Navigating Ecodesign for Sustainable Products Regulation (ESPR)
Introduction
The Ecodesign for Sustainable Products Regulation (ESPR) is the European Union's new framework aimed at increasing the sustainability of products sold on the EU market. Entering into force on July 18, 2024, it replaces the 2009 Ecodesign Directive as a key initiative to help the EU achieve its goals outlined in the 2020 Circular Economy Action Plan (CEAP). ESPR and CEAP are both significant policy levers introduced by the European Commission to address the environmental impact of products and promote a circular economy.
ESPR's implementation will be guided by “Working Plans” developed by the Ecodesign Forum, a group of stakeholders collaborating on the regulation's rules. These plans will outline which products and measures are being assessed, with the first Working Plan to be published within 9 months of ESPR’s entry into force.
What is ESPR aspiring to do
ESPR aims to extend the life cycle of products, reduce waste, empower consumers with better sustainability information, and remove unsustainable products from the market. By prioritizing sustainability, circularity, and energy efficiency, ESPR seeks to drive a more sustainable future for products sold in the EU.
Key components of ESPR include:
Ecodesign Requirements for specific products or product groups.
Digital Product Passport (DPP) for enhanced product transparency.
Ban on the Destruction of Unsold Products to reduce waste.
What disclosures are required
The core of ESPR is the ecodesign requirements for products or categories with similar characteristics. These rules are divided into “performance” and “information” indicators designed to enhance the sustainability and transparency of nearly all products sold on the EU market, with certain exceptions such as food and medical products.
These requirements will be rolled out progressively on a product-by-product basis or horizontally for products within the same category. While specific details are pending, examples of potential requirements include:
Product durability
Recyclability
Reusability
Energy usage
What is the Digital Product Passport (DPP)
The DPP serves as a digital identity card for products, providing details on their sustainability, increasing knowledge of the value chain for various stakeholders, and encouraging compliance with ecodesign requirements. Information on the DPP will be determined by the European Commission and may include:
Product’s origins and materials
Recyclability
Reusability
Technical performance
This tool aims to improve traceability and compliance, ultimately boosting consumer trust in the sustainability of products.
Ban on Destruction of Unsold Products
To address waste from unsold products, ESPR will feature a ban on the destruction of unsold textiles and footwear, with the possibility of expanding to other sectors. This measure targets the reduction of wasted energy and resources from the production and destruction processes.
The European Commission will also develop a reporting framework for companies to disclose details on their unsold products, promoting accountability and transparency.
Who Does ESPR Apply To
ESPR applies to all companies, both EU-based and global, that sell products on the EU market, including online sales, with specific exemptions for food and medicine. Companies failing to comply may face penalties from member states.
While ecodesign requirements will be introduced progressively, the following categories will be prioritized:
Iron & steel
Aluminum
Tyres
Detergent
Paint
Energy-related products
Lead
Chemicals
ICT products
Textiles
Electronics
Furniture
Key dates
The first Working Plan being published in Q2 of 2025 will include specific deadlines
July 18, 2024: ESPR entered into force.
Q2 2025: First Working Plan will be published, detailing ecodesign requirements for specific products and covering at least three years.
2025: Introduction of the first rules to implement the ban on the destruction of unsold goods.
2026: EU Commission to set up a digital product passport registry
How companies can prepare for ESPR
Review Products and Value Chains: Conduct Life Cycle Assessments (LCAs) to identify areas for improvement and assess the environmental impact of raw materials, manufacturing processes, and product disposal.
Assess Business Operations: Evaluate business operations, including manufacturing partners and data collection systems, to ensure alignment with ESPR requirements.
Monitor ESPR Updates: Stay informed about ESPR regulations, including the First Working Plan expected in Q2 2025 as well as new delegated acts beginning in 2028, to develop an effective ESPR strategy.
Gather Relevant Information: Begin collecting data on product performance indicators (i.e. recyclability, repairability, reusability, durability), product origins for the Digital Product Passport, and metrics on products destroyed annually.
Our recommendation
While the ESPR rules will be rolled out progressively, companies should not wait to take action. By acting now, your company will not only be ready to comply with ESPR but will also demonstrate leadership in sustainability, strengthening your reputation and positioning your business for long-term success in a more circular economy.
Where Bespoke ESG Can Support
Bespoke ESG helps companies navigate ESPR compliance with tailored solutions:
Regulatory Guidance: We stay updated on ESPR rules, breaking down requirements into clear, actionable steps for your business
Data & Reporting Support: We guide data collection for sustainability metrics to ensure companies are prepared for the requirements that will be laid out in the first Working Plan
Life Cycle Assessments: We conduct LCAs to help you reduce environmental impact and align with ESPR’s sustainability goals
Sustainability Strategy: We help you go beyond compliance and use regulation as a foundation for your sustainability strategy to drive innovation and long-term business valueDisclaimer: The information provided in this document is for general informational purposes only and does not constitute legal advice. Regulatory advice is provided solely within the scope of contracts between Bespoke ESG and its clients.
Disclaimer: The information provided in this document is for general informational purposes only and does not constitute legal advice. Regulatory advice is provided solely within the scope of contracts between Bespoke ESG and its clients.