ESPR Explained: New Duties for Manufacturers

ESPR is a new regulation that changes how products are designed and placed on the EU market. For manufacturers, importers and distributors it means new obligations around product data. Below we explain the essentials in a practical way.

What ESPR is

ESPR (the Ecodesign for Sustainable Products Regulation), Regulation (EU) 2024/1781, is the successor to the former Ecodesign Directive. It extends ecodesign logic from energy-related devices to almost all product categories sold in the Union.

The aim is for products to be more durable, easier to repair, more material-efficient and better documented. The Digital Product Passport (DPP) is one of the key tools for achieving that aim.

From a directive to a regulation

Earlier ecodesign rules mostly covered energy-related equipment, such as washing machines or fridges. ESPR reverses that logic: instead of a narrow list of appliances it sets a broad framework that can reach almost any category of physical products.

The change of form, from a directive to a regulation, also matters. A regulation applies directly in all member states, without separate transposition into national law. That makes the requirements more uniform across the Union.

What ecodesign requirements can cover

ESPR allows requirements to be set for various aspects of a product, among them:

• durability and reliability,
• reparability and availability of spare parts,
• material efficiency and recycled content,
• reusability and recyclability,
• information provided with the product, including via the DPP.

Which of these aspects apply to a given product, and to what extent, is decided by the delegated act for its group.

A horizontal framework, not a list of requirements

The most important thing to grasp: ESPR is a horizontal framework. It sets up mechanisms — such as ecodesign requirements and the product passport — but does not itself state what specific data a given product must carry.

Detailed requirements for individual product groups come from delegated acts. Only those define the parameters, thresholds and passport data scope for a specific sector.

Who ESPR applies to

Obligations do not rest with manufacturers alone. Depending on the role, they reach various actors in the chain:

• manufacturers, who design and make the product,
• importers, who bring non-EU products to the market,
• distributors, who make them available further down the line,
• online platforms, through which products reach customers.

If you sell into the EU, it is worth establishing early which of these roles your company plays — the scope of your obligations depends on it.

The DPP as part of ESPR

The product passport is a data layer linked to a product through a unique identifier and a data carrier, such as a QR code. It is not a separate law — it is a mechanism provided for within ESPR and detailed sector by sector.

Thanks to the passport, surveillance authorities, trading partners and consumers can reach the same consistent product data. More on the concept itself in What is a DPP.

A rollout in waves

ESPR does not impose obligations on all products on a single day. The regulation works in stages — successive product groups are covered as delegated acts are adopted. This staggering is deliberate and gives companies time to prepare.

The first area with a full product passport is batteries, under a separate instrument, Regulation (EU) 2023/1542, from 18 February 2027. We map out the schedule in the ESPR timeline.

How to prepare your company now

You do not need to wait for your sector's delegated act to start. It is worth doing now:

• tidy up product data and its sources,
• identify which categories may be covered first,
• check whether suppliers can deliver the data you will need,
• consider choosing a platform to build and publish passports.

Early preparation reduces the risk of a scramble just before the deadline and lets you spread the cost over time.

What it means for importers

If you import products from outside the EU, ESPR applies to you just as it does to an EU manufacturer. The importer is responsible for ensuring the product meets the requirements and carries the required passport. In practice this means obtaining data from a foreign supplier — often much earlier than expected.

It is worth writing data requirements into supplier contracts, rather than gathering them under deadline pressure.

Compliance as an ongoing process

ESPR is not a task you tick off once and for all. Passport data must be maintained, updated and versioned throughout the time the product is on the market.

So it is better to treat compliance as a process built into daily operations than as a one-off project closed just before a deadline.

ESPR is not the only rule

ESPR does not operate in a vacuum. Other product rules apply in parallel — for example the Battery Regulation (EU) 2023/1542, the packaging regulation PPWR (EU) 2025/40, or the CBAM mechanism. These are separate instruments and should not be confused with one another.

For a company this means that, while preparing DPP data, it is worth checking straight away which of these rules affect its products. Well-organised data can often serve more than one reporting obligation.

Key takeaways

• ESPR (Regulation 2024/1781) extends ecodesign to almost all EU products.
• It is a horizontal framework — specific requirements come from delegated acts.
• Requirements can address durability, reparability, materials and product information.
• The DPP is one of ESPR's key tools, detailed sector by sector.
• Obligations arrive in waves; batteries first, from 18 February 2027.

See how CyfroPass lets you build and publish a Digital Product Passport without writing code. Visit cyfropass.pl and start with your first product.