ESPR
ESPR Ecodesign Performance Requirements
ESPR is not only about the DPP. What minimum thresholds for durability, repairability, recyclability and resource efficiency will actually require.
A fact often skipped in DPP conversations: the Digital Product Passport is ESPR's information instrument. The regulation's real teeth are its performance requirements — the minimum thresholds the product itself has to meet.
Which criteria?
ESPR Annex I lists the criteria delegated acts can draw on:
| Criterion | Example threshold |
|---|---|
| Durability | Minimum cycles, washes or service life |
| Reliability | Failure rate, test conditions |
| Reusability | Ability to be disassembled and reused |
| Upgradability / repairability | Spare part availability period, disassembly steps |
| Recyclability | Ease of material separation |
| Recycled content | Minimum share |
| Energy and resource efficiency | Consumption limits |
| Hazardous substances | Restrictions |
| Carbon and environmental footprint | Declaration or limit |
Repairability scoring: a horizontal measure
The Working Plan foresees a product-group-independent repairability score for electronics and small appliances (indicative 2027). Scoring typically looks at ease of disassembly, tools required, spare part availability and price, access to repair manuals, and software update duration.
See the Right to Repair Directive and DPP for home appliances.
How performance and passport intersect
Performance requirements change the product; the passport proves it. For example:
- If a delegated act requires spare parts for 10 years, the passport carries the parts list and availability period.
- If it requires at least 20% recycled content, the passport carries the share and a reference to the evidence. See proving recycled content.
- If it requires a disassembly test, the passport references the test report.
Data preparation therefore cannot be separated from design compliance.
The other instruments
ESPR also brings:
- A ban on destroying unsold goods (Art. 25). See the destruction ban.
- Green public procurement criteria.
- Labelling obligations for specific product groups.
Frequently asked questions
Do performance thresholds apply already?
No; they arrive with each product group's delegated act. For energy-related products, the old Ecodesign Directive thresholds continue and transfer into ESPR.
What happens if my product misses a threshold?
It cannot be placed on the EU market. That is a harder consequence than a passport gap: missing data can be fixed, a design shortfall removes the product from the market.
How long do I get to change a design?
The transition period — typically 18–36 months. For products with long design cycles that is short, so preparation has to start early.
