The regulation behind the Digital Product Passport—and what it means for product development and compliance
Regulation doesn’t just happen on paper—it reshapes how products are made, tracked, and delivered. One of the most significant pieces of EU legislation now taking shape is the Ecodesign for Sustainable Products Regulation (ESPR).
If you’re a brand selling in Europe—or working with suppliers who are—this regulation is set to impact how you design your products and how you work with your supply chain. And it goes far beyond energy efficiency or recycling labels. The ESPR lays the groundwork for product-level sustainability standards across industries, from apparel and travel gear to electronics and packaging.
What is the ESPR?
The Ecodesign for Sustainable Products Regulation was adopted by the European Commission to replace and expand the scope of the original Ecodesign Directive. While the original focused mainly on energy-related products, the ESPR applies to nearly all physical goods placed on the EU market—including textiles, footwear, travel accessories, and more.
It introduces minimum sustainability requirements for product design and production, aiming to reduce environmental impact throughout the entire product lifecycle.
The ESPR is also the legal foundation for the Digital Product Passport (DPP), which will make product data accessible and traceable across the supply chain.
What does ESPR mean in practice?
The regulation sets out several core areas where requirements will eventually be applied:
- Durability, reusability, and repairability
- Recycled content and material composition
- Environmental footprint and energy use
- Presence of substances of concern
- Product information and labeling, including the DPP
The idea is to design products that last longer, use better materials, and can be more easily recycled, repaired, or reused—and to make this information visible and verifiable.
Which products are affected?
While the ESPR is a framework regulation, the EU will introduce product-specific rules over time. These rules will start with sectors identified as high-impact and high-priority, including:
- Textiles and apparel
- Footwear
- Luggage and travel gear
- Furniture
- Electronics and batteries
- Packaging and intermediate products
The first Working Plan, expected in Q2 2025, will outline which products are covered first and what requirements they must meet.
When does it apply?
Here’s the ESPR timeline based on current official guidance:
- July 18, 2024: The Ecodesign for Sustainable Products Regulation (ESPR) entered into force
- October–November 2024: The Ecodesign Forum will be established, with a call for stakeholder membership
- First half of 2025: The European Commission will adopt the first Working Plan, identifying the product groups and measures to be prioritized over a three-year period
- 2025–2026: Product-specific and horizontal measures will be developed through preparatory studies, stakeholder consultations, and impact assessments
- 2026 onwards: Delegated acts will begin to be adopted, establishing ecodesign requirements for selected product categories. These will typically apply 18 months after adoption
How PACTICS is responding
We’ve worked for years to build supply chain practices that align with impact, integrity, and collaboration. ESPR formalizes many of the standards we already strive to meet—but it also pushes us to do more. Here’s how we’re preparing:
- Closely monitoring developments in product design requirements to stay aligned with evolving ESPR
- Improving traceability and data collection for inputs and materials
- Working with clients to ensure the products we manufacture can meet future EU requirements
Final thoughts
The ESPR signals a shift: away from fast and disposable, and toward circular and intelligent design. For brands and sourcing professionals, it’s a chance to build products with real value—while also staying ahead of what’s coming.
We’re here to support this shift. If you’re looking for a partner who understands both compliance and long-term impact, reach out—let’s explore how we can work together.
Related Reads:
- The Future of Transparency: The Consequences of CSRD and ESRS on Your Business – PACTICS
- Collaborating to Mitigate Social & Environmental Impacts: the Way to Comply with the CSDDD – PACTICS
- Establishing a Sustainable Partnership With Your Supplier – An Introduction to Pactics’ Brand-Supplier Framework – PACTICS
Sources:
- https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en
- https://green-business.ec.europa.eu/implementing-ecodesign-sustainable-products-regulation_en
- Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/ECText with EEA relevance.
