# EU ESPR

Sustainability & Circular Economy

###### Ecodesign for Sustainable Products Regulation

## The EU Just Expanded Ecodesign Requirements to Nearly Every Physical Product. Can You Prove Compliance Across Your Entire Portfolio?

ESPR compliance demands product-level sustainability data—material composition, substances of concern, recycled content, durability metrics—collected from every supplier and delivered via a Digital Product Passport. Delegated acts are rolling out now. The first product-group requirements apply from 2027.

Certivo automates ESPR evidence collection from supplier sustainability declarations to DPP-ready documentation.

## Regulation Overview

**Jurisdiction:** European Union / European Economic Area  
**Regulatory Body:** European Commission (enforcement via national market surveillance authorities)  
**Regulation Number:** Regulation (EU) 2024/1781  
**Effective Date:** Entered into force July 18, 2024 (product-group requirements phased from 2027)  
**Official Source:** [Link](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en)  
**Key Threshold:** Virtually all physical products placed on the EU market (product-group delegated acts set specific requirements)

## What is ESPR?

ESPR is the EU's framework regulation for making sustainable products the norm on the European market. It replaces the Ecodesign Directive 2009/125/EC and expands scope from energy-related products to virtually all physical goods—including components and intermediate products.

For supply chain and product compliance teams, ESPR introduces two core obligation types: performance requirements (durability, recyclability, recycled content, substance restrictions) and information requirements (Digital Product Passport, substances of concern disclosure, energy labeling). Each obligation is activated through product-group delegated acts adopted by the European Commission.

ESPR compliance requires granular product data—material composition, substances of concern, recycled content percentages, carbon footprint metrics—from suppliers across your value chain. When delegated acts are adopted, your portfolio must be assessed against new requirements within an 18-month compliance window.

## Key Components / Sub-Frameworks

### Obligation 
- Minimum thresholds for durability, recyclability, recycled content, energy efficiency

### Performance Requirements
- Quantitative/qualitative product sustainability criteria

### Obligation 
- Digital Product Passport, substances of concern, labeling

### Information Requirements
- Mandatory product data disclosure

### Obligation 
- Material composition, origin, sustainability metrics, compliance evidence accessible via data carrier  
**Digital Product Passport (DPP)**  
- Digital identity record for products

### Obligation 
- Disclosure of SoC name, location, concentration; potential performance restrictions

### Substances of Concern (SoC)
- Tracking chemicals that inhibit circularity or pose risks

### Obligation 
- Disclosure obligations from July 2025; destruction ban from July 2026 (large enterprises)

### Unsold Goods Provisions
- Ban on destruction of unsold consumer products

### Obligation 
- EU Declaration of Conformity and CE marking required before market placement

### Conformity Assessment
- Verification of ecodesign requirement compliance

## Key Compliance Requirements

### Who Must Comply
- EU/EEA manufacturers of products covered by ESPR delegated acts
- Importers placing covered products on the EU market
- Distributors making covered products available in the EU
- Non-EU companies selling through EU importers or authorized representatives
- Companies assembling products from components subject to ESPR requirements
- Economic operators discarding unsold consumer products

## Key Thresholds

- Product-group delegated acts: Specific ecodesign requirements activated per product category
- 18 months: Typical compliance window after delegated act adoption
- July 2026: DPP registry operational; unsold goods destruction ban (large enterprises)
- 2027–2030: Phased enforcement of product-group ecodesign and DPP requirements

## Core Obligations

1. **Digital Product Passport**  
   - Create DPP with material composition, sustainability data, compliance evidence per delegated act  
   **DEADLINE:** Per product-group delegated act (first expected 2027)  
2. **Substances of Concern Disclosure**  
   - Disclose SoC name, concentration, location, and safe-use instructions in DPP  
   **DEADLINE:** Per product-group delegated act  
3. **Performance Requirements**  
   - Meet minimum thresholds for durability, recyclability, recycled content, energy efficiency  
   **DEADLINE:** Per product-group delegated act  
4. **Conformity Assessment**  
   - Complete assessment and issue EU Declaration of Conformity with CE marking  
   **DEADLINE:** Before market placement  
5. **Unsold Goods Disclosure**  
   - Disclose volume and reasons for destruction of unsold consumer products  
   **DEADLINE:** From July 19, 2025 (large enterprises)

## Frequently Asked Questions

### What products are covered by the EU ESPR?

ESPR covers virtually all physical products placed on the EU market, including components and intermediate products. Exemptions apply to food, feed, medicinal products, and certain vehicles already regulated by sector-specific legislation. Specific ecodesign requirements are activated through product-group delegated acts—the first Working Plan prioritizes iron, steel, aluminium, textiles, furniture, tyres, detergents, paints, lubricants, chemicals, and electronics. Certivo tracks all delegated act developments and maps them to your product portfolio.

### What are the penalties for ESPR non-compliance?

EU member states are responsible for enforcement through market surveillance authorities. Non-compliant products can be removed from the EU market, and authorities can require corrective actions, recalls, or sales restrictions. Specific penalty structures are defined at the member-state level. Products without valid conformity assessment and CE marking cannot be legally placed on the EU market once delegated acts are in force.

### What is the Digital Product Passport and when is it required?

The DPP is a digital record attached to each product via a QR code or data carrier, containing verified information about material composition, sustainability attributes, substances of concern, and end-of-life guidance. DPPs become mandatory per product group as delegated acts are adopted—first enforcement expected from 2027. The DPP registry will be operational by July 2026. CORA collects and structures supplier data into DPP-ready formats automatically.

### How does Certivo help with ESPR supplier data collection?

Certivo launches automated campaigns to collect material composition, recycled content, substances of concern, and sustainability data from suppliers in any format and language. CORA extracts and validates the data against ESPR delegated act requirements, identifies gaps, and generates DPP-ready evidence packages. This reduces data collection timelines from months to weeks and assembly from weeks to hours.