Introducing the ESPR: Ecodesign for Sustainable Products Regulation

Implementation Timelines and Delegated Acts

As determined under the ESPR’s Article 4, the commission is empowered to adopt a series of delegated acts which address product-specific challenges when it comes to their resource consumption, circularity, and waste production. These delegated acts also determine the information required within the Digital Product Passports mandated by the regulation. In fact, the delegated acts serve as the main body of requirements under the ESPR, with the text of the regulation itself offering mostly general parameters that can be applied across all products. Aside from specifying the ecodesign requirements for these categories of products, the delegated acts will also specify the specific data and design requirements of the Digital Product Passports, as established under Chapter III of the ESPR. 

So when are we getting the proper delegated acts? 

According to the Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 document, published on the 16th of April 2025, Delegated Acts will be published according to a set timeline, with the first delegated act, concerning discarded unsold consumer products, having been published earlier this year on the 9th of February.  

The full list of delegated acts expected in the coming years is as follows 

Digital Product Passports

Digital product passports are the primary enforcement tools of the ESPR. Governed under Chapter III of the regulation, they serve as a tool to promote transparency between businesses and consumers. Essentially, DPPs will carry all information about a product’s origin, correct usage, and environmental footprint. As such, DPPs aim to create transparency for consumers and help them make more informed decisions regarding the products they purchase. 

Manufacturers are therefore required to make Digital Product Passports available for all products subject to the ESPR. While the specific information requirements in DPPs are also deferred to delegated acts, all passports must comply with certain characteristics set out under Article 9 of the ESPR: namely, that each passport be linked via a data carrier (e.g. QR code) to a persistent unique product identifier (e.g. GTIN), and that this data carrier be physically present on the product, its packaging, or its accompanying documentation. Moreover, while specific datapoints within the DPPs are set to be released within the delegated acts, some broader data categories are already provided under Article 7:  

1. Information on the performance of the product in relation to one or more of the product parameters referred to in Annex I, including a repairability score, a durability score, a carbon footprint or an environmental footprint; 

2. Information for customers and other actors on how to install, use, maintain and repair the product, in order to minimise its impact on the environment and to ensure optimum durability, on how to install third-party operating systems where relevant, as well as on collection for refurbishment or remanufacture, and on how to return or handle the product at end-of-life; 

3. Information for treatment facilities on disassembly, reuse, refurbishment, recycling, or disposal at end-of-life;

4. Other information that could influence sustainable product choices for customers and the way the product is handled by parties other than the manufacturer to facilitate appropriate use, value-retaining operations and correct treatment at end-of-life;

Other Regulations

While the ESPR is the de facto cornerstone of the CEAP, other regulations are still applicable and relevant to different sectors, often citing interoperability with ESPR requirements such as the Digital Product Passport, below is a shortlist of the most relevant regulations 

Packaging and Packaging Waste Regulation (Aug 2026) 

From August 2026 onwards, companies involved in manufacturing, or importing packaging into the EU will need to ensure their products are compliant with the PPWR's requirements. Restrictions on single use plastics, heavy metals, and PFAS in packaging are complimented by a mandatory Digital Product Passport. Under the PPWR, every packaging unit in the EU needs to have a data carrier containing relevant information related to the make, and material footprint of the product in question. Where the product itself is by Union law required to carry a digital product passport, only one data carrier for the product and packaging simultaneously, is required. 

Construction Products Regulation (Jan 2026) 

This regulation deals mainly with construction products and their impacts. Similarly to the ESPR, materials under scope of this regulation, such as cement and concrete, are required to be accompanied by a Digital Product Passport. This DPP is to be interoperable with the DPP mentioned in the ESPR, as mentioned in Article 75 of the CPR. 

Batteries Regulation (Feb 2024) 

The EU Batteries Regulation is another CEAP regulation addressing product circularity within its scope. It focuses on a single product category, meaning specific requirements are set out directly in the regulatory text and can be accessed here. The regulation also introduces a battery passport, similar in concept to the digital product passports featured in other regulations on this list. Although the regulation entered into force in 2023, with general provisions applying from 2024, the battery passport does not become mandatory until August 2027. Under Article 78, the battery passport must be interoperable with other Digital Product Passports (DPPs) required under Union law.

How to Prepare

While the full scope of requirements under the ESPR will only become clear as delegated acts are published in the coming years, there are several steps companies can take now to get ahead of their compliance obligations. 

Engage suppliers and collect relevant product information 

Compliance with the ESPR, and in particular with the data requirements of the Digital Product Passport, will depend heavily on the availability of reliable product information across the supply chain. Companies should therefore begin engaging their suppliers early, mapping the flow of materials and components that make up their products, and identifying any gaps in available data. This is particularly important for manufacturers who bear primary responsibility for the accuracy of the information contained in their DPPs. 

Conduct a Life Cycle Assessment on target products 

A Life Cycle Assessment (LCA) is a systematic method for evaluating the environmental impact of a product across its entire lifecycle, from raw material extraction through to end-of-life disposal. Given that Article 5 of the ESPR explicitly targets performance dimensions such as durability, reusability, and recyclability, an LCA provides a natural framework for identifying where a product's environmental footprint is most significant and where improvements can be made. Companies are advised to prioritise LCAs on products most likely to fall within the scope of near-term delegated acts, such as those in the textiles, appliances, and furniture categories. 

Store information and await further guidance in the delegated acts 

As delegated acts are progressively published between 2026 and 2030, the specific data points and design requirements applicable to each product category will become clearer. In the meantime, companies should ensure that any product data already collected, including LCA outputs, supplier documentation, and declarations of conformity, is stored in a structured and accessible format. This will ease the process of populating Digital Product Passports once the relevant delegated act for a given product category is published. 

Build the technical infrastructure for your Digital Product Passport 

When the relevant delegated act for your product category is published, companies will need to put in place the technical building blocks of a DPP. This means assigning each product a unique identifier (such as a GTIN), generating a data carrier, typically a QR code or GS1 Digital Link, to be placed on the product or its packaging, and hosting a product page where the DPP information can be accessed by scanning that code. Companies should assess their existing IT systems early to understand what changes will be needed to support these requirements across their product range.