> For clean Markdown of any page, append .md to the page URL. > For a complete documentation index, see https://tieback.io/docs/llms.txt. > For AI client integration (Claude Code, Cursor, etc.), connect to the MCP server at https://tieback.io/docs/_mcp/server. # What is the Ecodesign for Sustainable Products Regulation (ESPR)? > What the EU Ecodesign for Sustainable Products Regulation is, why it exists, how it works through delegated acts, and where the Digital Product Passport fits within it. ## Executive Summary Almost everyone who encounters the [Digital Product Passport](/docs/knowledge-base/glossary/digital-product-passport) meets it through a single acronym: [ESPR](/docs/knowledge-base/glossary/espr). The two are then routinely treated as the same thing. They are not. ESPR is a framework regulation about product design and product information across the whole European single market. The Digital Product Passport is one instrument inside it, and an important one, but it is neither the purpose of the regulation nor the whole of it. This article explains what the Ecodesign for Sustainable Products Regulation actually is, the policy history that produced it, the market problems it was written to solve, and the mechanism it uses to turn a broad framework into concrete obligations for specific products. That mechanism, the [delegated act](/docs/knowledge-base/glossary/delegated-act), is the single most important thing to understand about ESPR, because it determines what your organisation must do and when. It also introduces the ESPR Implementation Journey, an eight stage model that shows ESPR as a staged progression from European policy ambition through to market surveillance and continuous improvement, rather than as a single deadline to be met. Throughout, four things are kept strictly apart: what Regulation (EU) 2024/1781 says today, what delegated acts will decide later, what is scheduled but not yet adopted, and what is industry interpretation. Where something has not been adopted, this article says so rather than guessing. This is the first article in the Regulations section and the fifth in the learning path that begins with [What is a Digital Product Passport?](/docs/knowledge-base/digital-product-passports/what-is-a-digital-product-passport). * ESPR is Regulation (EU) 2024/1781. It entered into force on 18 July 2024 and replaced the 2009 Ecodesign Directive. - It is a framework regulation. It creates powers and machinery; it does not by itself impose detailed product requirements. - Concrete obligations arrive through delegated acts adopted per product group. Until a delegated act covers your product, ESPR imposes no product specific ecodesign or passport requirements on it. - ESPR extends ecodesign beyond energy related products to nearly all physical goods placed on the EU market, with a small set of exclusions. - The Digital Product Passport is one instrument within ESPR, introduced to make product information travel with the product. - ESPR also bans the destruction of unsold consumer goods in defined cases and creates public procurement and market surveillance provisions. - The correct question is not "when does ESPR apply to us" but "which delegated act will cover our product group, and what is its timetable". Framework TBF-005 The ESPR Implementation Journey Shows how ESPR moves from framework regulation to binding product obligations, and where an organisation sits on that path. > **Educational scope** > > This article provides general educational information about EU product regulation concepts. It > does not determine the obligations of any particular organisation or product, and it is not legal > advice. Whether ESPR and its delegated acts apply to a given product is a legal question that > depends on specific facts. ## Table of Contents * [Definition](#definition) * [Why ESPR Was Introduced](#why-espr-was-introduced) * [The Problems ESPR Is Designed to Solve](#the-problems-espr-is-designed-to-solve) * [How ESPR Works](#how-espr-works) * [The ESPR Implementation Journey](#the-espr-implementation-journey) * [How Digital Product Passports Fit Into ESPR](#how-digital-product-passports-fit-into-espr) * [What ESPR Does Not Do](#what-espr-does-not-do) * [Delegated Acts Explained](#delegated-acts-explained) * [How ESPR Affects Manufacturers](#how-espr-affects-manufacturers) * [How ESPR Affects Importers](#how-espr-affects-importers) * [How ESPR Affects Retailers](#how-espr-affects-retailers) * [How ESPR Affects Technology Teams](#how-espr-affects-technology-teams) * [How Organisations Should Prepare Today](#how-organisations-should-prepare-today) * [Common Misconceptions](#common-misconceptions) * [Frequently Asked Questions](#frequently-asked-questions) * [Key Takeaways](#key-takeaways) * [Related Articles](#related-articles) * [Related Glossary Terms](#related-glossary-terms) * [References](#references) * [About This Article](#about-this-article) * [Page Metadata](#page-metadata) * [Related Docs](#related-docs) ## Definition Regulation (EU) 2024/1781 of the European Parliament and of the Council, which establishes a framework for setting ecodesign requirements for sustainable products. It repeals Directive 2009/125/EC and empowers the European Commission to adopt product specific rules covering, among other things, durability, reusability, reparability, recycled content, energy and resource efficiency, the presence of substances of concern, and the information that must accompany a product, including through a Digital Product Passport. Two words in that definition carry most of the weight. The first is **framework**. ESPR is horizontal legislation. It sets out what kinds of requirements may be imposed, on which products, by what procedure, and with what consequences. It does not, in its own text, tell a furniture maker how durable a chair must be. That is left to subsequent acts. The second is **regulation**. Its predecessor, the 2009 Ecodesign Directive, was a directive, which means each Member State transposed it into national law with its own timing and wording. A regulation applies directly and uniformly in every Member State without transposition. This change matters commercially: it removes the national variation that firms previously had to navigate country by country. Establishes the framework for ecodesign requirements for sustainable products and for the Digital Product Passport. Repeals Directive 2009/125/EC. Directly applicable in all Member States without national transposition. Product level obligations do not exist until the relevant delegated act is adopted and its transition period expires. > **Read the framework and the act together** > > Any statement of the form "ESPR requires X of our products" is incomplete unless it names the > delegated act that imposes X. If nobody in the room can name the act, the requirement is not yet > established for that product group. ## Why ESPR Was Introduced ESPR did not appear from nowhere. It is the product design instrument of a policy programme that has been building since 2019, and reading it in that context explains most of its design choices. ### The European Green Deal In December 2019 the European Commission published the European Green Deal, a growth strategy setting the objective of climate neutrality in the EU by 2050 alongside decoupling economic growth from resource use. The Green Deal identified product policy as one of the levers: how goods are designed determines much of their eventual environmental impact, and that impact is largely fixed before the product is manufactured. ### The Circular Economy Action Plan In March 2020 the Commission adopted the new Circular Economy Action Plan. It proposed a sustainable product policy framework and, explicitly, a legislative initiative on sustainable products that would widen the existing Ecodesign Directive beyond energy related products. It also named a digital product passport as one of the enabling measures. The Action Plan is where the passport concept enters EU policy as a formal proposal rather than an idea. ### The limits of the 2009 Ecodesign Directive The Ecodesign Directive had been effective within its scope. It delivered measurable energy savings across products such as lighting, motors and household appliances. Its limitation was that scope: it applied to energy related products only. A washing machine could be regulated for efficiency; the textiles washed inside it could not be regulated at all under the same instrument. As the policy focus moved from energy consumption during use to resource use across the whole life of a product, the directive's boundary became the constraint. ESPR responds to that by keeping the working method of the directive, which industry already understood, while removing the scope limitation and adding information requirements as a first class instrument alongside performance requirements. #### Why scope was the binding constraint Under the 2009 Directive the Commission could set minimum efficiency requirements for a refrigerator, because a refrigerator uses energy. It had no equivalent power over a mattress, a cotton shirt or a tin of paint, regardless of the resource intensity of those products. ESPR removes that distinction: the test is no longer whether a product uses energy, but whether the Commission has adopted a delegated act covering it. ## The Problems ESPR Is Designed to Solve The regulation's recitals and impact assessment identify a consistent set of market failures. It is worth separating them, because different parts of ESPR address different ones. ### Products designed without regard to what happens after sale Durability, reparability and recyclability are decided at the design stage, often years before a product is sold, by people whose incentives relate to unit cost and time to market. Nothing in an unregulated market obliges those decisions to account for repair or recovery. ESPR addresses this by allowing performance requirements to be set at the design stage. ### Information that does not travel with the product A recycler receiving a product at end of life typically knows almost nothing about it: not its material composition, not whether it contains substances of concern, not how to disassemble it. That information existed once, inside the manufacturer's systems, and was lost in transit. This is the problem the Digital Product Passport is aimed at. It is an information continuity problem, not a labelling problem. ### Unverifiable environmental claims Buyers, both consumers and professional purchasers, cannot readily distinguish a substantiated sustainability claim from an unsubstantiated one. That suppresses the price premium for genuinely better products and rewards marketing over engineering. Standardised, comparable [product data](/docs/knowledge-base/glossary/product-data) is the counter measure. ### Fragmentation of the single market Where the EU does not act, Member States legislate individually, and firms face divergent national rules. Choosing a regulation over a directive, and setting requirements centrally through delegated acts, is a deliberate response to that fragmentation. ### Destruction of unsold goods ESPR contains a distinct provision, unrelated to design, prohibiting the destruction of unsold consumer products in defined circumstances, with a first application to apparel, clothing accessories and footwear, together with disclosure obligations for large operators. This is one of the few parts of the regulation that bites without waiting for a delegated act. #### Treating ESPR as an environmental reporting regime ESPR is not a corporate sustainability reporting instrument and does not replace one. Reporting regimes describe what an organisation did over a period. ESPR governs what a product is and what information accompanies it. The unit of obligation is the product, not the company year. ## How ESPR Works ESPR operates through four connected mechanisms. ### 1. A wide scope with narrow exclusions ESPR applies to physical goods placed on the EU market or put into service, including components and intermediate products. A limited set of categories is excluded, including food and feed, medicinal products for human and veterinary use, living plants and animals, products of human origin, and certain vehicles already covered by their own type approval legislation. The practical reading is that most manufactured goods are within scope of the framework, even though almost none of them are yet subject to product specific requirements. ### 2. Two families of requirements The regulation distinguishes between performance requirements and information requirements. A delegated act may set either or both. | Requirement family | What it governs | Typical form | | ------------------------ | --------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------- | | Performance requirements | Measurable properties of the product, for example durability, reparability, recycled content, energy and resource efficiency, presence of substances of concern | Minimum thresholds, prohibitions, or class based limits | | Information requirements | What must be known and communicated about the product, to whom, and by what means | Mandatory data elements, labels, and the Digital Product Passport | The Digital Product Passport sits in the second family. It is a vehicle for information requirements, not a requirement in itself. ### 3. Delegated acts as the delivery mechanism The framework empowers the Commission to adopt delegated acts that select a product group and set the requirements for it, following preparatory studies, impact assessment, consultation and a scrutiny period for the European Parliament and Council. Each act carries its own transition period. This is covered in more detail below. ### 4. Working plans that signal sequence The Commission publishes working plans setting out which product groups it intends to address and in what order. The first ESPR [working plan](/docs/knowledge-base/glossary/working-plan) was adopted in April 2025 and identifies priority groups including textiles and apparel, furniture, tyres, mattresses, iron and steel, and aluminium, along with horizontal work on reparability and recycled content. A working plan states intent and sequence. It is not itself law and does not create obligations. #### Track the working plan, not the rumour mill The working plan is the authoritative public signal of which product groups are next and roughly when. It is a far better planning input than vendor timelines or conference predictions, and it is published by the Commission in full. ## The ESPR Implementation Journey ESPR is frequently presented as a date. That framing causes bad planning, because it suggests a single point at which an organisation becomes compliant or fails to. In practice ESPR is a staged journey: policy ambition narrows into a framework, the framework narrows into acts, acts narrow into product categories, and only then does anything land on a specific organisation. What follows is that journey as a model. The ESPR Implementation Journey has eight stages. The first three have already happened. The fourth is under way. The remainder describe where obligations become real and how they continue to evolve after they do. Policy foundation 1 European Green Deal 2019 growth strategy setting climate neutrality by 2050 and identifying product design as a policy lever. 2 Circular Economy Action Plan 2020 plan proposing a sustainable products initiative and naming a digital product passport as an enabling measure. Legal framework 3 ESPR Regulation (EU) 2024/1781, in force since 18 July 2024. Creates the powers, the instruments and the procedure. Imposes no product specific requirements by itself. 4 Delegated Acts Product group specific acts adopted by the Commission after preparatory study, consultation and scrutiny. Each sets its own requirements and transition period. Product reality 5 Product Categories A defined scope of goods becomes regulated. Only at this stage does an organisation know exactly which of its products are covered and by which rules. 6 Digital Product Passports Where the act requires one, product information must be created, carried and made accessible to the audiences the act names. Operating reality 7 Organisation Implementation Design changes, supplier data collection, system and process work, and the internal ownership needed to keep information accurate over time. 8 Market Surveillance & Continuous Improvement National authorities verify compliance; the Commission reviews and tightens requirements over time. Compliance becomes an ongoing state, not a delivery date. Stages 4 to 8 repeat for every product group. An organisation with a broad portfolio will be at different stages simultaneously, which is why a single ESPR programme deadline rarely survives contact with reality. ### How to use the model The value of the journey is diagnostic. Locate each of your product families on it. * Products with no adopted or drafted delegated act sit at stage 3. Nothing is required of them yet. Preparation is a commercial choice, not a legal one. * Products named in the working plan sit between stages 4 and 5. The requirements are not final, but the direction and rough timing are public. * Products covered by an adopted act with a running transition period sit at stages 5 and 6. Scope and content are now knowable, and the work is real. * Products already subject to applicable requirements sit at stages 7 and 8, where the question shifts from delivery to maintenance. #### Planning a single organisation wide ESPR deadline Portfolios span product groups, and product groups are regulated on different timetables. Programmes built around one company wide date either over invest in products that are years from regulation or under invest in the one category that is regulated first. Plan per product group. ## How Digital Product Passports Fit Into ESPR ESPR provides the legal basis for the Digital Product Passport. It sets out what a passport is for, what general properties it must have, that access must be provided through a [data carrier](/docs/knowledge-base/glossary/data-carrier) linked to a persistent [product identifier](/docs/knowledge-base/glossary/product-identifier), that different user groups may have different access rights, and that a Commission registry will hold identifiers. It also provides for interoperability, data authentication and reliability requirements to be specified. What ESPR does not do is state the content of any particular passport. The data elements, the required granularity, who may see what, and the date from which the obligation applies are all decided in the delegated act for the product group. Two products regulated under different acts can therefore carry passports with entirely different content. The relationship is best stated as a hierarchy: | Layer | Decides | Where it is written | | --------------------------- | -------------------------------------------------------------------------- | -------------------------------------------------------- | | ESPR | That passports exist, their general properties, access mechanism, registry | Regulation (EU) 2024/1781 | | Delegated act | Which products need one, what it contains, who sees what, from when | The act for the product group | | Harmonised standards | How the requirements are met in technical terms | European standardisation work, including CEN and CENELEC | | Organisation implementation | Systems, data sourcing, governance, day to day operation | Your own architecture and processes | The four preceding articles in this learning path deal with the layers below the regulation: [what a passport is](/docs/knowledge-base/digital-product-passports/what-is-a-digital-product-passport), [who is responsible for it](/docs/knowledge-base/digital-product-passports/who-needs-a-digital-product-passport), [what it contains](/docs/knowledge-base/digital-product-passports/what-information-does-a-digital-product-passport-contain) and [how it works end to end](/docs/knowledge-base/digital-product-passports/how-does-a-digital-product-passport-work). ESPR is the law that makes Digital Product Passports possible; delegated acts are the laws that make specific passports mandatory. ## What ESPR Does Not Do Being precise about the negative space prevents most of the wasted effort seen in early programmes. * **It does not impose product requirements on its own.** Until a delegated act covers a product group, ESPR sets no ecodesign or passport obligations for products in it. * **It does not create a single central EU database of product information.** ESPR provides for a Commission registry holding identifiers and a limited set of data, not a repository of full passport content. Data remains distributed. * **It does not mandate a particular technology, vendor, file format or platform.** It fixes outcomes, such as accessibility through a data carrier, and leaves the means open, with technical detail left to standards. * **It does not replace product safety, chemicals or sector legislation.** Obligations under instruments such as REACH, general product safety rules or the Construction Products Regulation, Regulation (EU) 2024/3110, continue to apply in parallel. That regulation establishes its own digital product passport system for construction products on a separate legal basis. * **It does not regulate companies.** The obligations attach to products placed on the market, which is why the responsible party changes depending on who performs that act. * **It does not apply outside the EU market.** It applies to products placed on the EU market, whoever makes them. A manufacturer outside the EU is affected through its products, not through its establishment. * **It does not set a single compliance date.** There is no universal ESPR deadline, because the dates live in the delegated acts. #### Buying a passport platform before knowing the requirement Procurement decisions taken before the applicable delegated act exists are made against assumed data elements. When the act lands, the assumptions rarely match. Establishing internal data quality and supplier data flows is useful regardless of the act; committing to a fixed content model is not. ## Delegated Acts Explained A delegated act is a legal act adopted by the European Commission under a power that the legislator has delegated to it in a basic act. Under ESPR, delegated acts are how the framework becomes enforceable for real products. A non legislative act of general application adopted by the European Commission under Article 290 of the Treaty on the Functioning of the European Union, which supplements or amends non essential elements of a basic legislative act. Under ESPR, delegated acts define product groups and set the ecodesign and information requirements, including Digital Product Passport requirements, that apply to them. ### What a delegated act typically settles * The scope: precisely which products are covered, usually by technical definition rather than marketing category. * The performance requirements, if any, and how conformity with them is measured. * The information requirements, including whether a Digital Product Passport is required and what it must contain. * The access rights: which data elements are available to the public, and which only to specified groups such as repairers, recyclers, [notified bodies](/docs/knowledge-base/glossary/notified-body) or national authorities. * The [conformity assessment](/docs/knowledge-base/glossary/conformity-assessment) route. * The application date and any transition arrangements. ### How one comes into being The Commission runs a preparatory study and impact assessment for the product group, consults stakeholders through the Ecodesign Forum and public consultation, prepares a draft, and then adopts it. Parliament and Council have a scrutiny period during which either may object. Once adopted and published, an application date follows, typically after a transition period intended to give industry time to comply. > **The transition period is the real planning window** > > Between adoption and application there is a defined window. Organisations that have already sorted > out product data ownership, supplier data collection and identifier assignment use that window to > apply a known specification. Organisations that have not use it to start from scratch. For the sequence in which the Commission intends to work through product groups, see the ESPR working plan referenced below. Individual delegated acts will be covered in their own articles in this section as they are adopted; nothing on this page should be read as describing requirements that have not yet been adopted. ## How ESPR Affects Manufacturers Manufacturers carry the primary obligation, because they design the product and hold most of the information about it. * **Design decisions become regulated decisions.** Where a delegated act sets performance requirements, choices about materials, fasteners, spare parts and disassembly move from discretionary to constrained. * **Product data becomes a deliverable.** Information that previously lived in specifications, drawings and supplier emails must become structured, current and defensible. * **Supplier data becomes a dependency.** Composition and origin information usually sits several tiers up the supply chain. Contracts and onboarding processes are the mechanism for getting it, and they take longer to change than systems do. * **Conformity work extends.** Declarations, [technical documentation](/docs/knowledge-base/glossary/technical-documentation) and, where the act requires it, passport publication become part of placing the product on the market. * **The obligation is per product placed on the market**, not per company, so it recurs with every new model and variant. #### Where the real cost usually sits In most manufacturing programmes the expensive part is not publishing a passport. It is establishing, for the first time, an authoritative internal answer to questions such as which supplier supplied which component for which production run. Firms that already run disciplined [product traceability](/docs/knowledge-base/glossary/product-traceability) find the regulatory step comparatively small. ## How ESPR Affects Importers An importer that places a product from outside the EU on the EU market takes on obligations in its own right. In practice this is the group most often caught out, because the work is not manufacturing work but verification work. * The importer must satisfy itself that the product complies and that required documentation and information exist before placing it on the market. * Where the non EU manufacturer cannot or will not supply the underlying data, the importer cannot simply pass the problem on. The obligation attaches to the act of placing on the market. * Own brand and white label arrangements deserve particular attention: a business that has a product made to its specification and sells it under its own name is generally treated as the manufacturer for these purposes, not as a distributor. * Contractual data clauses with overseas suppliers are the practical control, and they need to be in place well before the applicable date. The allocation of responsibility across [economic operators](/docs/knowledge-base/glossary/economic-operator) is examined in detail in [Who Needs a Digital Product Passport?](/docs/knowledge-base/digital-product-passports/who-needs-a-digital-product-passport). ## How ESPR Affects Retailers Retailers and distributors generally do not create product information, but they are the point at which consumers encounter it, and they carry duties of care. * A distributor must act with due care and should not make available a product it knows or ought to know is non compliant. * Where a delegated act requires information to be available to consumers, retail channels are where that expectation is tested, both online and in store. * Online marketplaces have specific obligations regarding the information displayed in listings and cooperation with authorities. * Retailers that sell under their own brand are, for these purposes, usually manufacturers, and the full set of manufacturer obligations follows. * The unsold goods destruction provisions apply to economic operators holding unsold consumer products, which frequently means the retailer rather than the maker. #### Make passport availability a purchasing condition The cheapest point at which a retailer can secure compliant product information is the supplier onboarding contract. Retrofitting data requirements onto an existing supplier base after a delegated act applies is considerably harder than writing them into new agreements now. ## How ESPR Affects Technology Teams For technology teams, ESPR is a data problem before it is a compliance problem, and a governance problem before it is a platform problem. * **Identifier discipline.** A persistent, unique [product identifier](/docs/knowledge-base/glossary/product-identifier) at the right level of granularity, whether model, batch or item, is the foundation. Choosing the wrong level is expensive to reverse. * **Systems of record.** Information will come from several existing systems. The task is deciding which system is authoritative for each data element, not building a new store to duplicate them all. * **Supplier data ingestion.** Collecting, validating and versioning data from external parties is usually the largest engineering component. * **Access control.** Differentiated access by user group means authorisation logic, and authorisation logic means an authoritative view of who is asking and why. * **Longevity.** Passport information may need to remain available long after the product was sold and, in some cases, after the product line is discontinued. Retention, archival and endpoint stability are design constraints, not operational afterthoughts. * **Standards over bespoke formats.** Interoperability requirements point towards established identification and data exchange standards such as those maintained by [GS1](/docs/knowledge-base/glossary/gs1), including [GS1 Digital Link](/docs/knowledge-base/glossary/gs1-digital-link), rather than proprietary schemes. The technical shape of this is set out in [How Does a Digital Product Passport Work?](/docs/knowledge-base/digital-product-passports/how-does-a-digital-product-passport-work). #### Starting with the QR code A [QR code](/docs/knowledge-base/glossary/qr-code) is trivially easy to produce and answers none of the hard questions. Teams that begin with the carrier tend to discover, months later, that they have no agreed identifier granularity, no authoritative data source and no supplier data pipeline. The carrier is the last step, not the first. ## How Organisations Should Prepare Today The honest answer for most organisations is that no ESPR obligation currently applies to their products, and that this is precisely why preparation is worthwhile: the work that takes longest is the work that can be done before the requirement is known. Work that improves the organisation regardless of what any delegated act eventually says, and that cannot be compressed once the specification arrives. 1. **Map your portfolio against the working plan.** Establish which of your product groups are named, which are plausibly next, and which are far from regulation. This single exercise usually reframes the whole programme. 2. **Assign ownership of product data.** Name a person accountable for the accuracy of each major data domain. Absence of ownership, not absence of software, is the usual root cause of poor product data. 3. **Audit what you already know.** Most organisations hold far more of the likely data elements than they expect, scattered across specification documents, quality records and supplier files. Find it before you buy anything. 4. **Fix identifiers.** Decide granularity and make identifiers persistent and unique. Everything downstream depends on this and it is the hardest thing to change later. 5. **Start the supplier conversation.** Data clauses in contracts and onboarding questionnaires have long lead times because they renew on commercial cycles, not project cycles. 6. **Keep the content model flexible.** Design to accept new data elements without re-platforming, because the delegated act will not match your assumptions exactly. 7. **Watch the primary sources.** Track the Official Journal, the Commission's ESPR pages and the European standardisation work rather than secondary commentary. #### Sequence preparation by lead time, not by visibility Order the work by how long it takes to change, not by how visible it is. Supplier contracts and identifier schemes have the longest lead times and the lowest visibility. Public facing passport pages have the shortest lead time and the highest visibility, which is why they are so often built first and so rarely the right place to start. Preparation work of this kind belongs to delivery rather than to legal analysis. The staged view is in [How to Build a Digital Product Passport Implementation Roadmap](/docs/knowledge-base/implementation/how-to-build-a-digital-product-passport-implementation-roadmap), the systems view in [Building an Enterprise Digital Product Passport Architecture](/docs/knowledge-base/enterprise-systems-and-data-architecture/building-an-enterprise-digital-product-passport-architecture), and the standing operational view in [How to Operate a Digital Product Passport Programme](/docs/knowledge-base/implementation/how-to-operate-a-digital-product-passport-programme). ## Common Misconceptions **"ESPR and the Digital Product Passport are the same thing."** They are not. ESPR is a framework regulation covering product design and information across the single market. The passport is one instrument within it. **"ESPR applies to our products from a fixed date."** There is no single ESPR compliance date for products. Product level obligations begin on the dates set in the applicable delegated act. **"ESPR is in force, so we are already non compliant."** The regulation is in force, but the obligations that attach to a specific product depend on an adopted delegated act covering that product group and its transition period having expired. **"We are outside the EU, so this does not concern us."** ESPR follows the product, not the company. Goods placed on the EU market are covered irrespective of where they were made. **"We just need to put a QR code on the label."** The carrier is the visible endpoint of an information supply chain. Without accurate, sourced and maintained data behind it, it publishes an inaccuracy at scale. **"There will be one EU database we upload to."** ESPR provides for a registry of identifiers and limited data, not a central repository of full passport content. The [data stays distributed](/docs/knowledge-base/digital-product-passports/how-does-a-digital-product-passport-work). **"Compliance is a project with an end date."** Requirements are reviewed and tightened over time, and passport information changes across the [product lifecycle](/docs/knowledge-base/glossary/product-lifecycle). It is an operating state. ## Frequently Asked Questions #### Is ESPR law today? Yes. Regulation (EU) 2024/1781 entered into force on 18 July 2024 and applies directly in all EU Member States. What is not yet law for most products is any product specific ecodesign or Digital Product Passport requirement, because those arrive through delegated acts. #### Does ESPR replace the Ecodesign Directive? Yes. ESPR repeals Directive 2009/125/EC. Implementing measures adopted under the old directive remain in force until they are replaced or repealed, so some products continue to be governed by existing measures in the meantime. #### Which products does ESPR cover? In principle, physical goods placed on the EU market, including components and intermediate products, with a defined set of exclusions such as food, feed, medicinal products, living plants and animals, products of human origin, and certain vehicles covered by their own legislation. Being within scope of the framework is not the same as being subject to requirements. #### When will a delegated act cover my product group? That depends on the group. The ESPR working plan adopted in April 2025 sets out the Commission's priorities and indicative sequence, including textiles and apparel, furniture, tyres, mattresses, iron and steel and aluminium. Dates for groups not named in an adopted act are not established and should not be assumed. #### Does every product covered by ESPR need a Digital Product Passport? No. A passport is required only where the applicable delegated act requires one. A delegated act may set performance requirements without requiring a passport. #### How does ESPR relate to the Batteries Regulation? The Batteries Regulation, Regulation (EU) 2023/1542, is separate legislation with its own battery passport obligations and its own timetable. It is often described as the first live example of a passport style obligation in EU law, but it does not derive from ESPR. #### What happens if we do not comply? Enforcement is carried out by national [market surveillance](/docs/knowledge-base/glossary/market-surveillance) authorities. Member States set penalties, which must be effective, proportionate and dissuasive, and authorities have powers including restricting or withdrawing non compliant products from the market. #### Do we need to do anything before a delegated act applies to us? Nothing is legally required. Commercially, the preparation with the longest lead time, namely identifier decisions, data ownership and supplier data clauses, is worth starting early because it cannot be compressed once the specification is published. ## Key Takeaways #### Key Takeaways * ESPR is Regulation (EU) 2024/1781, a directly applicable framework regulation in force since 18 July 2024, replacing the 2009 Ecodesign Directive. - It exists because product design determines most environmental impact, because product information does not survive the supply chain, and because national rules were fragmenting the single market. - It works through delegated acts. The framework grants powers; the acts create obligations for named product groups on their own timetables. - The Digital Product Passport is one instrument inside ESPR. ESPR says passports exist and how they are reached; delegated acts say which products need one and what it contains. - The ESPR Implementation Journey runs from the European Green Deal through the Circular Economy Action Plan, ESPR, delegated acts, product categories, passports and organisation implementation to market surveillance and continuous improvement. - Different product families in the same portfolio will sit at different stages, so plan per product group rather than to a single corporate date. - Preparation that pays off regardless of the eventual specification is identifier discipline, data ownership, an audit of existing data, and supplier data clauses. - Verify every claimed requirement against a named act in the Official Journal before acting on it. ## Related Articles * [What Are Delegated Acts?](/docs/knowledge-base/regulations/what-are-delegated-acts) * [When Will Digital Product Passports Become Mandatory?](/docs/knowledge-base/regulations/when-will-digital-product-passports-become-mandatory) * [Digital Product Passport](/docs/knowledge-base/glossary/digital-product-passport) * [How Does a Digital Product Passport Work?](/docs/knowledge-base/digital-product-passports/how-does-a-digital-product-passport-work) * [What Information Does a Digital Product Passport Contain?](/docs/knowledge-base/digital-product-passports/what-information-does-a-digital-product-passport-contain) * [What is a Digital Product Passport?](/docs/knowledge-base/digital-product-passports/what-is-a-digital-product-passport) * [Who Needs a Digital Product Passport?](/docs/knowledge-base/digital-product-passports/who-needs-a-digital-product-passport) * [Which Products Will Require a Digital Product Passport?](/docs/knowledge-base/regulations/which-products-will-require-a-digital-product-passport) ## Related Glossary Terms Definitions of record for the terms used above live in the [glossary](/docs/knowledge-base/glossary/overview). * [ESPR](/docs/knowledge-base/glossary/espr) * [Delegated Act](/docs/knowledge-base/glossary/delegated-act) * [Digital Product Passport](/docs/knowledge-base/glossary/digital-product-passport) * [Economic Operator](/docs/knowledge-base/glossary/economic-operator) * [Conformity Assessment](/docs/knowledge-base/glossary/conformity-assessment) * [Market Surveillance](/docs/knowledge-base/glossary/market-surveillance) * [Circular Economy](/docs/knowledge-base/glossary/circular-economy) * [Product Data](/docs/knowledge-base/glossary/product-data) * [Product Identifier](/docs/knowledge-base/glossary/product-identifier) * [Product Lifecycle](/docs/knowledge-base/glossary/product-lifecycle) * [Product Traceability](/docs/knowledge-base/glossary/product-traceability) * [Sustainability Data](/docs/knowledge-base/glossary/sustainability-data) * [Data Carrier](/docs/knowledge-base/glossary/data-carrier) * [QR Code](/docs/knowledge-base/glossary/qr-code) * [GS1](/docs/knowledge-base/glossary/gs1) * [GS1 Digital Link](/docs/knowledge-base/glossary/gs1-digital-link) ## References * Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products, Official Journal of the European Union: [https://eur-lex.europa.eu/eli/reg/2024/1781/oj](https://eur-lex.europa.eu/eli/reg/2024/1781/oj) * Directive 2009/125/EC establishing a framework for the setting of ecodesign requirements for energy related products, Official Journal of the European Union: [https://eur-lex.europa.eu/eli/dir/2009/125/oj](https://eur-lex.europa.eu/eli/dir/2009/125/oj) * European Commission, The European Green Deal, COM(2019) 640 final: [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019DC0640](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019DC0640) * European Commission, A new Circular Economy Action Plan, COM(2020) 98 final: [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020DC0098](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020DC0098) * European Commission, ESPR working plan 2025 to 2030, COM(2025) 187: [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025DC0187](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025DC0187) * European Commission, Ecodesign for Sustainable Products Regulation policy pages: [https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation\_en](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en) * Regulation (EU) 2023/1542 concerning batteries and waste batteries, Official Journal of the European Union: [https://eur-lex.europa.eu/eli/reg/2023/1542/oj](https://eur-lex.europa.eu/eli/reg/2023/1542/oj) * Regulation (EU) 2019/1020 on market surveillance and compliance of products, Official Journal of the European Union: [https://eur-lex.europa.eu/eli/reg/2019/1020/oj](https://eur-lex.europa.eu/eli/reg/2019/1020/oj) * Regulation (EU) 2024/3110 laying down harmonised rules for the marketing of construction products, Official Journal of the European Union: [https://eur-lex.europa.eu/eli/reg/2024/3110/oj](https://eur-lex.europa.eu/eli/reg/2024/3110/oj) * Treaty on the Functioning of the European Union, Article 290, delegated acts: [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A12012E%2FTXT](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A12012E%2FTXT) * CEN-CENELEC Joint Technical Committee 24 (JTC 24), Digital Product Passport standardisation work programme: [https://www.cencenelec.eu/areas-of-work/cen-cenelec-topics/digital-product-passport/](https://www.cencenelec.eu/areas-of-work/cen-cenelec-topics/digital-product-passport/) ## About This Article About This Article
Last Reviewed
2026-08-07
Next Scheduled Review
2027-08-07
Article Version
1.0
tieback Knowledge is a continuously maintained reference library covering Digital Product Passports, product traceability, product compliance and related regulations. Articles are reviewed regularly as legislation, standards and implementation guidance evolve. ## Page Metadata | Field | Value | | ------------- | ------------------------------------------------------------------------------ | | Published | 2026-08-07 | | Last Reviewed | 2026-08-07 | | Reading Time | 22 min | | Difficulty | beginner | | Author | tieback | | Category | Regulations | | Tags | ESPR, Regulation (EU) 2024/1781, Delegated Acts, Ecodesign, DPP, EU Green Deal | ## Related Docs * [Regulations](/docs/knowledge-base/regulations/overview) * [What Is a Digital Product Passport?](/docs/knowledge-base/digital-product-passports/what-is-a-digital-product-passport) * [Who Needs a Digital Product Passport?](/docs/knowledge-base/digital-product-passports/who-needs-a-digital-product-passport) * [How Does a Digital Product Passport Work?](/docs/knowledge-base/digital-product-passports/how-does-a-digital-product-passport-work)