What is the ESPR?
Which products does the ESPR apply to?
The ESPR can apply to any physical product, including components and intermediate products, whether manufactured in the EU or imported.
Food, feed, medicinal products for human and veterinary use, living plants, animals and microorganisms, products of human origin, and certain plant and animal products directly related to their reproduction are excluded from its scope. Vehicles are also subject to specific provisions where certain aspects are already regulated by sector-specific EU legislation.
What types of requirements can the ESPR establish?
Will all products have to comply with the same requirements?
No. The ESPR is a general framework, and specific requirements will be defined by product category or, where appropriate, horizontally for several product groups.
Therefore, the fact that a product falls within the scope of the ESPR does not mean that specific obligations already apply to it. It will be necessary to check whether an applicable delegated act has been adopted and what its implementation timeline is.
Which products are prioritised for 2025–2030?
The first Working Plan prioritises four final products: textiles/apparel, furniture, tyres and mattresses; and two intermediate products: iron and steel, and aluminium.
It also provides for horizontal requirements on repairability (including a possible scoring system) and on recycled content and recyclability of electrical and electronic equipment. The plan also continues work previously initiated on various energy-related products.
When are these products expected to be regulated?
The indicative timetable for the adoption of the measures places iron and steel in 2026; textiles, tyres, aluminium and repairability in 2027; furniture in 2028; and mattresses and horizontal requirements on recycled content and recyclability of electrical and electronic equipment in 2029.
Importantly, the expected date of adoption is not the same as the effective date of application. The relevant acts will establish their respective transition periods.
What about footwear?
Although it was initially considered among the categories that could be prioritised, footwear was not included as a priority product in the first 2025–2030 Working Plan.
The Commission plans to carry out a specific study on its potential regulation under the ESPR, which is expected to be completed by the end of 2027.
What is the Digital Product Passport?
Is the DPP already operational?
Yes, although it is important to distinguish between the DPP infrastructure and its application to different products. The European DPP Registry has been operational since 20 July 2026 and allows economic operators to register and verify their identity.
Currently, the passports that can be registered are those for batteries, the first product category with a regulated DPP. Their registration takes place through this common infrastructure and will become mandatory from 18 February 2027 for those covered by the Batteries Regulation.
For other products, the requirement to have a DPP will be introduced progressively as the corresponding specific requirements are adopted.
What information is stored in the European DPP Registry?
The Registry functions as a central European index: it stores unique identifiers, registration data and certain metadata, but not necessarily all product information.
The DPP operates in a decentralised manner: detailed information is not stored in a single location but is managed by the company responsible for the product, either directly or through a specialised DPP service provider.
What will be the first mandatory DPP?
The first expected milestone is 18 February 2027 for certain batteries, in accordance with the EU Batteries Regulation.
Other product categories will subsequently be incorporated through the ESPR and other EU legislation, including iron and steel, textiles, aluminium, tyres, construction products and certain ICT equipment.
Does the ESPR create a new European environmental label?
No. It does not create a single mandatory environmental label for all products.
For energy-related products, energy labelling and EPREL will continue to play a central role. For other products, information will mainly be provided through the DPP, although certain acts may also establish ESPR labels or other specific information systems.
What happens to unsold products?
Since 19 July 2026, large companies have been prohibited from destroying certain unsold apparel, clothing accessories and footwear, except in justified circumstances such as certain safety issues or product damage.
The prohibition will be extended to medium-sized companies in 2030, while small and micro-enterprises are exempt. A harmonised format has also been established for reporting information on unsold consumer products that are discarded.
Can the ESPR also affect public procurement?
Yes. The ESPR allows for the establishment of mandatory minimum green public procurement requirements for regulated products where they are relevant to public buyers and economically feasible.
These requirements will not apply automatically to all product categories: they will need to be adopted through specific implementing acts. The Commission plans to assess them in parallel with the ecodesign requirements for priority products.
Does the ESPR also apply to products manufactured outside the EU?
Yes. The applicable requirements concern products placed on the EU market, regardless of where they were manufactured.
Therefore, imported products will have to comply with the same applicable requirements as products manufactured within the European Union.
How can the ESPR affect a manufacturing company?
It can directly affect product design, the materials and components used, information requested from suppliers, repairability, calculation of environmental indicators, end-of-life management and product traceability.
In addition, the required information will need to be sufficiently structured to feed systems such as the DPP. The impact is therefore not limited to sustainability teams: it also affects engineering, procurement, operations and information systems.
What can a company do to prepare?
First, it should identify whether its products are among the priority categories or are subject to upcoming regulatory developments.
It should then review what information is currently available on composition and materials, recycled content, suppliers, durability and repairability, environmental impacts, substances, end-of-life management, and product identification and traceability. The aim is to identify which data may be difficult to obtain once the requirements become mandatory.
The implementation of the ESPR will introduce new ecodesign, information and traceability requirements for different product categories, including, where applicable, the calculation and communication of environmental performance indicators.
At Baisma, we help organisations assess how the ESPR may affect their products, anticipate applicable requirements and develop and calculate the necessary environmental indicators, covering aspects such as carbon footprint, environmental footprint, resource use and circularity, as well as structuring the information required for the Digital Product Passport.
If your organisation wants to anticipate ESPR requirements, develop environmental indicators for its products or prepare the information needed for upcoming regulatory developments, we would be happy to help.
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