Ecodesign Regulation
The Regulation of the European Parliament and of the Council establishing a framework for the setting of ecodesign requirements for sustainable products and repealing Directive 2009/125/EC(ESPR) forms an essential part of the European Green Deal with regard to the economic transformation to a circular economy. With a few exceptions, the ESPR applies to the placing on the market and putting into service of all products. In particular, food, feed and medicinal products, as well as animals, plants, vehicles and products with strategic or defence uses are excluded.
The ESPR is a framework regulation on the basis of which product-specific ecodesign requirements are defined by the European Commission, which are documented in a digital product passport and must be transferable. The first ESPR requirements for certain product categories, prioritising textiles, steel and furniture, will be published at the beginning of 2026. They are then expected to apply from 2027.
The ESPR also contains bans on disposable clothing and clothing accessories as well as shoes and obliges companies to design products sustainably. The corresponding specific regulations on the ban are expected to be applicable from mid-2025.
ESPR: The development
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125 April 2024
EP plenary vote on the final ESPR text
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2May 2025
Final adoption by the Council
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3June 2024
Publication in the Official Journal
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4June/July 2024
Entry into force
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5Q3 2024
Establishment of an ecodesign forum; invitation to join
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6End of 2024
First meeting of the Ecodesign Forum
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7March 2025
Adoption of the 1st ESPR work plan
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8Mid 2025
Legal acts prohibiting the destruction of unsold goods and exceptions
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9End of 2025
Legal acts on DPP registers, service providers, data carriers, digital credentials
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102026
Adoption of the first ESPR measures (e.g. textiles/steel)
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112027/2028
Validity of the first product requirements
Consequences for companies
On the one hand, companies must design their products according to the specific product-specific parameters of eco-design. This includes a number of requirements, in particular
- easy repair and maintenance
- recycling-orientated design
- indicators for reuse, retrofitting and remanufacturing, but also affordability of spare parts
- use of used components and recycled materials as well as the material, CO2 and environmental footprint.
Companies must document the condition of the products in a digital product passport, which must be passed on along the supply chain. The supply chain is understood more as a supply cycle because the steps of reuse and processing are also included.
If companies do not fulfil the product requirements, they may not be placed on the market or put into operation. Placing on the market also includes import in the sense of release for free circulation.
The ban on the destruction of clothing and shoes applies regardless of this.
How we can provide support
The lawyers of the Green Trade Team offer sound advice on the ESPR. We actively follow all stages of the legislative process with regard to the product-specific delegated acts and offer strategic advice during consultation phases. In addition, we regularly inform you about current developments. Our law firm offers customised compliance solutions and strategic advice to meet the specific requirements of the regulation. We have specialised expertise, particularly in the area of the circular economy and supply chain processes. Our advice takes into account not only EU-wide regulations, but also relevant international standards thanks to our cooperation with partner law firms worldwide. Due to our broad and cross-thematic expertise, we offer holistic advisory approaches that cover all areas of the Green Deal, i.e. emissions, resource scarcity, circular economy, biodiversity and human rights.
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