Updated by Emma Owens (original blog authored by Marcus Schneider)
The Ecodesign for Sustainable Products Regulation (ESPR) entered into force on July 18, 2024. As one of the central building blocks of the EU’s Circular Economy Action Plan (CEAP), it reshapes how manufacturers bring products to market across the EU.
ESPR is more than just a regulation — it’s a major shift in how companies approach product compliance, design, and sustainability. And now that it’s here, the fine print is starting to come into focus. Delegated acts for product-specific rules will begin rolling out in 2025, with the current working plan extending through 2030. More is expected beyond that until nearly all product groups are covered. Once a delegated act is finalized, companies will typically have 18 months to comply, unless otherwise specified. In addition, broadly applicable rules will be established early on, applicable to all product groups and likely to set requirements coming into force before any sector-specific acts.
So, what’s new — and what do you need to do to keep your products moving into the EU?
A Refresher on the ESPR Framework
At its core, ESPR aims to improve the environmental sustainability, circularity, and performance of nearly every physical product sold on the EU market. It replaces the older Ecodesign Directive, which focused on energy-related products.
Under ESPR, the rules are broader and deeper. New requirements go beyond energy efficiency to include:
- Material use and composition
- Recycled content and recyclability
- Substances of Concern: POPs, SVHCs, substances that hinder circularity, and thousands of substances regulated under CLP
- Product durability, reparability, and upgradability
- Carbon and environmental footprint
- Other sustainability-related data from the supply chain (with social sustainability under consideration for future phases, pending further evaluation)
And it doesn’t stop at collecting this information. ESPR also requires manufacturers to provide data before a product can receive the CE marking and enter the EU market — and to plan for improvement.
Enter the Digital Product Passport
One of the biggest updates is the central role of the Digital Product Passport (DPP). Think of it as a digital identity card for your product. It contains key sustainability, compliance, and performance information that’s accessible to regulators, customers, and supply chain partners.
The goal? Greater transparency — and accountability — throughout the product’s life cycle. This means companies can no longer rely on end-of-line compliance checks. Instead, the data needed to populate DPPs must be gathered during product development and design.
But the DPP isn’t everything. Despite the considerable attention it receives, it represents only a portion of the data and processes needed to establish sustainable product design as defined by ESPR. Sustainable design requires the early involvement of the supply chain in both information gathering and active management.
What’s Changed Since ESPR Became Law
While ESPR’s high-level goals remain the same as those of the Ecodesign Directive, there are a few critical updates:
- The product scope is broader than ever and almost all physical goods and their parts placed on the EU market will be affected
- Data requirements have expanded, so manufacturers can expect to provide more detail on recycled content, hazardous substances, and life cycle carbon emissions, with social metrics coming in later stages
- The timing is also more clear, and delegated acts will define specific requirements by product group, with the first wave expected between 2025–2027. After each act is finalized, companies will have roughly 18 months to comply unless otherwise stated
- Sustainability data is no longer a side conversation. It’s front and center in design, sourcing, and investment decisions. CFOs and CROs are taking notice
- Several types of goods are under discussion for a “lifetime” DPP, which would mean constant updates of an individual product’s DPP during its lifespan to reflect on its current state and to allow for better understanding of its sustainable performance
This shift also raises the stakes for your supplier data. To meet ESPR obligations, manufacturers will need more detailed information from upstream suppliers — at scale.
How Manufacturers Maintain EU Market Access
ESPR represents a fundamental shift in chemical and material compliance. Until ESPR, manufacturers often waited until the end of the product development process to gather compliance data, using it primarily for quality documentation. ESPR changes that. Now, key sustainability data — covering materials, substances of concern, recyclability, carbon footprint, and more — must be gathered at the early product design stage to inform sustainable decision-making and ensure products are prepared for CE labeling.
This shift elevates product compliance data to a strategic asset. Sourcing, design, and financial decisions are now influenced by whether a product can meet ESPR’s sustainability and circularity thresholds. That means more functions across the organization — particularly CPOs and CFOs — are paying close attention to the cost of compliance and its impact on long-term market access.
To maintain access to the EU market, manufacturers must expand their supplier data collection efforts. The ESPR’s broad scope means that even companies outside the EU — those supplying components or materials — may be asked to provide detailed compliance and sustainability data. In-scope manufacturers will be responsible for gathering and validating this information across global supply chains.
Failure to comply with ESPR can result in steep consequences: fines, reputational damage, and loss of EU market access. And because ESPR is tied to CE marking requirements, enforcement will be coordinated across EU member states and backed by expanding market surveillance capabilities.
The bottom line? Companies that want to compete in the EU will need to build robust, scalable compliance processes — well before ESPR deadlines arrive. Non-compliance could mean losing the ability to sell your products in the EU altogether. And in a world where transparency is currency, reputational risk looms large.
How Assent Helps You Prepare
ESPR isn’t a one-time checklist — it’s a moving target. As ESPR expands to cover more product groups and introduces new requirements, manufacturers will need to keep up, adapt quickly, and demonstrate sustainable performance across their supply chains.
Assent helps you stay ahead. Our platform brings together the tools, supplier engagement, and regulatory expertise you need to build a compliance program that’s flexible, scalable, and built for change. Whether you’re collecting data on substances of concern, recycled content, or critical raw materials, Assent makes it easier to do it early — and do it right.
With AI-enabled insights and scalable supplier engagement and support, you can identify risks faster, reduce manual work, and respond to new requirements without starting from scratch. And because ESPR is just one part of a rapidly shifting regulatory landscape, having a centralized solution ensures you’re ready for whatever comes next — from CE marking rules to future circularity metrics.
If you’re not yet preparing for ESPR, now’s the time. Watch our on-demand webinar, ESPR Essentials: Understanding the New Ecodesign for Sustainable Products Regulation, to see how your current processes stack up — and what to prioritize next.
