EU 2024/1781 · ESPR

EU Digital Product Passport Regulation

The EU Ecodesign for Sustainable Products Regulation (ESPR / 2024/1781) is the legal foundation for mandatory Digital Product Passports across the European Union. It entered into force on 18 July 2024 and replaces the earlier Ecodesign Directive 2009/125/EC.

What is the ESPR Regulation?

The EU Ecodesign for Sustainable Products Regulation (ESPR), formally Regulation (EU) 2024/1781, is the cornerstone of the European Green Deal's Circular Economy Action Plan. It expands the previous Ecodesign Directive's energy-efficiency focus to cover durability, repairability, recycled content, hazardous substances, and end-of-life management.

The regulation is a directly applicable EU law, meaning all 27 member states must enforce it without national transposition. Manufacturers, brand owners, and EU importers must comply, even if their headquarters are outside the EU.

Scope of the Regulation

ESPR covers virtually all products placed on the EU market, with a few exemptions (food, feed, medicinal products, military equipment, and some animal/plant products). The regulation applies to:

  • Finished consumer products (textile, electronics, furniture, etc.)
  • Intermediate products (steel, aluminium, plastics, chemicals)
  • Components and subassemblies
  • Both new and remanufactured items

The European Commission progressively extends ESPR via delegated acts, prioritising sectors with the highest environmental footprint.

ESPR Working Plan 2025-2030

The first ESPR Working Plan (published April 2025) sets the priority sectors and timelines:

2027Textiles & apparel (first wave)
2028Electronics, batteries (already EU 2023/1542)
2029Iron, steel, aluminium, furniture, tyres
2030Packaging, chemicals, paints, lubricants, toys

Penalties & Enforcement

Each EU member state designates a Market Surveillance Authority responsible for ESPR enforcement. Penalties for non-compliance vary but typically include:

  • Fines: Up to 4% of annual EU turnover or €100,000+ per infringement
  • Market ban: Non-compliant products withdrawn from sale
  • Recall orders: Mandatory product recall at the manufacturer's expense
  • Public disclosure: Non-compliance published in EU public registers
  • Criminal liability: In severe cases involving safety or fraud

Frequently Asked Questions

ESPR entered into force on 18 July 2024 (20 days after publication in the EU Official Journal). However, sector-specific requirements take effect via delegated acts from 2027 onwards.

Yes. Any manufacturer or distributor placing products on the EU market must comply, regardless of where they are headquartered. Non-EU companies typically appoint an EU-based Authorised Representative.

No. Foods, feeds, medicinal products, plants, animals, and military equipment are exempt. Cosmetics are partially in scope (packaging only).

Through delegated acts adopted by the European Commission, often after public consultation and impact assessment. The first delegated act for textile is expected in late 2026.

Officially, ESPR recommends GS1 Digital Link as the standard. Other formats are technically permitted but may complicate cross-border interoperability and audits.

Yes. Each delegated act includes a transition period (typically 18-24 months) between adoption and applicability, giving manufacturers time to comply.

ESPR complements REACH (chemicals) and RoHS (hazardous substances in electronics). The DPP must reference SVHC (REACH) and RoHS data, ensuring a single source of truth.

Related DPP Topics

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