The ESPR Guide: Ecodesign Regulation and the DPP

ESPR — the Ecodesign for Sustainable Products Regulation, (EU) 2024/1781 — is the European Union's framework regulation for making products more durable, repairable, recyclable and transparent. It entered into force on 18 July 2024, replacing the old Ecodesign Directive (2009/125/EC) and widening the scope from energy-related products to almost every physical product.

The Digital Product Passport is ESPR's most visible instrument — but not its only one.

What ESPR changed

The old Ecodesign Directive covered only energy-related products — appliances, lighting, motors — and focused largely on energy efficiency. ESPR widened this on three fronts:

1. Scope: every physical product on the EU market, with narrow exceptions such as food, feed and medicinal products.
2. Criteria: durability, repairability, reusability, recyclability, recycled content, carbon and environmental footprint and hazardous substances now sit beside energy efficiency.
3. Instruments: performance requirements plus information requirements — and the vehicle for the latter is the Digital Product Passport.

See from the Ecodesign Directive to ESPR for the transition detail.

How the framework works: the delegated act mechanism

ESPR itself imposes no duty on any product. The sequence is:

1. The Commission publishes a working plan naming priority product groups.
2. The JRC runs a preparatory study for the group and proposes the data content.
3. The Commission drafts a delegated act and runs a public consultation.
4. The act is adopted; Parliament and Council have a scrutiny window.
5. It enters into force, starting a transition period of typically 18–36 months.
6. When that period ends, the DPP becomes mandatory for that product group.

See what a delegated act is. The practical consequence: the answer to "when is the DPP mandatory?" depends on the product group and is not fixed in the regulation.

The Working Plan 2025–2030

COM(2025) 187, published on 16 April 2025, narrowed roughly 33 candidate categories down to six product groups and two horizontal measures:

The first textile wave covers apparel and accessories only; footwear sits outside it. Energy-related products transfer across from the old directive: dishwashers in 2026, EV chargers and refrigeration in 2028, phones and tablets in 2030.

See the ESPR working plan 2025–2030 and the timeline guide.

ESPR obligations beyond the passport

Focusing only on the DPP misses the rest of the regulation:

• Ecodesign performance requirements: minimum thresholds for durability, repairability and resource efficiency. See ESPR ecodesign performance requirements.
• Ban on destroying unsold goods (Art. 25): live for large companies in textiles and footwear since 19 July 2026; medium-sized companies follow in 2030, SMEs are exempt. See the destruction ban.
• Green public procurement: sustainability criteria in public tenders.
• Labelling: visual label requirements for specific product groups.

Who does it cover?

ESPR targets the economic operator placing a product on the EU market. For a manufacturer exporting from Türkiye, China or the US, the direct duty falls on the EU importer or authorised representative — but the data request travels down the contract chain to the manufacturer regardless.

• Manufacturer (EU-based): creates and maintains the passport.
• Importer / authorised representative (for non-EU manufacturers): takes on the same duties.
• Distributor: verifies that a compliant passport and carrier exist.
• Online marketplace: performs the same check before listing.

See economic operators and their duties.

Enforcement and penalties

Enforcement runs through Market Surveillance Regulation (EU) 2019/1020. Member States set their own penalty regimes; ESPR requires them to be "effective, proportionate and dissuasive" and allows measures such as temporary exclusion from public procurement. At the border, a mismatch between the registered identifier and the declared commodity code can block release for free circulation.

See market surveillance and enforcement and DPP checks at EU customs.

What it means for an exporter

Three questions summarise your exposure:

1. Is my product group on the list? Even if it is not, your brand or retailer customer will ask you for the data.
2. Is my data ready? Fibre shares, origin, recycled content and carbon data are missing at most manufacturers today.
3. Who will maintain it? A passport is not a one-off document; it is a living, versioned record.

Start with the EU exporter compliance checklist and the SME guide.

Frequently asked questions