Digital Product Passport & ESPR: what businesses can expect

With the Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport (DPP), the EU Commission is laying the foundation for a sustainable economy. For manufacturing companies, retailers and importers, this means that aspects such as circularity, energy efficiency, recyclability and durability are becoming increasingly important – and with them the requirements for your products and processes. In this article, you will learn the most important facts about ESPR and DPP and how you can prepare in good time. After all, acting timely not only creates clarity and legal certainty, but also secures a decisive strategic advantage.

ESPR at a glance: what you need to know

The Ecodesign for Sustainable Products Regulation (ESPR) is a key measure of the Circular Economy Action Plan (CEAP) adopted by the European Commission in March 2020. It serves to implement the European Green Deal and aims to make Europe more sustainable, cleaner and more competitive. The ESPR came into force on 18 July 2024 and replaces the Ecodesign Directive 2009/125/EC. The scope has been significantly expanded: instead of covering only energy-related products, the new regulation now applies to almost all physical products placed on the EU market. The only exceptions so far are food, feed and medicinal products.

• Rules to prevent the destruction of unsold consumer goods
• Minimum requirements for sustainable procurement by public authorities
• Introduction of a digital product passport

• Improving durability, reparability and retrofitability
• Reusability and ease of maintenance
• Increasing energy and resource efficiency
• Avoiding substances that hinder circularity
• Increasing the proportion of recycled materials
• Recording the CO₂ footprint and compliance with possible maximum values
• Limiting waste generation
• Transparent provision of information on product sustainability for consumers and businesses

The introduction of specific ecodesign requirements for the respective product groups will take place gradually. To this end, the European Commission is drawing up a multi-year work plan that specifies which product groups are to be regulated as a priority. Priorities are based on comprehensive impact assessments, stakeholder consultations and technical analyses within the framework of an Ecodesign Forum. The first ESPR working plan was published in April 2025 and is valid for a period of five years.

The Digital Product Passport (DPP): what it contains and how it works

• Technical performance characteristics
• Materials used and their origin
• Information on repair and maintenance options
• Information on recyclability
• Data on environmental impacts throughout the entire life cycle, e.g. using product carbon footprint (PCF) or life cycle assessment (LCA) 

For companies, this means that in future they will have to provide structured, reliable and digital sustainability data on their products.

ESPR milestones: DPP and product groups by 2030

The following timeline shows the most important developments and the introduction of product groups by 2030. It includes the planned dates for delegated acts that will set specific requirements for product groups, the transition period of at least 18 months, and the date by which the measures must be implemented. As the exact deadlines are still being developed and depend heavily on the respective product sector and the final decisions of the EU Commission, all dates mentioned are provisional. Companies should therefore regularly check the current status in order to adapt their products in good time.

The timeline is limited to product groups for which minimum environmental requirements are being introduced for the first time under the ESPR. The 35 products already regulated by the previous Ecodesign Directive 2009/125/EC are not included. For 19 of these, a transition period until 31 December 2026 applies, and the corresponding delegated acts should therefore be published in the near future. The remaining 16 products were included in the first ESPR working plan. These are listed in the table below, together with the provisional date of their delegated act.

(Source: Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030)

Detergents, paints, lubricants, footwear and chemicals are not yet included in the working plan. Some of these product groups were originally considered for the first implementation phase, but have been postponed due to their high complexity, regulatory overlaps or lack of data. Chemicals in particular offer considerable potential for reducing environmental impacts. However, there are many demarcation issues and interactions with existing EU regulations such as REACH. A study is therefore planned by the end of 2025 to examine which chemicals could fall under the ESPR in the future and how their sustainability can be improved in concrete terms.

3 things you can do now to prepare for the DPP

It is clear that the ESPR, and in particular the introduction of the Digital Product Passport, will have far-reaching implications for the market structure and economic environment in the EU. Anyone wishing to sell products on the European market in future will have to make their sustainability transparent and measurable. Companies should take action now, not only to comply with legal requirements, but also to benefit from the advantages of sustainable products.

These three measures will put you on the right track:

1. Collect relevant product data
   You should have a comprehensive overview of material information, origin, environmental impact and recyclability of your products. This can be done, for example, by creating a PCF or LCA.
2. Ensure that the results are presented transparently
   Unfortunately, compiling product data alone is not enough. The results must also be communicated in a targeted and comprehensible manner, for example in the form of standardised sustainability reports.
3. Develop a sustainability strategy
   Establishing fixed structures and setting concrete climate targets based on suitable sustainability KPIs forms the basis of a future-proof and resilient corporate strategy. This ensures that you are not playing catch-up with regulatory requirements, but actively addressing them.

As an experienced sustainability consultancy, we are happy to support you in these and further steps. Contact us today for a non-binding initial consultation.

Or get started right now by taking our free sustainability check for companies.

Text: Hannah Zachskorn