PLMV-KB-014 · Regulation & Compliance · Reviewed 2026-10-16
ESPR: The Ecodesign for Sustainable Products Regulation
The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, is the EU framework for setting sustainability requirements on almost all physical products. It entered into force on 18 July 2024. Product-specific delegated acts set performance and information requirements, including Digital Product Passports, while the regulation itself bans destroying unsold apparel and footwear.
Key takeaways
- ESPR is a framework: obligations for each product group only apply once a delegated act for that group is adopted and in application.
- The 2025-2030 working plan prioritises iron and steel, aluminium, textiles, tyres, furniture and mattresses, plus horizontal rules on repairability and electronics recyclability.
- The ban on destroying unsold apparel, accessories and footwear has applied to large companies since 19 July 2026.
- Ecodesign requirements translate into measurable PLM attributes such as recycled content, durability, repairability, substances of concern and carbon footprint.
How ESPR works as a framework
ESPR replaced the Ecodesign Directive 2009/125/EC, which covered energy-related products only. The new regulation extends ecodesign to almost every physical good placed on the EU market, with exemptions for food, feed, medicinal products, living organisms and vehicles covered by type approval. It sets the legal toolbox; the requirements themselves arrive through delegated acts per product group or as horizontal rules across several groups.
Delegated acts can set two types of requirement:
- Performance requirements: minimum or maximum levels, such as recycled content, durability, energy use or carbon footprint thresholds.
- Information requirements: data that must be made available, usually through a Digital Product Passport, labels or instructions. Information on substances of concern is a standard element.
ESPR typically allows at least 18 months between adoption of a delegated act and its application, unless a shorter period is justified. Each delegated act is prepared with input from the Ecodesign Forum, which brings together industry, civil society and Member State experts, and is preceded by preparatory studies, often led by the Joint Research Centre. Companies can follow and comment on drafts through the Commission feedback portal, which gives product data teams early sight of the attributes that will be required.
Which product groups are in the ESPR working plan?
The Commission adopted the first ESPR working plan on 16 April 2025. Adoption years below are indicative.
| Category | Product group | Indicative adoption |
|---|---|---|
| Intermediate products | Iron and steel | 2026 |
| Intermediate products | Aluminium | 2027 |
| Final products | Textiles and apparel | 2027 |
| Final products | Tyres | 2027 |
| Final products | Furniture | 2028 |
| Final products | Mattresses | 2029 |
| Horizontal | Repairability (scope to be confirmed) | 2027 |
| Horizontal | Recycled content and recyclability of electrical and electronic equipment | 2029 |
The plan also carries over energy-related products from the previous ecodesign work programme, including dishwashers, refrigeration appliances, electric motors, EV chargers and smartphones and tablets. Footwear, detergents, paints, lubricants and chemicals were left out of the priority list, though the Commission can add groups in later plans.
Status of the first delegated acts
For iron and steel, the Commission published a call for evidence on 19 May 2026, which closed on 12 August 2026. Measures under consideration include mandatory carbon footprint and recycled content information, performance classes based on carbon footprint, and passport requirements. Adoption is expected in Q4 2026. Textiles, tyres and aluminium remain indicated for 2027. At the time of writing (October 2026), no product-specific ESPR delegated act was in application. Readers should check the Commission ESPR pages for later adoptions.
The unsold goods destruction ban
ESPR directly prohibits the destruction of unsold apparel, clothing accessories and footwear. The ban has applied to large enterprises since 19 July 2026 and will apply to medium-sized enterprises from 19 July 2030. A delegated regulation published in April 2026 sets the derogations, such as products that are unsafe, counterfeit or damaged beyond repair, and failed donation attempts. Large enterprises must also disclose the volumes of unsold consumer products they discard; an implementing regulation published in February 2026 sets the reporting format, using product categories based on Combined Nomenclature codes, and applies from 2 March 2027. This creates new data needs for fashion and retail PLM and merchandising systems.
What ESPR means for PLM data
Ecodesign requirements are expressed as measurable product attributes, so they belong in the product record from the concept stage. Typical attributes include:
- material composition and recycled content per component
- durability and reliability metrics, spare part availability and repair information
- substances of concern, with concentration and location
- product carbon footprint and other environmental footprint values
- disassembly information and recyclability characteristics
- unique identifiers and commodity codes for the passport
Because these values change with design decisions, they should be governed through engineering change management and linked to the bill of materials. Enterprise suites such as Dassault Systèmes 3DEXPERIENCE and Siemens Teamcenter and fashion-focused platforms such as Lectra PLM offer sustainability and material compliance modules; the depth of support for ESPR-specific attributes varies and should be tested in scripted vendor demos.
Frequently asked questions
When does ESPR apply to my products?
ESPR entered into force on 18 July 2024, but product requirements only apply once a delegated act for your product group is adopted and its application date is reached, usually at least 18 months after adoption. The destruction ban for unsold apparel and footwear is the exception: it is set in the regulation itself and has applied to large enterprises since 19 July 2026.
What is the difference between ESPR and the old Ecodesign Directive?
The Ecodesign Directive 2009/125/EC covered energy-related products and focused mainly on energy efficiency. ESPR covers almost all physical products and adds circularity requirements such as durability, repairability, recycled content and substances of concern, plus the Digital Product Passport. Existing implementing measures adopted under the directive, for example for appliances, remain valid until replaced.
Does ESPR apply to small companies?
Product requirements in delegated acts apply to all economic operators placing those products on the EU market, including small companies. The unsold goods destruction ban and disclosure obligation exempt micro and small enterprises, and medium-sized enterprises only fall under the ban from 19 July 2030. Delegated acts may also include specific support measures for SMEs.
Sources
- Regulation (EU) 2024/1781 Ecodesign for Sustainable Products (EUR-Lex)
- European Commission: Ecodesign for Sustainable Products Regulation
Reviewed 16 October 2026 by the PLM Vendors editorial team. Regulatory dates and vendor details change; check the sources for the latest position.