ESPR, the Ecodesign for Sustainable Products Regulation: scope, delegated acts and what product teams must prepare

ESPR is a framework that becomes binding product by product

ESPR sets the rules for making rules. The regulation itself defines which requirements the Commission may impose, while the actual obligations arrive through delegated acts for specific product groups. Until a delegated act covers a product group, most ESPR duties stay dormant for that group, with two exceptions: the destruction ban and the disclosure of discarded unsold goods.

Scope is broad. ESPR covers almost every physical good placed on the EU market, including components and intermediate products such as steel and aluminium. Food, feed, medicinal products, veterinary products, living organisms and vehicles fall outside scope. It also replaces the Ecodesign Directive, although existing energy-related implementing measures remain valid until reviewed.

Delegated acts follow a published working plan

The Commission adopted the first ESPR working plan in April 2025, covering the period to 2030. It names the product groups that receive delegated acts first:

• Intermediate products: iron and steel, aluminium.
• End-use products: textiles and apparel, furniture, tyres, mattresses.
• Assessed but not prioritised: chemicals, detergents, paints, lubricants and footwear, which may return in a later plan.
• Energy-related products: carried over from the Ecodesign Directive programme.
• Horizontal measures: reparability requirements and recycled content or recyclability rules for electrical and electronic equipment.

Each delegated act passes through a preparatory study, stakeholder consultation via the Ecodesign Forum, impact assessment and scrutiny. The process typically takes two to three years per product group, and application normally follows after a transition period of at least 18 months. Product teams therefore receive warning, though the exact attribute list stays open until late in the process. Iron and steel is first in line, with adoption indicated for late 2026; as of October 2026 no product-specific delegated act had been adopted.

A typical delegated act specifies the products in scope, the performance thresholds, the information to disclose, the DPP granularity (model, batch or item), the data carrier, the access rights per actor and the conformity assessment route. Reading the preparatory study early gives product data teams a reliable preview of the attributes that will become mandatory.

Performance and information requirements define the work

ESPR distinguishes two kinds of obligation, and each lands on different teams.

Performance requirements change the product itself. Information requirements change how product facts are captured, verified and published. The information side is where most organisations underestimate effort, because it requires traceable data from suppliers at the granularity the act prescribes. The resulting Digital Product Passport becomes the delivery channel for these facts.

Substances of concern deserve particular attention. ESPR requires tracking them through the product lifecycle, which extends existing REACH and SCIP work described in the substance compliance guide.

The destruction ban applies directly from 19 July 2026

The destruction ban is the first ESPR obligation that needs no delegated act. From 19 July 2026, large enterprises may not destroy unsold apparel, clothing accessories and footwear. Medium-sized enterprises follow from 19 July 2030, while micro and small enterprises are exempt. Delegated Regulation (EU) 2026/296 sets the derogations, covering cases such as safety risks, damage that cannot be repaired, intellectual property infringement and products refused for donation.

Large companies must also publicly disclose the number and weight of unsold consumer products they discard, the reasons and the share sent to reuse, remanufacturing, recycling or disposal. This disclosure duty already applies to large enterprises, with annual reporting on their website, and the standard disclosure format in Implementing Regulation (EU) 2026/2 applies from 2 March 2027. Meeting it requires stock movement data linked to product master data, which most ERP and warehouse systems hold in fragmented form.

Prepare the information layer first

The central insight is that ESPR rewards early investment in information requirements, since performance requirements stay product-specific while the data mechanics repeat across every act. A company that builds governed material, supplier and footprint data once can respond to steel, textile and furniture acts with the same processes.

Practical first steps include:

1. Map which of the company's product groups appear in the working plan.
2. Assign an owner to monitor preparatory studies and consultations per group.
3. Inventory existing attributes against the ESPR information menu.
4. Close supplier data gaps on materials, origin and substances.

Sector detail is available for textiles, and a sequenced plan sits in the DPP readiness roadmap.