Not systematically, but almost always in practice. Almost all sector-specific delegated acts require the carbon and environmental footprint measure, calculated using an LCA aligned with the European Commission's PEF (Product Environmental Footprint) method. Without an LCA, it is impossible to produce the footprint. Even where a delegated act does not request the footprint, LCA remains essential for managing the other measures (recyclability, recycled content, durability). The good news: a well-scoped LCA serves ESPR, CSRD for ESRS E1, environmental labelling and public procurement simultaneously.
Read the source article: ESPR: obligations and timetable for the Ecodesign Regulation