- 1ESPR (EU Regulation 2024/1781) extends ecodesign from 31 categories to almost all goods.
- 2Framework regulation plus delegated acts: the framework is set, quantified requirements arrive sector by sector.
- 3Six priority product groups: textiles, mattresses, iron and steel, aluminium, furniture, tyres between 2026 and 2029.
- 4Seven ecodesign measures, a mandatory DPP and a prohibition on destroying unsold clothing and footwear.
The regulation that reshapes eco-design in Europe
The ESPR (Ecodesign for Sustainable Products Regulation) does not set a climate target: it sets the conditions for being allowed to sell a physical product in Europe. Four figures to frame the topic.
1ESPR in one sentence
ESPR is the European regulation setting ecodesign conditions for almost all physical products placed on the European Union market. Official legislation: Regulation (EU) 2024/1781, adopted on 13 June 2024, in force since 18 July 2024, available on EUR-Lex. It replaces the old Ecodesign Directive 2009/125/EC, which covered only energy-related products (fridges, light bulbs, electric motors, boilers: 31 categories in total).
The change in scale is radical: from 31 categories to a scope that will eventually cover almost all manufactured goods sold in Europe. Food, medicines, living organisms and defence products are explicitly excluded; everything else is in its sights, wave after wave.
No ESPR compliance, no placing on the market. It is that simple, and that fundamental.
To understand the change in figures, the infographic below sets out the four reference points underpinning the rest of the article.
2From the Green Deal to your product sheet: the legal architecture
ESPR did not come out of nowhere. It is part of a European mechanism that moves from policy to technical details through four levels. Understanding these levels means understanding why we do not (yet) have all the answers about what will apply to a given product.
From the Green Deal to your product sheet: 4 levels
The ESPR did not come out of nowhere. It fits into a European mechanism that descends from the political to the technical, down to the product you hold in your hand.
Level 1: the European Green Deal (2019). The political roadmap: climate neutrality in 2050, a circular economy, a just transition. This sets the direction.
Level 2: the Circular Economy Action Plan (March 2020). 35 practical measures to translate the Green Deal into sector policies. Among them: revise the Ecodesign Directive and extend it to a broader range of products. This is where ESPR originated.
Level 3: ESPR itself (EU 2024/1781). The framework regulation. It sets out the terminology (declarant, placing on the market, ecodesign requirements), methods (PEF, LCA), cross-cutting obligations (DPP, EU declaration of conformity, prohibition on destroying unsold goods), penalties and market surveillance procedures. But it sets almost no quantified requirements itself: this is the key point to understand.
Level 4: sector-specific delegated acts (2026 onwards). This is where precise requirements are set, product category by product category. Textiles will have their delegated act, steel its own, furniture its own, and so on. In April 2025 the European Commission published its ESPR Working Plan 2025-2030, listing priority product groups.
A helpful analogy: a highway code defining "motor vehicle", "public road" and "administrative penalty" without immediately specifying which speeds are allowed on which roads. The speeds then arrive, road by road. Until your product group's delegated act is published, you have no quantified obligation, but the timetable is public and the intended outcomes are known.
3What ESPR actually requires of your product
Regulation (EU) 2024/1781 lists seven ecodesign measures that the Commission can activate in each delegated act (Articles 5 to 7). The idea is not that all seven apply to every product group: each delegated act selects what is relevant to the product concerned. A textile delegated act will mainly involve durability, recycled content, recyclability and footprint. A steel delegated act will emphasise resource efficiency and carbon footprint. The infographic below lets you explore the seven measures, with a sector example for each.
What ESPR actually requires of your product
ESPR does not set a single objective: it lists 7 ecodesign measures from which each delegated act selects the requirements relevant to the product group concerned. Click a measure.
Declare the product footprint calculated through LCA (PEF method).
Three cross-cutting requirements almost always added
1. The Digital Product Passport (DPP). An electronic product identity sheet, accessible by QR code, making its composition, environmental footprint, repair and end-of-life instructions traceable. The DPP is covered in depth in our manufacturing guide: this is the element that makes ESPR compliance tangible for consumers and authorities.
2. The prohibition on destroying unsold goods. For clothing, clothing accessories and footwear, destroying unsold goods has been prohibited for large businesses since 19 July 2026 (Article 25 and Annex VII of the regulation). The Commission may extend the list to other product groups through delegated acts. This measure alone is changing fast fashion's overproduction logic.
3. The EU declaration of conformity. As with CE marking, the party placing the product on the market must sign a formal declaration attesting that it complies with the applicable delegated act. A legally enforceable document, kept for 10 years and available to any market surveillance authority.
4Does ESPR affect me, and when?
Three criteria are enough to place a business on the ESPR map: does it place products on the European market (manufacturer, importer or own-label retailer)? Is its product in a priority group? Does it already have a usable LCA? The decision tree below combines the three to give a verdict and the resulting priority action.
Am I affected by the ESPR, and when?
Three questions to place your company on the ESPR map: declarant scope, application wave and the critical path to prepare.
The 6 priority product groups identified in the ESPR Working Plan 2025-2030 are: iron and steel (delegated act expected in 2026), textiles and clothing (2027), tyres (2027), aluminium (2027), furniture (2028, see our furniture ESPR/DPP guide), and mattresses (2029). Batteries are not on this list because they already have their own regulation, the Batteries Regulation (EU) 2023/1542, which acts as a full-scale pilot for the entire ESPR mechanism.
For the complete map of the seven overlapping regulations (ESPR, DPP, CSRD, BEGES, CBAM, batteries, environmental labelling) and their sector-by-sector timetable, the manufacturers' ESPR/DPP/timetable guide gives the overview. This article focuses on ESPR and its operational implications.
5What changes for product teams
ESPR is not a legal matter you can outsource to the compliance department. It is a transformation affecting four internal functions simultaneously. Here is what changes for each.
R&D and eco-design
Eco-design moves from an exploratory option to a product specification. In practice: incorporate durability, repairability, recyclability and recycled content criteria from the design stage. Use life cycle assessment (product LCA) as a design tool, rather than only for communication. Learn the PEF method and its relationship to conventional LCA, because this is the basis for delegated acts.
The step underpinning everything else: launch a pilot LCA on the flagship product. To learn the method and identify the product's hotspots, rather than for communication. This LCA will then provide the basis for upcoming obligations and processes: DPP, environmental labelling, CSRD for ESRS E1, public procurement. It is the most cost-effective investment in the project.
Supply chain and purchasing
The DPP requires traceability down to supply chain tiers 2 and 3 (suppliers' suppliers). For steel, this means knowing the ore's origin. For textiles, it means tracing back to the spinner and grower. Purchasing becomes the guarantor of the quality of data feeding the Digital Product Passport.
Three practical actions: add ESPR clauses to supplier contracts (data transmission, possible audits), build a standardised supplier questionnaire on relevant ESPR criteria, and anticipate response times: an Asian supplier rarely responds in less than three months on environmental data.
Quality and compliance
The ESPR EU declaration of conformity follows the same model as CE marking. It is signed by an executive, legally enforceable, kept for 10 years and available to any European market surveillance authority. Quality must develop the operating procedures making this declaration credible: design reviews, tests, internal audits, managing deviations.
Note: ESPR documentation will be reusable across products once the first product is established. ESPR compliance is not a one-off: it is a product quality system that is built and then replicated.
Marketing, digital and services
The DPP is also a customer touchpoint. A QR code on the label, a mobile-first web page, useful content (repair instructions, recycled material percentage, carbon footprint, end of life). It is an opportunity to turn a regulatory obligation into a differentiation tool: something that works for a brand taking the issue seriously and backfires for one doing the bare minimum.
One point to watch: an environmental claim in the DPP becomes legally enforceable. You can no longer write "eco-designed" without evidence or communicate a product's "carbon neutrality" (targeted by the Empowering Consumers Directive (EU) 2024/825 for offsetting-based claims, applicable since 27 September 2026 but not yet transposed in France, where the Climate and Resilience Act already regulates carbon neutrality). The DPP is read by consumers, but also authorities and NGOs.
6Where to start: the 18-month roadmap
Five milestones take a catalogue unfamiliar with ESPR to a first fully compliant product in 18 months. The sequence is not linear: some milestones run in parallel, but the logical order remains as follows.
Where to start: the 18-month roadmap
Five milestones to move from a catalogue not yet prepared for ESPR to a first fully compliant product. Click on a milestone to see the detail, the internal lead and the classic pitfall.
The critical workstream. The LCA produces the carbon footprint, feeds the DPP and serves all the other obligations (CSRD, environmental labelling). Reusable, not disposable.
The critical task remains the pilot LCA: the only one that cannot be shortened (an irreducible 3 to 6 months). Starting with it saves a quarter in the overall timetable. For a French SME, the Bpifrance/ADEME Diag Éco-conception funds a substantial share of a first LCA's cost.
7Penalties and business risks
ESPR penalties are set by each Member State in accordance with the regulation's principles (Article 74). In France, this system falls under national law, with the regulation applying directly without transposition. But the European regulation itself already provides the range of instruments authorities can use, three of which have immediate business consequences.
1. Withdrawal from the market. This is the toughest penalty. The market surveillance authority can order withdrawal of a batch, or even a product, if ESPR compliance is not demonstrated. At European scale, this means stopping sales in 27 countries simultaneously.
2. Administrative fines. Their amount falls under each Member State's law: the regulation requires effective, proportionate and dissuasive penalties, without setting a ceiling or percentage of turnover. The sometimes-quoted ceiling of 4% of global turnover belongs to GDPR.
3. Exclusion from public procurement. The Public Procurement Directive (EU) 2014/24 and its French transposition already allow candidates to be excluded for documented environmental breaches. ESPR compliance becomes a de facto admission criterion. For B2B suppliers to local authorities and the state, this is a major commercial risk.
Alongside these penalties comes reputational risk. NGOs (Zero Waste Europe, EEB, Friends of the Earth) have announced that they will actively monitor implementation, and the media will follow. The first major brands exposed for ESPR non-compliance will make the news: better not to be among them.
8Key takeaways
- ESPR (Regulation (EU) 2024/1781) extends regulatory ecodesign from 31 categories to almost all physical goods sold in the EU.
- The framework regulation sets the framework, sector-specific delegated acts (2026 →) set quantified requirements group by group.
- 6 priority product groups: textiles, mattresses, iron/steel, aluminium, furniture, tyres. Delegated acts between 2026 and 2029.
- 7 ecodesign measures + mandatory DPP + prohibition on destroying unsold clothing and footwear since July 2026.
- Four internal functions affected: R&D, supply, quality, marketing/digital. Not an isolated legal matter.
- The pilot LCA remains the critical path (an irreducible 3 to 6 months). Starting here saves a quarter.
- Penalties: withdrawal from the European market, fines set by each Member State, exclusion from public procurement, reputational risk.
Sources: Regulation (EU) 2024/1781 (official EUR-Lex text), European Commission ESPR page, ESPR Working Plan 2025-2030 (DG ENV / DG GROW, April 2025), Ecodesign Directive 2009/125/EC, Empowering Consumers Directive (EU) 2024/825, PEF method (Recommendation 2013/179/EU), ADEME · eco-design, Celsius field experience 2026 (textile, furniture, electronics manufacturers).
