Sustainable product innovation: The EU Ecodesign for Sustainable Products Regulation (ESPR) driving a greener market

The European Union is taking a significant step toward a sustainable and circular economy by introducing the Ecodesign for Sustainable Products Regulation (ESPR), effective since July 18, 2024. This Regulation replaces the previous Ecodesign Directive 2009/125/EC and expands its scope beyond energy-consuming products to almost all physical goods. This Regulation is a key part of the EU's Green Deal, which aims to achieve climate neutrality by 2050. 

The ESPR sets stricter ecodesign standards for nearly all physical products sold within the European market, with only a few exceptions, such as food, feed, and medicinal products. 

These requirements go beyond energy efficiency to include durability, repairability, recyclability, and a general reduction of environmental and climate impacts. Products will be designed to last longer, be more easily repairable, and facilitate recycling.

The key aspects on the ESPR include:

• Stricter ecodesign requirements for all product categories.
• The creation of a Digital Product Passport to offer more transparency regarding materials and sustainability. Information on material composition and any substances of concern in the product will be included, together with information on how it can be safely used, recycled and disposed of. For more information, we refer to our article regarding the Digital Product Passport.
• Restrictions on the disposal of surplus products, with a clear differentiation between B2B and B2C products.
• Encouragements to boost the circular economy, including recycling, remanufacturing, and repair.

In principle, if a product is already regulated by sector-specific legislation, the ESPR is not likely to intervene, with exception to certain construction products—such as energy-related products (e.g. heaters, boilers, heat pumps, ventilation systems) and intermediate products (e.g. building materials or components)—which will generally fall under the ESPR for sustainability requirements, while the Construction Products Regulation (“CPR”) which will enter into force on January 8, 2026 may complement by addressing other aspects like safety.

The Regulation came into force on July 18, 2024, and is directly applicable across all EU member states. The first ESPR Working Plan adopted and published on April 16, 2025, prioritizes product categories and defines compliance deadlines. Product rules will then be developed based on inclusive planning, detailed impact assessments, regular stakeholder consultation within the Ecodesign Forum, and specific consultations. The aforementioned rules will be adopted as from 2026. Subsequently, companies will have at least 18 months following the adoption to meet product-specific measures, with a phased implementation for certain product groups or complex requirements.

The ESPR aims to harmonize sustainability Regulations across the EU’s internal market, preventing fragmented national legislation and ensuring fair competition. This creates economic opportunities in sectors such as remanufacturing, recycling and repair, fostering innovation and job creation.

As mentioned, the first Working Plan under the ESPR was adopted and published on April 16, 2025, outlining a five-year strategy (2025-2030) with a mid-term review in 2028. It includes a prioritized list of products for energy labelling in accordance with the Energy Labelling Framework Regulation. In general, older labels will be updated to reflect current market and technological advancements.

The Working Plan identifies four final products and two intermediate products for immediate focus, i.e.:

• Final products:

1. Textiles/Apparel: improving product lifetime extension, material efficiency, and reducing environmental impacts.
2. Furniture: enhancing resource use and mitigating production-related environmental impacts.
3. Tyres: improving recyclability and managing end-of-life waste more effectively.
4. Mattresses: reducing waste generation and enhancing material efficiency.

• Intermediate products:

1. Iron and Steel:improving climate change impacts and energy consumption, complementing existing green steel initiatives.
2. Aluminium: enhancing recyclability and reduce greenhouse gas emissions through the use of secondary materials.

• Horizontal requirements:

1. Repairability: aiming to enhance circularity and durability across various product categories.
2. Recycled Content and Recyclability: focusing on electrical and electronic equipment to improve resource use and waste prevention.

The Working Plan also carries over 16 products from the previous ecodesign and energy labelling plan, with specific adoption timelines set for various categories, ensuring a smooth transition to the new Regulations:

By replacing the Ecodesign Directive, the ESPR strengthens the EU’s objectives for a circular economy and sustainable future. Products will become more durable, repairable and recyclable, helping the EU in transitioning to a resource-efficient model. For businesses, this represents both a challenge and an opportunity to innovate and support the EU Green Deal’s common goals. With the first Working Plan adopted on April 16, 2025, the Regulation will continue to develop, providing more explicit guidelines for companies navigating this transformative change.