The EU ESPR explained: What manufacturers need to know

The EU’s original ecodesign rules, established in 2009, applied only to energy-related products. However, the Ecodesign for Sustainable Products Regulation (ESPR), which came into effect on 18 July 2024, extends sustainability requirements to nearly all physical goods sold in the EU market, a scope shift that affects manufacturers across nearly every product category.

Getting clear on what the ESPR actually requires, which products are in scope, the compliance timeline, and what you need to do now to get your product data and operations ready is where to start.

What does the ESPR require manufacturers to do?

Beyond ecodesign requirements for individual product groups, the ESPR introduces three broader measures, each carrying its own compliance implications depending on your product category and business size.

1. Digital Product Passports

The ESPR requires manufacturers to attach a Digital Product Passport (DPP) to their products, a structured, electronically accessible record that stores sustainability information about a product, its components, and the materials it contains. The goal is to provide consumers, manufacturers, and regulatory authorities with consistent, verifiable product data at any point in the product’s lifecycle.

The exact information required in each DPP will vary by product group and will be defined through delegated acts (the product-specific rules). Based on what the Commission has outlined, that information can include:

• A product’s technical performance
• Materials and their origins
• Repair activities
• Recycling capabilities
• Lifecycle environmental impacts

Customs authorities will also be able to use DPP data to run automatic checks on imported products, which means the accuracy and completeness of your product data carries regulatory weight beyond just EU market access.

2. The ban on destroying unsold goods

Destroying unsold inventory has long been standard practice across retail and manufacturing. The ESPR addresses this directly, introducing the first EU-wide ban on the destruction of unsold textiles and footwear, and leaving room for similar bans in other sectors if evidence supports it.

Large companies across all product sectors will also be required to publish annual disclosures covering the number and weight of unsold consumer products they discard, along with their reasons for doing so. 

Medium-sized companies will eventually face the same requirement, so even manufacturers whose products are not yet subject to a destruction ban should expect reporting obligations to apply.

3. Green Public Procurement

Public authorities across the EU spend around €1.8 trillion annually on works, goods, and services. The ESPR enables the EU to set mandatory Green Public Procurement (GPP) rules for specific product categories, requiring public buyers to purchase only products that meet the highest levels of sustainability and circularity performance. 

Manufacturers selling into public-sector channels will need to meet those thresholds to remain eligible for procurement contracts, creating direct commercial pressure to meet ESPR performance requirements.

Which products are covered by the ESPR?

The first ESPR and Energy Labelling Working Plan 2025–2030, adopted in April 2025, sets out the priority product groups for the current regulatory cycle and the indicative timelines for the adoption of their delegated acts. 

The new products covered in the plan account for nearly €500 billion in annual EU market sales, and the full basket of regulated products, including energy-related categories, represents approximately 31% of the climate change impacts of overall EU consumption.

Priority product groups: 2025 to 2030

Two horizontal measures covering repairability and recycled content for electrical and electronic equipment are also included in the working plan, with indicative adoption years of 2027 and 2029, respectively. ICT products fall within the scope of these horizontal requirements rather than standing as a separate product group.

Footwear, detergents, paints, lubricants, and chemicals are not included in the first working plan. Footwear and chemicals are subject to preparatory studies during this cycle and could appear in a future working plan. If your products fall into any of those categories, the mid-term review scheduled for 2028 is worth monitoring closely, since the Commission will use it to reassess which products to add.

Energy-related products already regulated under the old Ecodesign Directive, covering 16 product groups including displays, household washing machines, refrigerating appliances, and mobile phones and tablets, carry forward into the ESPR working plan, with adoption timelines running through to the end of 2030.

ESPR key requirements explained

The ESPR splits its requirements into two distinct categories: performance requirements and information requirements. The difference matters because each places different demands on your operations, your supply chain, and the product data you need to collect and maintain.

Performance requirements

Performance requirements set minimum standards for how a product must be designed, built, and resourced. The regulation allows the EU to mandate improvements across a wide range of product attributes, including:

• Durability, reusability, upgradability, and reparability
• Energy and resource efficiency
• Recycled content
• Recyclability and ease of remanufacturing
• Availability of spare parts
• Reduction of substances that inhibit circularity
• Carbon and environmental footprint limits

The specific thresholds and attributes that apply will vary by product group and will be defined in each delegated act. A delegated act for textiles will set different performance parameters than one for steel or furniture.

Information requirements

Information requirements govern what data must be collected, structured, and made available about a product. Under the ESPR, this primarily means supplying the data that feeds into the DPP, including specific data points on any substances of concern present in the product, which vary by product group and are confirmed under each delegated act.

The Working Plan makes clear that, for some product groups, the Commission may initially set only information requirements, particularly for intermediate products such as steel and aluminum, where the downstream implications of performance mandates require more careful assessment before rules are finalized.

ESPR compliance timeline: Key dates and deadlines 

Product-specific deadlines are now rolling out through 2030 under the first ESPR and Energy Labelling Working Plan. Dates marked as indicative below reflect the Commission’s current planning and will only be confirmed once the relevant delegated act is formally adopted.

Additionally, the 2028 mid-term review is a date worth tracking even if your product category isn’t yet in scope. The Commission will use it to reassess the Working Plan and could add product groups currently under preparatory study, including footwear and chemicals.

Why ESPR is a product data problem first 

The regulation’s information requirements covering material origins, recycled content levels, repairability details, and substances of concern must be collected, maintained accurately, and shared in a structured format that machines can read and regulators can verify. Scattered product data across spreadsheets, supplier emails, or disconnected systems is where the difficulty starts.

The deeper issue runs further into your supply chain. The DPP requires you to trace material and component claims back to the source, which means your tier-two or tier-three suppliers need to provide data in a format you can actually use. If they can’t, your DPP will have gaps, and gaps carry real regulatory risk, given that customs authorities will use DPP data to check imported goods at the border.

Requirements will also vary across your portfolio depending on which delegated act applies to each product category, and those acts will continue rolling out through 2030. Keeping track of what’s required for each product and ensuring the right data is collected and kept up to date becomes very difficult without a centralized system to manage it.

Product Information Management (PIM) is where the regulation’s data demands become practically manageable. A PIM system provides a centralized place to collect sustainability data from suppliers, structure it consistently across your product catalog, and distribute it in the formats DPPs require, making supply chain transparency a practical reality rather than a task to rush before compliance deadlines.

How should you prepare for ESPR compliance?

The delegated acts defining your specific compliance obligations haven’t all been published yet, and that’s no reason to wait. The manufacturers best positioned when deadlines arrive are those building their data foundations now.

Here are six practical steps to get started:

1. Map your product portfolio against the Working Plan

Cross-reference your catalog against the ESPR and the Energy Labelling Working Plan 2025–2030 to identify which product categories are in scope and when their indicative delegated-act deadlines fall. 

Iron and steel have an indicative adoption date of 2026; furniture and mattresses have adoption dates of 2028 and 2029, respectively. Your position on that timeline determines how urgently the steps below need to be taken.

2. Audit your current product data

Measure what you currently hold against what the ESPR will require: material origins, recycled content, repairability information, substances of concern, and lifecycle environmental impacts. Most manufacturers will find gaps. 

Pay particular attention to whether your data is structured and machine-readable, since the DPP requires information in formats that systems can process automatically, not just in formats humans can read.

3. Evaluate your data infrastructure

Assess whether your current systems can collect sustainability data from suppliers, maintain it accurately over time, and distribute it in the structured formats that DPPs require. A spreadsheet-based approach won’t scale across a large portfolio with multiple product categories and staggered delegated act timelines. Identifying that gap early gives you time to implement the right infrastructure before deadlines arrive.

4. Engage your suppliers early

Your DPP is only as accurate as the data your supply chain provides. Start conversations with key suppliers about what sustainability data they currently collect, in what format, and how reliably they can share it. Multi-tier supply chains add complexity here, and the earlier you surface gaps at the supplier level, the more time you have to address them without the pressure of a deadline.

5. Monitor delegated act developments for your product categories

The delegated act for your specific product group will define exactly what you need to comply with and when. Follow the Ecodesign Forum process, which involves public consultation before any act is finalized, to get advanced visibility into likely requirements. Use the indicative timelines in the Working Plan as planning triggers rather than confirmed deadlines.

6. Pilot a DPP workflow before it’s mandatory

Run a pilot DPP workflow on one product line before any delegated act forces your hand. Select a category with an earlier indicative deadline, map out the data you’d need to populate a compliant DPP, and test whether your systems and supplier relationships can deliver it. A pilot surfaces format mismatches, supplier gaps, and process bottlenecks while you still have time to fix them.

Get ahead of ESPR before your delegated act drops

The regulation is live, the Working Plan is set, and the first delegated-act deadlines begin in 2026. If your product categories are already in scope, getting your product data in order now is more practical than scrambling once a delegated act confirms your obligations.

Your Digital Product Passport readiness is a good place to start. Manufacturers in fashion, footwear, or apparel face DPP requirements with specific implications worth understanding early. Furniture manufacturers can find sector-specific guidance relevant to their category, and footwear producers should review the DPP requirements for footwear closely, given the preparatory study already underway for that sector.

Speak a customized demo with our team to see how Inriver can help you prepare for DPP and ESPR.