ESPR & Digital Product Passport: The Ecodesign Regulation for Industry in Germany at a Glance

The EU Ecodesign Regulation for Sustainable Products (ESPR) aims to promote sustainable and innovative products and initiates a market mechanism within the EU single market that clearly favors these products.

It replaces the previous Ecodesign Directive (2009/125/EC) and significantly expands its scope – for example, to textiles, electronics, and many other product groups.

This is intended not only to reduce environmental impacts, but also to create fair competitive conditions for companies in the EU and help shape global sustainability standards. In this article, you will learn whether your products are directly or indirectly affected and what specific requirements are placed on these products.

Current timeline of affected product categories

It has already been determined when the requirements of the Ecodesign Regulation will apply to the first final products, intermediate products, and horizontal requirements. In this context, final products refer to goods sold directly to consumers – such as clothing, furniture, tires, or mattresses. For these product groups, the ESPR sets specific ecodesign requirements. Intermediate products are industrial precursors like iron, steel, or aluminum, which are used in further manufacturing processes. Environmental requirements are also to be defined for them, for example, regarding their CO₂ footprint or the proportion of recycled material.

Horizontal requirements, in turn, are rules that apply across products within a category or industry. An example is reparability: Instead of creating separate regulations for each individual electronic device, a horizontal requirement for reparability would apply to all electronic products – i.e., equally to smartphones, laptops, and washing machines. They thus differ from vertical requirements, which relate only to a specific product.

Final Products:

• 2027: Textiles / Apparel
• 2027: Tires
• 2028: Furniture
• 2029: Mattresses

Intermediate Products:

•  2026: Iron and Steel
•  2027: Aluminium

Horizontal Requirements:

• 2027: Repairability (incl. repair score) for consumer electronics and small household appliances
• 2029: Recycled content & recyclability of electrical and electronic equipment

The categories mentioned above are being prioritized, and their implementation timeline is already established. However, the ESPR will eventually apply to almost all physical products placed on the EU market or put into service. Exceptions only exist for specific categories like food or medical products, where ecodesign requirements are either impractical or already covered by other regulations.

Products that could follow in the first wave include detergents, paints, and lubricants. Footwear was initially excluded. However, due to its environmental impact, a study is already underway to investigate the potential for ecological improvement of footwear under the ESPR, with results expected by the end of 2027. Chemicals are also currently excluded. Due to their complexity, a study will be launched by the end of 2025 to examine how they could be integrated into the ESPR in the future.

What requirements will apply to the affected products?

The ESPR provides the legal basis for establishing ecodesign requirements, but these will vary depending on the product category. This means each product category will have its own specific requirements. These requirements will be based on 4 overarching categories:

Requirement 1: Product Design

Products placed on the EU market will in the future have to meet 9 specific ecodesign requirements.

1. Durability and Reliability
2. Reusability
3. Upgradability, Repairability, Maintenance, and Refurbishment
4. Absence of substances of concern
5. Energy and resource efficiency
6. Recycled content
7. Remanufacturing and Recyclability
8. CO₂ and environmental footprint
9. Waste generation throughout the product lifecycle

These requirements aim to make products more sustainable, durable, and circular. For these categories, limits will be progressively set, which they must not fall below or exceed.

Requirement 2: Digital Product Passport (DPP)

The Digital Product Passport is a central element of the ESPR, making ecodesign requirements transparent and implementable throughout the entire value chain. It contains relevant information such as material composition, CO₂ footprint, hazardous substances, and repair and recycling instructions – accessible to businesses, authorities, and consumers. The DPP will be mandatory for almost all regulated products, with the exception of energy-related products, which will continue to use the energy label (EPREL).

Technical Requirements for the Digital Product Passport:

• Data carrier (e.g., QR code or NFC tag) with a unique product identifier
• Placement on the product, packaging, or accompanying documents
• Standardized format according to ISO/IEC 15459:2015
• Machine-readable & interoperable

The DPP connects data, processes, and stakeholders – making sustainable products achievable in practice. The DPPs will be made accessible in a central EU register. They will be viewable and verifiable there. This portal is intended to be available to consumers, authorities, and businesses by July 2026.

Requirement 3: Waste prevention for unsold products

The ESPR obliges companies to be more transparent in their handling of unsold products and to reduce waste.

In the future, companies must publicly disclose:

• The quantity of disposed unsold consumer products
• The reasons for their disposal
• The disposal methods used, according to the waste hierarchy (e.g., reuse before destruction)

The regulation gives the EU the possibility to introduce a ban on the destruction of unsold products. However, this is not yet being utilized in the current work plan – the Commission is first awaiting data from the new disclosure obligations to be able to specifically justify future bans.

Requirement 4: Criteria for environmentally friendly public procurement

The ESPR enables the EU to set binding minimum requirements for public procurement. This means that public bodies, such as authorities, could be obliged to purchase particularly environmentally friendly products – provided it is economically viable.

For products prioritized in the current work plan, the EU Commission is assessing whether procurement criteria should be established alongside ecodesign requirements.

For energy-related products, public procurement is already linked to their energy efficiency – for example, through energy labeling or the Energy Efficiency Directive.

Key takeaway for industrial companies:

The ESPR and the Digital Product Passport mark a profound transformation for industrial companies in the EU. They establish clear frameworks for sustainable product design, mandate greater transparency along the supply chain, and set new standards for product circularity. Even though the implementation period is staggered, affected companies should prepare now for the upcoming requirements – especially in prioritized product groups such as textiles, furniture, or metals.

The Digital Product Passport will become a central instrument: It makes environmental and material data visible and accessible – for authorities, business partners, and consumers. Companies that invest early in systematic data management, ecodesign optimization, and digital infrastructure not only ensure regulatory compliance but also gain a competitive advantage in an increasingly sustainability-oriented internal market.

The ESPR is not just a compliance issue – it is an opportunity to strategically develop sustainable industrial processes and products.