- Regulatory Guide
ESPR Regulation 2024/1781 — Complete Guide
Last reviewed: August 2026 · PassoNext Team
The Ecodesign for Sustainable Products Regulation (ESPR) 2024/1781 is the main European framework for product sustainability. It entered into force on 18 July 2024 and gives the European Commission the authority to establish mandatory ecodesign rules and information disclosures—most notably mandatory Digital Product Passports—for almost all physical products. Replacing the 2009 Ecodesign Directive, the ESPR covers nearly every product category, excluding only food, feed, human and veterinary medicines, and a few other specifically named items.
- ESPR is the framework regulation — it establishes the legal basis for DPPs across all product categories.
- Product-specific requirements are defined through delegated acts, not in the ESPR itself.
- Textiles, electronics, tyres, and furniture are among the first priority categories.
- The regulation applies to all products placed on the EU single market, regardless of where they are manufactured.
- Each delegated act will define the specific data fields, deadlines, and scope for its product category.
The Ecodesign for Sustainable Products Regulation is the most far-reaching product sustainability law the European Union has ever passed. Replacing the 2009 Ecodesign Directive, it expands mandatory sustainability criteria to almost every physical item sold on the EU market. For any business that manufactures or imports goods for the EU, this law directly affects your operations.
This guide explores the complete reach of Regulation (EU) 2024/1781: what it requires, which products are affected, how the Digital Product Passport fits in, and what manufacturers should do to prepare.
What Is the ESPR?
In short: the ESPR is an EU regulation, not a directive, in force since 18 July 2024, that extends mandatory sustainability requirements from just energy-related products to nearly all physical products sold in the EU.
Formally known as Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation creates a broad legal framework for setting ecodesign rules on products sold in the EU internal market. It was published in the Official Journal of the European Union on 28 June 2024 and entered into force on 18 July 2024.
The ESPR updates and significantly expands the 2009 Ecodesign Directive 2009/125/EC. While the old directive applied only to energy-related goods—like heating systems, appliances, lighting, and motors—the ESPR covers almost all physical products, whether they use energy or not.
Because this is a regulation rather than a directive, it applies directly across all EU Member States without needing to be written into national laws. This ensures one set of consistent rules across the entire internal market.
Scope: Which Products Are Covered
In short: almost every physical product sold in the EU is in scope, with a short, explicit exclusion list covering food, medicines, live organisms, and vehicles already governed by type-approval rules.
The ESPR applies to all physical goods placed on the EU market, including components and intermediate products. Its scope is deliberately broad. Article 1 sets out what the regulation covers and lists its narrow exemptions.
Products Excluded from the ESPR
- Food and feed as defined in Regulation (EC) No 178/2002
- Medicinal products for human use (Directive 2001/83/EC) and veterinary medicinal products (Regulation (EU) 2019/6)
- Living plants, animals, and micro-organisms
- Products of human origin
- Products of plants and animals relating directly to their future reproduction
- Motor vehicles and their trailers covered by Regulation (EU) 2018/858 (type-approval framework)
Products exclusively used for defence or national security purposes
Just about everything else is included. Textiles, electronics, furniture, construction materials, chemicals, packaging, industrial components, and everyday consumer goods all fall under the ESPR. The law won’t hit every category at the exact same moment, though. Instead, it gives the European Commission the green light to roll out specific rules for individual product groups over time using delegated acts.
Key Provisions of the ESPR
In short: the ESPR introduces four requirement categories, Digital Product Passports, minimum ecodesign performance thresholds, substance-of-concern restrictions, and a ban on destroying unsold goods, each activated per product group through a delegated act.
The ESPR brings in four main categories of product requirements. Each will be rolled out through delegated acts that set precise rules for specific product groups.
1. Digital Product Passport (Articles 9-12)
The DPP is the most significant structural addition in the ESPR. Articles 9 through 12 set up the legal rules for requiring Digital Product Passports on covered goods. Passports must hold standardized, machine-readable data that people can access through a data carrier (like a QR code) linked to the central EU DPP Registry.
Article 9 outlines basic DPP rules: unique product identifiers, physical data carriers, machine-readable formats, and compliance with interoperability standards. Article 10 sets up a three-tiered access structure—public data, restricted data for parties with a legitimate interest, and secure data for market surveillance agencies. Article 11 covers technical standards for passport systems, while Article 13 sets up the EU Central DPP Registry.
2. Ecodesign Performance Requirements (Article 5)
The ESPR gives the Commission the authority to set minimum performance standards on traits like durability, reliability, reusability, upgradability, reparability, energy efficiency, resource efficiency, recycled content, and substances of concern. These are mandatory floors, not suggestions. Products that fail to meet the minimum standards set in an applicable delegated act cannot be legally sold in the EU.
3. Substance of Concern Restrictions (Article 5(1)(b))
Delegated acts can limit or ban specific substances of concern in products. This expands on familiar rules like REACH and RoHS by bringing chemical safety directly into general product design. The ESPR requires manufacturers to track and disclose these substances, letting the Commission step in with limits or bans whenever a substance hurts circularity or complicates recycling down the line.
4. Destruction of Unsold Consumer Products (Chapter VI, Articles 23 to 25)
Article 23 targets inventory waste by introducing public disclosure rules and an eventual ban on scrapping unsold retail goods. Under these terms, large companies must publish annual reports detailing how many unsold items they discard, why they threw them away, and what steps they took to prevent destruction in the first place.
On top of that, delegated acts can introduce outright bans on destroying specific types of unsold goods. This policy targets common retail practices in fashion, tech, and consumer goods, where excess stock gets burned or dumped rather than reused or recycled. A direct ban on destroying unsold textiles and footwear takes effect for large companies in mid-2026.
The Delegated Acts Process
In short: the ESPR itself sets no product-specific rules; each product category gets its own delegated act through a multi-year process of study, consultation, adoption, and a transition period before compliance becomes enforceable.
The ESPR is a framework law. It doesn’t write out item-by-item rules in its main text. Instead, Article 4 gives the European Commission the power to pass delegated acts that define detailed ecodesign criteria, required DPP data fields, and labeling rules for each product group.
Every delegated act follows a clear, multi-step pipeline:
- Preparatory study: Technical research commissioned by the Commission to assess the environmental impacts, improvement potential, and feasibility of ecodesign requirements for the product group.
- Stakeholder consultation: Industry, civil society, and Member State input through the Ecodesign Forum and public consultations.
- Impact assessment: Analysis of the economic, environmental, and social impacts of proposed requirements.
- Adoption: The Commission adopts the delegated act. The European Parliament and Council have a scrutiny period (typically two months, extendable to four) to raise objections.
- Publication and transition: The delegated act is published in the Official Journal. A transition period (typically 18 to 36 months) gives manufacturers time to comply.
Because of this step-by-step process, there is a clear gap between when the ESPR takes effect and when actual product-level rules kick in. But that lead time shouldn’t lead to sitting back and waiting. Technical research for priority products is already underway, and setting up the data systems needed to comply takes far longer than a few months.
Priority Product Categories
In short: textiles and footwear, iron/steel/aluminium, furniture, tyres, and electronics are the categories the European Commission is addressing first.
The European Commission has already signaled which product sectors it plans to tackle first with ESPR delegated acts. These groups were chosen based on their total environmental impact, sector readiness, and political importance.
Textiles and Footwear
Clothing and footwear are top policy priorities, supported by the EU Strategy for Sustainable and Circular Textiles launched in March 2022. The upcoming delegated act for textiles will focus on physical durability, recyclability, recycled fiber percentages, microplastic shedding, and DPP integration. Footwear shares this first-wave spot on the Commission’s schedule.
Iron, Steel, and Aluminium
These core materials carry high carbon footprints. Upcoming delegated acts will focus on verified recycled content, carbon disclosures, and supply chain traceability. Digital passports for these materials will provide verified environmental data to downstream manufacturers who need those figures for their own products.
Furniture
Ecodesign goals for home and office furniture center on product lifespan, repair options, and end-of-life recycling. The furniture delegated act will set minimum standards for product durability, spare part availability, and easy disassembly.
Tyres
Because tyre wear contributes heavily to microplastic pollution, secondary rules will target abrasion rates, rolling resistance, wet grip performance, and road noise alongside DPP features.
Electronics and ICT Equipment
Building on existing energy labels, delegated acts for electronics will add rules for reparability scores, guaranteed spare part availability, software update timelines, and recycled plastic content. This category covers smartphones, tablets, laptops, servers, and networking gear.
Other Categories
Detergents, paints and varnishes, and industrial lubricants are also highlighted in the Commission’s work plan. They will follow the main priority categories, but could move quickly given their simpler product setups and existing regulatory baselines.
DPP Requirements Under the ESPR
In short: every ESPR-based Digital Product Passport needs a unique identifier, a QR code data carrier, tiered public/restricted access, machine-readable data, and registration in the EU Central DPP Registry.
The main ESPR text sets out the technical groundwork for all Digital Product Passports. While specific delegated acts will spell out exact data fields, these basic rules apply across the board.
Unique Product Identifier
Every DPP must link to a unique identifier. Depending on what the delegated act requires, tracking will happen at the product model, batch, or individual item level. The identifier must be globally unique and conform to standard systems like ISO/IEC 15459 or GS1 standards.
Data Carrier
The physical entry point to the passport must be an ISO/IEC 18004-compliant QR code printed on the product, its packaging, or included documents. The QR code must lead to a URL formatted under the GS1 Digital Link standard and stay scannable throughout the product’s expected lifespan.
Tiered Access
Article 10 outlines three distinct access levels: general public info, restricted data for verified professionals (like repair shops and recyclers), and secure administrative access for market oversight officials. Passport systems must manage these access permissions and verify restricted requests.
Interoperability and Machine-Readability
DPP data must be published in open, machine-readable formats. This allows automated processing by customs databases, market surveillance tools, and supply chain management software. Technical standards will be detailed by the Commission through implementing acts.
EU Central DPP Registry
All active product passports must be registered in the EU Central DPP Registry set up under Article 13. The registry acts as the official lookup directory for market inspectors and customs officers. It doesn’t host all the product data itself; instead, it stores core identifiers and points back to the passport endpoints hosted by manufacturers or their tech partners.
Relationship to the Battery Regulation
In short: the EU Battery Regulation’s battery passport, already mandatory from 18 February 2027, is the reference implementation the ESPR’s Digital Product Passport framework was modelled on, and some manufacturers will need separate but interlinked passports for both.
The EU Battery Regulation—Regulation (EU) 2023/1542—was the first industry-specific law to make Digital Product Passports mandatory, introducing them under Article 77 a full year before the ESPR was finalized.
Because it came first, the battery passport served as a real-world model for the ESPR’s DPP structure. Core technical details in the ESPR—like QR code carriers, tiered permissions, and a central lookup registry—were adapted from the original battery passport designs.
If your company makes products covered by both laws (like battery-powered electronics), you will need to handle two connected passports: one for the battery under Regulation (EU) 2023/1542, and one for the overall device under the relevant ESPR delegated act. The ESPR recognizes this overlap and mandates smooth coordination between the two systems, though the exact technical details will come via implementing acts.
Timeline: When Does the ESPR Bite?
In short: the framework has applied since July 2024, but actual product-level DPP and ecodesign obligations only land as each category’s delegated act clears its transition period, expected from around 2027 onward for the first priority categories.
The ESPR legal framework is active today, having entered into force on 18 July 2024. However, product-specific rules only go live through delegated acts. The expected timeline looks like this:
- 18 July 2024: ESPR enters into force. Framework provisions active. Commission empowered to adopt delegated acts.
- 2024-2025: Preparatory studies for priority product categories launched or ongoing.
- 2025-2027: First delegated acts adopted for priority product categories (textiles and footwear, iron and steel, aluminium expected among the first).
- 2026 (mid-year): Ban on destruction of unsold textiles and footwear takes effect for large companies.
- 2027-2028: Transition periods for first delegated acts expire. First ESPR-based ecodesign requirements and DPP obligations become enforceable.
- 2028-2030: First ESPR-based Digital Product Passports must be live and registered for products in the priority categories.
- Ongoing: Additional delegated acts adopted for further product categories. EU Central DPP Registry fully operational.
This timeline is fast for European legislation. Manufacturers who wait until final delegated acts appear will face tight deadlines and higher costs trying to catch up.
Enforcement and Penalties
In short: market surveillance authorities and customs can check DPP data directly through the EU Central DPP Registry, and Member States must set penalties strong enough to remove any financial benefit of non-compliance.
The ESPR establishes a strong enforcement network across the region. Market inspection rules live in Chapter XI (Articles 66 to 68), while Chapter XII (Articles 69 to 71) covers safeguard processes for risky products. Penalties are addressed separately in Chapter XIV, where Article 74 directs EU Member States to enact effective, proportionate, and discouraging punishment rules.
Market Surveillance
Market oversight authorities in each EU country are responsible for checking compliance. They have the legal right to request technical paperwork, perform facility audits, test products, and pull physical samples. Under the ESPR, officials also get direct access to the EU Central DPP Registry, enabling rapid, automated digital checks.
Customs Cooperation
The regulation connects product compliance directly to border control. Goods imported into the EU will face DPP verification. Customs officers can query the central registry to confirm that a valid passport exists for incoming shipments. Shipments missing a registered DPP can be held at the border, sent for extra inspection, or blocked from entering the market entirely.
Penalties
Article 68 requires Member States to establish penalty systems that are effective, proportionate, and dissuasive. The ESPR leaves exact fine amounts to national laws, but those penalties must be tough enough to wipe out any financial gain from ignoring the rules. Inspection authorities can order products pulled from shelves, halt sales, and demand complete product recalls.
If you sell across multiple EU countries, non-compliance risk adds up quickly. Getting flagged in one country can trigger coordinated enforcement across the entire EU through the shared ICSMS (Information and Communication System for Market Surveillance) network.
How to Prepare: A Manufacturer’s Checklist
In short: start now on regulatory monitoring, a data readiness audit, supplier data requirements, DPP platform selection, internal governance, and a pilot implementation, the delegated-act lead time is not a reason to wait.
Preparing for the ESPR requires taking practical steps right now rather than waiting for delegated acts to hit the press. Here is how to get ready:
Regulatory Monitoring
Track the delegated act process for your specific product types. Keep an eye on the Commission’s work plans, sign up for public consultations, and join industry task forces. Technical studies give early signals about what rules will appear in the final laws.
Data Readiness Assessment
Audit the product information you currently collect. Measure your existing data against the categories outlined in Articles 9-12 and the expected DPP requirements for your sector. Spot gaps in your carbon footprint numbers, material breakdowns, chemical tracking, and supply chain origin records.
Supply Chain Engagement
Passport data doesn’t just live in your own system. Upstream suppliers need to provide material breakdowns, environmental impact metrics, and chemical disclosures. Start adding these reporting demands directly into vendor contracts, purchasing requirements, and onboarding steps. This part takes the most time, so launch it right away.
Platform Selection
Look for software platforms that can manage your DPP compliance at scale. Essential features include built-in support for ESPR and Battery Regulation data models, automated GS1 Digital Link QR generation, tiered access security, direct registration with the EU Central DPP Registry, API integration with ERP/PLM systems, and multi-category support. Platforms like PassoNext are designed specifically to handle EU regulatory DPP compliance over the long haul.
Internal Governance
Assign clear internal responsibility for ESPR compliance. The Digital Product Passport isn’t just an IT project or a sustainability goal—it touches product design, purchasing, manufacturing, quality assurance, legal affairs, and IT. Put together a cross-functional group backed by executive leadership.
Pilot Implementation
Pick one product line—ideally in a priority category—and run a complete trial run. Build test passports, generate QR codes, test access tiers, double-check data accuracy, and walk through the registration workflow. Use this trial to catch integration issues, clean up bad data, and fix broken processes before official deadlines arrive.
What the ESPR Means for Non-EU Manufacturers
In short: the ESPR applies to any product placed on the EU market regardless of where it’s made, so non-EU manufacturers exporting to the EU face the same obligations, typically passed through their EU importer.
The ESPR applies to any product sold on the EU market, no matter where it was manufactured. Overseas companies exporting to the EU face the exact same obligations as European brands. Legal responsibility rests on the party placing the goods on the market—either the EU importer or an appointed authorized representative.
In practice, EU importers will expect non-EU suppliers to provide all the data needed to build passports and prove ecodesign compliance. Overseas suppliers who can’t provide this data risk losing their EU market access. Over time, the ESPR will become a global benchmark for product transparency, much like REACH changed global chemical tracking.
If you manufacture outside the EU, start working with your European buyers and importers now to align data formats and put the digital systems in place to deliver compliant data.
Summary: The ESPR at a Glance
- Regulation: (EU) 2024/1781 — Ecodesign for Sustainable Products Regulation
- Published: 28 June 2024, Official Journal of the European Union
- In force: 18 July 2024
- Scope: Nearly all physical products placed on the EU market
- Key instruments: Digital Product Passport (Articles 9-12), ecodesign performance requirements (Article 5), substance of concern restrictions, unsold goods destruction ban (Article 23)
- Implementation: Through product-specific delegated acts adopted by the European Commission
- First DPP obligations (ESPR-based): Expected 2028-2030
- Enforcement: Market surveillance authorities, customs cooperation, Member State penalty regimes
This guide outlines the legal status as of March 2026. The ESPR delegated act rollout is actively moving forward, with new rules published progressively. You can follow delegated act updates, open consultations, and deadline trackers via Regulatory Radar on passoNext.digital.
What This Means For Your Business
The ESPR is the most important European product law introduced since the CE mark. It establishes a mandatory framework for Digital Product Passports across almost every physical product category sold in the EU. While the main ESPR law doesn’t list immediate product-level deadlines, the coming delegated acts will—and work is already well underway for textiles, electronics, tyres, and furniture.
Companies that hold off on setting up their passport processes until final delegated acts are published will find themselves under intense pressure. Gathering supply chain data, mapping suppliers, and connecting IT systems takes months of steady effort.
Action Steps
- Identify which ESPR delegated acts will affect your product categories.
- Track delegated act development via the ESPR Delegated Acts Tracker.
- Begin collecting product data now — material composition, environmental footprint, supply chain origin.
- Evaluate your supply chain readiness for upstream data sharing.
- Start with a free PassoNext account to understand the data structure before deadlines are set.
- What is a DPP?
- EU Battery Regulation
- ESPR 2024/1781
- EU Deforestation (EUDR)
- EU Packaging (PPWR)
- Mandatory Fields
- GS1 Digital Link
- EU Central Registry
- Registry Operator Guide
- Registry Regulation 2026/1778
- GDPR & DPPs
- REACH & SVHC
- Access Rights (PoLI)
- Compliance FAQ
- Deferred Data Points
- Delegated Acts Tracker
Frequently asked questions
What is the ESPR regulation?
The EU Council formally adopted the regulation implementing the Ecodesign for Sustainable Products Regulation (ESPR) on 13 June 2024, and it has been in force since 18 July 2024. Regulation (EU) 2024/1781 aims to replace the 2009 Ecodesign Directive. ESPR is a horizontal regulation that enables the Commission to introduce product-specific ecodesign and information requirements (including mandatory DPPs) for any goods sold in the EU. The Regulation applies to every category of goods, except food, feed, medicinal products, and a few explicitly excluded goods.
What products does ESPR apply to?
ESPR is a framework regulation, with specific sectors brought into its scope through delegated acts (see below). The 2025-2030 working plan prioritizes textiles, furniture, tyres, iron and steel, aluminum, chemicals, ICT and consumer electronics, and construction products. Batteries are explicitly excluded from ESPR as they are subject to a dedicated Regulation (2023/1542). Food, feed, medicinal products, live plants, living organisms, and motor vehicles subject to the Type Approval framework are outside the scope of ESPR.
When does ESPR apply?
The framework Regulation has been in force since 18 July 2024; obligations for specific product categories enter into force only once a delegated act for that category is adopted. The first delegated acts (iron and steel, textiles, tyres) are expected to enter into force in late 2026 or 2028, with an 18- to 36-month transition period before DPPs and information requirements enter into force for each category.
How does ESPR differ from the previous Ecodesign Directive?
The previous Ecodesign Directive (2009/125/EC) was limited to energy-related products, focused on energy-efficiency requirements, and had a limited scope. ESPR covers all physical products, not only those related to energy; it introduces new requirements (durability, reparability, recycled content), sets minimum requirements for the content and use of recycled materials, introduces the Digital Product Passport (DPP) as a mandatory standardised set of information for any goods, introduces a ban on the destruction of certain unsold consumer goods, sets performance classes and requires disclosing additional product-specific information to consumers.
What are delegated acts and how are they developed?
Delegated acts under ESPR are implementing acts that set out delegated powers for specific product categories. Each delegated act sets out the products falling under its scope, the mandatory DPP information fields, performance requirements, information requirements, verification rules, and the transition period for applying the requirements. The Ecodesign Forum develops the delegated acts through a stakeholder consultation process. The Ecodesign Forum publishes draft delegated acts for consultation before formal adoption.
What is the destruction-of-unsold-goods ban?
ESPR (Article 25) bans the destruction of unsold consumer products in certain categories. This will apply to clothing, clothing accessories and footwear from 19 July 2026 for large companies (i.e., more than 1,000 employees or €50 million turnover in any one of the last three financial years). Medium-sized companies (excluding those that fall under the large-company definition) have a six-year transition period, while small companies are entirely exempt. Additional product categories will be added to the scope of the destruction ban through delegated acts. Large and medium-sized companies subject to the destruction-of-unsold-goods ban must publish the number and weight of products destroyed, plus the rationale for the decision.
What are the performance and information requirements?
Under ESPR, there are two types of requirements – performance requirements and information requirements. Performance requirements include minimum material durability, carbon footprint thresholds, minimum recycled content, etc., while information requirements specify what information must be provided and made available to the public, including information on materials used, chemicals of concern, reparability scores, service life, end-of-life treatment instructions, etc. For each category, a delegated act sets out the requirements and defines the mandatory content of the DPP.
How does ESPR interact with the Battery Regulation?
Regulation (EU) 2023/1542 on batteries is entirely separate from ESPR – batteries are explicitly excluded from the application of ESPR. Both the Battery Regulation (2023/1542) and ESPR utilise the same DPP architecture, GS1 Digital Link specification for the data carrier and the EU Central DPP Registry. Economic operators placing both batteries and other goods subject to ESPR on the EU market should comply with both regulations but can use a single DPP service provider and a single authoring process for both regulations.
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