In 2024, the European Parliament adopted new ecodesign legislation. This Ecodesign for Sustainable Products Regulation (ESPR) stipulates that virtually all product groups must be designed to be both more energy-efficient and more circular. Manufacturers must also provide clear information on this. ESPR’s purpose is to make sustainable products the norm across the European Union.

The new regulation replaces and builds on the Ecodesign Directive from 2009 (Directive 2009/125/EC). The Ecodesign Directive’s main aim was to increase the energy efficiency of electrical and electronic equipment. ESPR, however, will apply to almost every product group and introduce minimum requirements for circularity, including requirements related to product lifetime, repairability, and recyclability.

Performance and information requirements

ESPR introduces two types of requirements: performance requirements and information requirements. Performance requirements aim to improve the environmental performance of products. Information requirements are intended to ensure transparency, for instance through the introduction of a Digital Product Passport (DPP). Only a few product groups, such as food, medicines, and motor vehicles, are exempt.

Performance requirements are determined on the basis of relevant product parameters, such as:

• The lifetime and reliability of the product
• Ease of repair and maintenance
• Ease of reuse, refurbishment, remanufacturing, and recycling
• Consumption of energy, water, and other resources
• Use of recycled materials
• The carbon, environmental, and material footprint of the product

Information requirements set conditions for the data required in the product passport, such as the presence of substances of concern, and the product’s performance with regard to the product parameters listed above.

What are the next steps?

In the coming years, product-specific ecodesign requirements will be established for each product category through so-called delegated acts. In the first ESPR working plan for the period 2025–2030, the European Commission gives priority to four end products, two intermediate products, and two “horizontal” requirements (overarching requirements that will apply to multiple, comparable product types).

End products

• Textiles (2027)
• Furniture (2028)
• Tyres (2027)
• Mattresses (2029)

Intermediate products

• Iron and steel (2026)
• Aluminium (2027)

Horizontal requirements

• Repairability scores for multiple product groups (2027)
• Requirements for the use of recycled content and the recyclability of electrical and electronic equipment (2029)

In addition, electrical and electronic equipment that is already covered by the Ecodesign Directive will transition to the ESPR. For some of these products, such as dishwashers and refrigerators, the potential for improvement still needs to be assessed. These products are therefore included in the ESPR working plan. Research is also being conducted into the improvement potential for footwear (to be completed by the end of 2027) and chemicals.

In 2028, the European Commission will carry out an interim evaluation. Additional product groups may then be announced.

How can you prepare for the ESPR?

Companies can prepare by recording data on the product parameters listed in Annex I of the ESPR and by substantiating and documenting their design choices. By conducting a hotspot analysis, you can already identify opportunities to improve the environmental performance of your product.

It is also worthwhile to start early with collecting relevant product data for the Digital Product Passport (DPP). By exploring in advance how internal processes can be organised for this purpose and by consulting with supply-chain partners in a timely manner, your business will be able to collect the required data quickly and accurately in the future.

How can we support you?

Our circular economy experts, who have many years of experience as industrial designers, can support you with ecodesign challenges. We can help you make practical and strategic choices to meet ecodesign requirements, such as extending product lifetime, reuse, repair, design for recycling, and the use of recycled materials. We can also help prepare your organisation for collecting data for the Digital Product Passport.

We can provide insight into the environmental impact of your product by carrying out a life cycle analysis. Based on a hotspot analysis, we can help improve the environmental performance of your design. In addition, we conduct circularity scans: how circular are you currently, and what are opportunities for improvement? We can support you by developing custom ecodesign tools for your designers and monitor and evaluate your progress.