EcoDesign for Sustainability Regulation (ESPR)

The EU’s EcoDesign for Sustainability Regulation (ESPR) is designed to make sustainable products the default in the EU. It aims to do this by setting a framework for new, product-specific rules that will raise expectations on durability, repairability, recyclability, and transparency across value chains.

The ESPR also introduces the concept of a Digital Product Passport (DPP) for products in the EU which seeks to explain how durable, repairable and recyclable an item is. The EU’s ambition is clear; the regulation seeks to make sustainable products standard.

What is ESPR?

ESPR replaces the EU’s previous sustainability regulations (which focused mainly on energy-related products) and expands sustainability requirements. Almost all products will be in scope, with a small number of exemptions for products such as food, feed and medicines (amongst others).

Crucially, ESPR is a framework regulation. It doesn’t impose one universal rulebook for every product today - instead, it enables the European Commission to introduce detailed requirements through delegated acts, either for specific product groups (e.g., textiles) or “horizontal” requirements that cut across multiple categories (e.g., repairability information).

ESPR will be implemented through Commission working plans and delegated acts. The first working plan (2025-2030) prioritises product groups with high environmental impact and strong potential for improvement. Priority categories include:

·       Textiles & apparel

·       Furniture & mattresses

·       Consumer electronics & IT equipment

·       Industrial materials

·       Tyres

·       Detergents and paints

The Digital Product Passport (DPP)

A central figure of the ESPR is the Digital Product Passport. A DPP is a digital record which provides standardised information about a product’s composition, environmental performance and lifecycle. The DPP remains with the product throughout its lifecycle. Once the regulations are formalised, any product - including those manufactured overseas - sold on the EU market will need to comply.

The DPP is being piloted initially with the ‘Battery Passport’ which mandates digital information requirements for certain battery types. The Battery Passport comes into place from 18 February 2027 and is also included in upcoming Toy Safety Regulation. Battery requirements will apply to:

·       Industrial batteries with a capacity above 2kWh

·       Electric Vehicle (EV) batteries

·       Light means of transport (LMT) batteries (e.g., for e-scooters and e-bikes).

The Battery Passport will include information such as the battery type, manufacturer details, battery composition and materials, safety and compliance information, lifecycle emissions, recycling and end-of-life information.

Recent updates

In early 2026, the final versions of two of the key delegated acts were released. These acts introduced a standardised format for reporting discarded, prohibited the destruction of certain unsold products (initially apparel, clothing, accessories & footwear), and defined the specific circumstances under which these items may be destroyed despite prohibitions. 

The ban on the destruction of unsold products will apply to large companies from the 19th July 2026 and to medium-sized enterprises from 2030. The annual disclosure with a standardised reporting format is due to apply from February 2027.

Why it matters (for corporates & investors)

For corporates, ESPR is likely to drive:

·       Product redesign and specification changes

·       New transparency & data obligations

·       Greater expectations of circularity

·       Wider enforcement and scrutiny

For private equity investors, it’s important that they are engaging with portfolio companies that may be in scope to ensure they’re acting on the forthcoming regulations. The regulation may also bring with it opportunities for value creation where companies can design more circular models and provide credible sustainability information.

How to prepare

Companies that start early will be best placed to manage compliance, reduce disruption and potentially gain a competitive advantage as expectations shift.

Get in touch if you’d like help:

·       Mapping your product portfolio against ESPR priority categories

·       Engaging with supply chains on traceability queries

·       Monitoring and translating upcoming delegated acts into practical product and data requirements.

The ESPR is set to reshape how products are designed, sourced, marketed, repaired and recycled. Companies that invest early - by building data infrastructure, engaging suppliers and designing for circularity - will be better positioned not only to comply, but to compete in a rapidly evolving marketplace.

If you’d like to hear more about ESPR and how it may impact you get in touch today.