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EURegulation guide

# EU Ecodesign for Sustainable Products Regulation (ESPR)

ESPR 2024/1781 fundamentally expands the EU's product sustainability framework beyond energy efficiency. The Digital Product Passport is its most novel mechanism — a data carrier that follows the product from manufacture to end of life, accessible to consumers, regulators, and recyclers. For hardware makers, this is the most significant new compliance architecture since the CE system was established.

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At a glance

Key changes from ErP

4

Priority product categories

10

DPP data requirements

7

## What changed from ErP to ESPR

ErP Directive 2009/125/EC→ESPR Regulation 2024/1781

ESPR entered into force on 18 July 2024. Existing ErP product-specific regulations (delegated regulations for TVs, lighting, motors, etc.) remain valid until replaced by new ESPR delegated acts.

Energy efficiency only→Circular economy parameters

ESPR expands requirements beyond energy consumption to cover durability, reparability, recyclability, recycled content, carbon footprint, chemical content, and resource efficiency.

No product passport→Digital Product Passport (DPP)

ESPR introduces the Digital Product Passport — a machine-readable record accessible via QR code or similar technology, containing sustainability data, materials, and repair information.

Products only→Products + ICT software

ESPR can extend to software products and services that have a significant environmental impact, broadening the potential scope beyond physical products.

## Digital Product Passport — what it must contain

The DPP is a product-level data record accessible via a data carrier (QR code, RFID, or similar) affixed to the product or its packaging. Specific content requirements are set in delegated acts for each product category — but ESPR defines the general data architecture.

01

Unique product identifier — linked to a specific product unit or batch

02

Supplier and manufacturer information — for traceability throughout the supply chain

03

Material composition and hazardous substance content — including restricted substances

04

Durability and repairability information — expected lifetime, spare parts availability, repair instructions

05

End-of-life instructions — disassembly guidance, recyclability, waste classification

06

Carbon footprint data — where required by delegated regulation for the product category

07

Access controls — read access for consumers, regulators, and recyclers; write access controlled by manufacturer

## Frequently asked questions

### Do existing ErP-regulated products need to comply with ESPR immediately?

No. Existing ErP delegated regulations — covering products like TVs, lighting, motors, refrigerators, and washing machines — remain in force until they are specifically replaced by new ESPR delegated acts. Manufacturers of currently ErP-regulated products should continue to meet existing regulations while monitoring when their product category is updated under ESPR.

### When will the Digital Product Passport be required?

The DPP will be required progressively as product-specific delegated regulations under ESPR are adopted. The first working plan identifies priority product groups — textiles, furniture, and ICT products are expected among the earliest targets. There is no single universal DPP deadline; it depends on when the specific delegated act for your product category enters into force.

### Does ESPR affect CE marking requirements?

ESPR itself does not introduce CE marking — it is a sustainability regulation, not a safety directive. However, compliance with applicable ESPR delegated regulations is a condition for placing products on the EU market, parallel to CE marking requirements. Products that comply with safety directives but fail applicable Ecodesign performance requirements cannot legally be sold in the EU.

### Is the ESPR the same as Energy Labelling?

No. Ecodesign (ESPR) sets minimum performance thresholds — products that do not meet them cannot be sold. Energy Labelling (Regulation EU 2017/1369) requires energy efficiency information to be displayed to consumers so they can compare products. The two frameworks are complementary: Ecodesign sets the floor, Energy Labelling informs above-floor purchasing decisions.

**Disclaimer:** Educational resource only. ESPR delegated acts for specific product categories are still being developed. Monitor the European Commission ESPR working plans for your product category to stay ahead of implementation timelines.

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