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Ecodesign for Sustainable Products Regulation (ESPR): context, consequences and how to comply

Ecodesign for Sustainable Products Regulation seeks to enhance the circularity, energy efficiency, and overall environmental sustainability of products introduced into the EU market. Read this article to find out more about this regulation, what consequences to expect and how to start.

What is the ESPR?

The new Ecodesign for Sustainable Products Regulation, shortened ESPR, replaces from the 18th of July onwards the current Ecodesign Directive 2009/125/EC. The ESPR seeks to enhance the circularity, energy efficiency, and overall environmental sustainability of products introduced into the EU market. 

In this context, a sustainable product typically exhibits one or more of these qualities:

  • Consumes less energy
  • Has a longer lifespan
  • Is readily repairable
  • Features components that are easy to disassemble and reuse
  • Contains minimal harmful substances
  • Is easily recyclable
  • Includes a higher percentage of recycled materials
  • Possesses a reduced carbon and environmental footprint throughout its lifecycle

More specifically, the ESPR establishes a framework for setting ecodesign requirements, focussing on performance and information conditions for almost all categories of physical goods (with some exceptions, such as food and feed).

The aims of these ecodesign requirements are the following:

  • Improve product durability, reusability, upgradability and reparability
  • Make products more energy and resource-efficient
  • Address the presence of substances that inhibit circularity
  • Increase recycled content
  • Make products easier to remanufacture and recycle
  • Set rules on carbon and environmental footprints
  • Improve the availability of information on product sustainability

The ESPR is aligned with the Energy Labeling Regulation (EU/2017/1369), a regulation aiming at enabling customers to make informed choices based on the energy consumption of energy-related products.

Which products have to meet these requirements?

The first categories that will have to face ESPR-requirements are iron & steel, aluminium, textiles (garments and footwear), furniture (including mattresses), tyres, detergents, paints, lubricants, chemicals, energy-related products (including new measures and revisions of existing ones) and ICT products, as well as other electronics.

Read more here about all products covered.

Consequences of the ESPR

Let’s dive into three of the key-elements of the ESPR in the paragraphs below.

Digital product passport

An important element of the ESPR is the Digital Product Passport (DPP); this is essentially a digital ID or label that needs to be added to products, components, and materials. This passport will contain vital data to enhance the sustainability and circularity of products and ensure compliance with regulations. Accessible by a data-carrier, for example an QR-code.

With this digital accessible data, consumers, manufacturers, and regulatory bodies are able to make better-informed decisions concerning sustainability, circularity, and legal compliance. And customs authorities can automatically verify the presence and authenticity of DPPs for imported goods.

What information exactly needs to be included, is to be further determined by the European Commission after thorough consultation with all relevant parties, tailored to the particular product. But you can expect information about:

  • Technical performance of the product
  • Origins and types of materials used
  • Repair history
  • Recycling potential
  • Environmental impacts over the product's lifecycle

Read our article about the digital product passport: https://www.hhc.earth/knowledge-base/digital-product-passports-sustainable-products 

Destruction of unsold items

Another key-element are ESPR-initiatives to stop the destruction of unsold items. In the EU, a significant number of unsold products are currently being destroyed, squandering precious resources. 

The regulation will mandate that large and eventually medium-sized enterprises, from all product sectors publicly, report specific details about what items they destruct annually on their websites. This information will include the quantity and weight of products they dispose of and the reasons behind these actions.

And the ESPR will implement a ban on, for example, the destruction of unsold textiles and footwear. And other sectors, where destruction is happening on a large scale as well, might follow. 

Green public procurement

EU public authorities spend approximately €1.8 trillion on acquiring works, goods, and services. The ESPR aims to guide these substantial expenditures towards more sustainable options by introducing mandatory Green Public Procurement criteria for EU authorities purchasing regulated products.

This initiative could greatly increase the demand for sustainable products, encouraging more companies to invest in environmentally friendly practices.

When will the ESPR be implemented?

The ESPR requires the Commission to adopt and publish the first ESPR working plan in the first half of 2025. The working plan will cover a minimum period of 3 years. As with all European regulations, member states will then translate it to nation legislations supporting it.

The ESPR functions as an overarching legislative framework, which means that specific rules for products will be established gradually, either for individual products or for groups of products sharing similar traits.

Each product group regulated under the Ecodesign Directive is governed by its own "implementing act," a legal document that enforces the ecodesign criteria. The EU is currently working on new implementing acts for additional product groups and updating existing ones. These acts are initially enforced under the existing Ecodesign Directive. 

However, once the ESPR is enacted, it will incorporate these acts and supersede the current directive. For instance, the latest implementing act for mobile phones and tablets, which was adopted in June 2023 and will be enforced from June 2025, mandates durable design, batteries that last longer, and extended availability of software updates and spare parts. 

As mentioned earlier in this article the first categories that will have to face ESPR-requirements are iron & steel, aluminium, textiles (garments and footwear), furniture (including mattresses), tyres, detergents, paints, lubricants, chemicals, energy-related products (including new measures and revisions of existing ones) and ICT products, as well as other electronics.

Find out more about the implementation of the ESPR here.

How can organisations meet the ESPR requirements? 

Where to start, meeting the ESPR requirements? A good idea is to gain knowledge, and share this with your team. To understand these new standards and the importance of accurate data reporting. And establish a robust framework for collecting, managing, and reporting sustainability data. Because a lot of sustainability data is needed. So conduct a thorough assessment of current sustainability practices and metrics in place, aligning them with the ESPR requirements. 

Implementing dedicated sustainability reporting software or platforms can streamline the process, ensuring that data is consistently collected and reported in a format that meets ESPR guidelines. Regular internal audits and reviews will help maintain compliance and improve sustainability practices over time. 

Additionally, engaging with stakeholders—including investors, customers, and suppliers—about these practices enhances transparency and supports the broader adoption of sustainable practices across the value chain.

Life Cycle Assessments (LCAs) can be very helpful for organisations aiming to meet ESPR requirements. Because LCA’s provide a comprehensive view of a product's sustainability, by systematically evaluating the environmental impacts of products throughout their entire life cycle—from raw material extraction through production, use, and disposal.

This thorough analysis helps organisations identify significant environmental hotspots and opportunities for improvement in product design and manufacturing processes. By integrating LCA findings into their product development and decision-making processes, companies can align their products with ESPR's focus on reducing environmental impact, enhancing durability, and improving recyclability. 

What is covered in an LCA

Context: the Green Deal

The ESPR is part of the bigger “package” of EU measures supporting the 2020 Circular Economy Action Plan. This Action Plan is one of the main building blocks of the European Green Deal.

In short; the European Union has very progressive and ambitious sustainability goals, with the aim to be the first continent that:

  • has no net emissions of greenhouse gasses by 2050
  • decoupled economic growth from resource use
  • leaves no person and no place behind in this ambitions

The circular economy will reduce pressure on natural resources and will create sustainable growth and jobs.

Read more about the ESPR on the official EU website.

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This article is written by:
Clara
Clara
Head of Communications
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