ESPR: the law, the timeline, and what it actually requires of you

The Ecodesign for Sustainable Products Regulation entered into force in July 2024, and it applies to almost every physical product sold in the EU. It does not yet impose ESPR requirements on most of them, because the regulation is a framework: each product category is switched on separately by a delegated act, and the first of those arrive from 2026.

So the honest answer to “when does ESPR affect me” is: it depends entirely on what you sell, and the gap between categories is years.

Check the dates. Every date below comes from our research in March 2026. The ESPR working plan moves. Verify against the official timetable before you plan around any of it.

What ESPR replaced, and why it is broader

ESPR replaces the old Ecodesign Directive, which covered energy-related products: fridges, motors, lighting, that sort of thing. Its scope was narrow and its concern was energy in use.

ESPR extends to nearly all physical goods placed on the EU market, with a handful of carve-outs including food, feed and medicinal products, and it moves the concern from energy in use to the whole life of the product: how long it lasts, whether it can be repaired, what it is made of, and what happens to it at the end.

Being a regulation rather than a directive matters too. It applies directly across member states rather than being transposed into 27 national laws, so there is one text to read.

Who it applies to

Anyone who places a product on the EU market. That is the operative phrase, and it catches more people than expected:

• Manufacturers outside the EU, including UK manufacturers, if their product ends up on sale in the EU. Where it was made is irrelevant.
• Importers and authorised representatives, who carry the obligation when the manufacturer is outside the EU.
• Distributors, who must not supply product that fails to carry what it should.
• Online marketplaces, which have their own duties around listings and cooperation with authorities.

The most common mistake we hear in the UK is “we are not an EU business, so it does not apply”. If your goods are sold into the EU, by you or by a distributor you supply, they are in scope on the date your category switches on.

The timeline

Two things to read out of that table.

First, batteries are ahead of the rest and arrive under their own regulation rather than under ESPR itself, which is why that date is firmer than the others.

Second, textiles and electronics in 2027 covers an enormous share of consumer goods, and the preparatory work for those categories is happening now, not in 2027.

These dates need checking against the current official timetable before you rely on them. Delegated acts slip, and a category’s date is only fixed once its act is adopted.

What the requirements actually are

ESPR gives the Commission the power to set two kinds of requirement per category.

Performance requirements. Minimum standards the product itself has to meet. Depending on category these can cover durability and reliability, reparability, upgradability, recycled content, resource and energy efficiency, expected lifetime, and restrictions on substances of concern that inhibit recycling.

Information requirements. What has to be declared, and how. This is where the Digital Product Passport sits: a structured data set about the specific product, carried in a standard format, reachable from the product itself.

Alongside those, ESPR introduces measures that are not product performance at all:

• A ban on destroying unsold consumer goods, starting with textiles and footwear, with a transparency obligation on larger companies to disclose what they discard and why. The start dates and the company-size thresholds here are among the most frequently misquoted parts of the regulation, so check them for your own situation.
• Green public procurement criteria, which can require public buyers to favour compliant, better-performing products. For anyone selling into the public sector this arrives as commercial pressure well before it arrives as a fine.

What a delegated act means in practice

A category does not go from nothing to obligation overnight.

The Commission runs a preparatory study, consults, then adopts a delegated act setting that category’s requirements. There is normally a transition period after adoption before the requirements apply, commonly around 18 months.

That sounds generous. It is not, if the requirement is a data one. Publishing a passport is a few weeks of work. Getting verified material composition out of a tier two supplier, for every product in a range, is not, and that is the work that has to start before your date is announced rather than after.

Three things people get wrong

“We have until 2030.” Maybe, for your category. But the data collection is the long pole, and it does not start when the act is adopted. It starts when you first ask a supplier a question they have never been asked before.

“It is a compliance job.” ESPR requirements are answered mostly by procurement, product engineering and IT rather than by a sustainability team. The information exists across the supply chain and across internal systems that were never designed to talk to each other. Whoever owns it needs the authority to ask other departments for things.

“We will pick a technology later.” Fair, and mostly true. The carrier, whether a QR code, an NFC tag or an RFID tag, is a late decision and a reversible one. The identifier scheme underneath it is neither. Deciding what an item’s unique identity is, and at what granularity you assign it, shapes everything after.

Product, batch or item

That granularity question is worth a paragraph on its own, because it is the one decision that is expensive to change later.

ESPR lets identifiers sit at model, batch or item level depending on the category and what the information requires. Model level is cheapest. Item level is the only one that supports a service history, a repair record, a resale provenance trail or a refill count.

If compliance is all you want, choose the cheapest level your category permits. If you expect to run repair, resale, refill or warranty on the same data within five years, the cheapest level will be rebuilt. Most brands we talk to end up wanting item level for a commercial reason rather than a regulatory one.

Where to start

One question, the same one as in our passport piece, because it is still the one that separates a publishing job from a project:

For a single one of your products, can you today state what it is made of, by percentage weight, with evidence?

If yes, you are in good shape and the rest is a data-publishing exercise. If no, that is the project, and it belongs to procurement before it belongs to anyone else.