyclability and recovery of materials are separate points. Annex I adds twenty parameters
Recycling unsold goods is not destructionArticle 2 defines destruction as damaging or discarding as waste; only delivery for preparing for reuse is excluded. Recycling is not among the 2026/296 derogations, and Article 5 of that act only plans a review
Destruction is allowed for health, safety or IP reasons "subject to declaration"Delegated Regulation (EU) 2026/296 lists ten specific circumstances with specific evidence, kept five years; donation offers (eight weeks, three entities) come last
Consumer electronics and toys are the next candidates for the destruction banArticle 18(3) only requires the Commission to consider electrical and electronic equipment. Section 4.2 of the working plan says no products will be added in this first plan; toys are not mentioned
Every ESPR passport is per product or per batchArticle 9(2)(d): the delegated act chooses model, batch or item level
The DPP data carrier must sit on the productArticle 10(1)(b): product, packaging or accompanying documentation, as the delegated act specifies
Environmental footprint must be declared under the PEF methodArticle 2(24) names PEF but also allows "other scientific methods"; Annex I point (m) leaves the choice to each delegated act
A REACH candidate substance above 0.1 % must be in the DPP of any productOnly once a delegated act sets information requirements for that product group; Article 7(6)(b) then forbids exempting it
Upstream due diligence is integrated in ESPRESPR has no due diligence regime. Article 38 information duties on supply chain actors apply only when a delegated act says so
Any product covered by a delegated act carries CE markingArticle 27(2): CE marking, unless the delegated act sets alternative marking rules under Article 4(6)(d)
Smartphones will need an ESPR DPP and a removable battery togetherNo ESPR act on smartphones exists. They fall under Regulation (EU) 2023/1670; the working plan gives "end 2030" for mobile phones and tablets
National transpositions set the finesESPR is a regulation and is not transposed. Member States set penalty rules under Article 74, at least fines and time-limited exclusion from public procurement
The 2009 Directive stops applying to computers and power supplies on 31 December 2026That date ends the window to adopt measures under the Directive for those groups. Measures already adopted, such as 2025/2052 (applying from 14 December 2028), stay in force until repealed

Sources & references

  1. Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products (ESPR), EUR-Lex eur-lex.europa.eu/eli/reg/2024/1781/oj
  2. COM(2025) 187, Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 (16 April 2025), European Commission (EUR-Lex) eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187
  3. Delegated Regulation (EU) 2026/296, derogations from the prohibition of destruction of unsold consumer products, EUR-Lex eur-lex.europa.eu/eli/reg_del/2026/296/oj
  4. Implementing Regulation (EU) 2026/2, details and format for the disclosure of information on discarded unsold consumer products, EUR-Lex eur-lex.europa.eu/eli/reg_impl/2026/2/oj
  5. Implementing Regulation (EU) 2026/1778, implementation arrangements for the digital product passport registry, EUR-Lex eur-lex.europa.eu/eli/reg_impl/2026/1778/oj
  6. Implementing Decision (EU) 2026/1736 on harmonised standards for digital product passports (EN 18216, EN 18219 to EN 18223:2026), EUR-Lex eur-lex.europa.eu/eli/dec_impl/2026/1736/oj
  7. Regulation (EU) 2025/2052, ecodesign requirements for external power supplies, wireless chargers and USB Type-C cables (adopted under Directive 2009/125/EC), EUR-Lex eur-lex.europa.eu/eli/reg/2025/2052/oj
  8. Regulation (EU) 2023/1670, ecodesign requirements for smartphones and slate tablets, EUR-Lex eur-lex.europa.eu/eli/reg/2023/1670/oj
  9. Regulation (EU) 2023/1542 concerning batteries and waste batteries, EUR-Lex eur-lex.europa.eu/eli/reg/2023/1542/oj
  10. European Commission, Ecodesign for Sustainable Products Regulation page, European Commission environment.ec.europa.eu/strategy/circular-economy/ecodesign-sustainable-products-regulation_en
  11. Digital Product Passport, Commission information page, European Commission single-market-economy.ec.europa.eu/single-market/digital-product-passport_en
  12. Directive 2009/125/EC establishing a framework for ecodesign of energy-related products (repealed by ESPR Article 79(1), transitional provisions apply), EUR-Lex eur-lex.europa.eu/eli/dir/2009/125/oj
  13. Decision 768/2008/EC on a common framework for the marketing of products, EUR-Lex eur-lex.europa.eu/eli/dec/2008/768/oj

Frequently asked questions

When did the ESPR enter into force and what does it replace?
Regulation (EU) 2024/1781 was signed on 13 June 2024, published in the Official Journal on 28 June 2024 and entered into force on 18 July 2024 (Article 80). Article 79(1) repealed Directive 2009/125/EC with effect from 18 July 2024, with two exceptions. For nineteen listed energy-related product groups (photovoltaic panels, heaters, computers, servers and data storage, external power supplies, imaging equipment and others) the Commission may keep adopting measures under the Directive until 31 December 2026, and amendments addressing technical issues in existing measures remain possible until 31 December 2030. The implementing measures already adopted stay in force until they are repealed or declared obsolete.
What is the scope of ESPR?
Article 1(2) applies the Regulation to any physical goods placed on the market or put into service, including components and intermediate products. The exclusions are exhaustive: food, feed, medicinal products, veterinary medicinal products, living plants, animals and micro-organisms, products of human origin, products of plants and animals relating directly to their future reproduction, and vehicles under Regulations (EU) No 167/2013, No 168/2013 and 2018/858 but only for the aspects governed by their sectoral acts. Article 5(5) excludes from product groups only products whose sole purpose is defence or national security. Nothing applies to a product until a delegated act under Article 4 covers its product group.
How many ecodesign aspects does Article 5 list?
Sixteen, in Article 5(1) points (a) to (p): durability, reliability, reusability, upgradability, repairability, maintenance and refurbishment, substances of concern, energy use, water use, resource use, recycled content, remanufacturing, recyclability, recovery of materials, environmental impacts including carbon and environmental footprint, and expected generation of waste. Annex I then lists twenty product parameters, points (a) to (t), on which requirements are built.
What is the Digital Product Passport (DPP)?
A set of product data reachable through a data carrier linked to a persistent unique product identifier (Articles 9 and 10). Each delegated act decides whether the passport is at model, batch or item level, which data from the Annex III menu it holds, which data carrier is used and who can read or update which data. The manufacturer must also lodge a back-up copy with a DPP service provider (Article 10(4)). Implementing Regulation (EU) 2026/1778 sets out how passports are registered in the Commission registry, and Implementing Decision (EU) 2026/1736 published six harmonised standards, EN 18216 and EN 18219 to EN 18223:2026, that give a presumption of conformity with Articles 10 and 11.
Which product groups are prioritised in the 2025-2030 working plan?
Communication COM(2025) 187 of 16 April 2025 lists four final products (textiles and apparel, furniture, tyres, mattresses), two intermediate products (iron and steel, aluminium), two horizontal measures (repairability including scoring, and recycled content and recyclability of electrical and electronic equipment) and sixteen energy-related products carried over from the 2022-2024 plan. Detergents, paints, lubricants, chemicals and footwear are named in Article 18(5) but left out, with studies announced for footwear and chemicals. The years in the plan are indicative adoption dates, not application dates.
How does ESPR interact with the EU Battery Regulation (EU) 2023/1542?
The Battery Regulation governs the battery, ESPR the host product. Under Article 77 of the Battery Regulation, a battery passport is required from 18 February 2027 only for LMT batteries, industrial batteries above 2 kWh and electric-vehicle batteries; from the same date Article 13(6) requires a QR code on all batteries. The ESPR registry stores battery identifiers too (Article 13(1) ESPR), and Implementing Regulation (EU) 2026/1778 treats the battery passport as a digital product passport for registration purposes.
How does ESPR interact with the Cyber Resilience Act (CRA)?
They regulate different things. ESPR sets environmental requirements product group by product group; the CRA, Regulation (EU) 2024/2847, sets cybersecurity requirements for products with digital elements, with reporting obligations from 11 September 2026 and full application from 11 December 2027. A connected product can be subject to both, and Article 44(3) ESPR then requires a single EU declaration of conformity covering every applicable act.
When does the unsold-goods destruction ban take effect?
Article 25(1) has prohibited, since 19 July 2026, the destruction of the unsold consumer products listed in Annex VII: apparel and clothing accessories (CN 4203, 61, 62, 6504, 6505) and footwear (CN 6401 to 6405). Micro and small enterprises are outside the prohibition; medium-sized enterprises come within it from 19 July 2030. Destruction includes discarding as waste for recycling: only delivery for preparing for reuse is carved out. The ten permitted grounds are in Delegated Regulation (EU) 2026/296, which also applies from 19 July 2026 and requires five years of supporting documentation.
What is the conformity assessment procedure and who is responsible?
Each delegated act picks the procedure (Article 4(5)): module A as set out in Annex IV to ESPR, or one of modules B to H1 of Decision 768/2008/EC. The manufacturer then draws up the EU declaration of conformity (Article 44) and affixes the CE marking (Article 46), unless the delegated act sets an alternative marking for products not subject to CE marking (Article 4(6)(d)). Technical documentation and the declaration are kept for 10 years unless the delegated act sets another period (Article 27(3)). Importers, distributors, dealers, fulfilment service providers and online marketplaces have their own duties (Articles 29 to 35).