ESPR explained: the regulation making Digital Product Passports mandatory
If you have read about the Digital Product Passport, you have met its legal engine: the ESPR. This is the regulation turning the DPP from a voluntary sustainability idea into a condition of access to the EU market. Here is what the ESPR is, when it bites, and what it means for the products you place on the market.
What is the ESPR?
The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) entered into force in July 2024. It replaces and greatly expands the old Ecodesign Directive, which only covered energy-related products. The ESPR extends eco-design thinking to almost all physical goods sold in the EU and makes the Digital Product Passport one of its central instruments.
How the ESPR sets requirements
The ESPR itself is a framework. It does not list every rule for every product; instead it empowers the European Commission to adopt delegated acts that set specific requirements — including DPP requirements — category by category. This is why the honest answer to “what exactly must my product show?” is always: it depends on your category and its delegated act.
The timeline: what happens when
- 2024 — ESPR enters into force; the Commission begins working plans and priorities.
- 2025–2026 — first working plan and delegated acts drafted for priority groups.
- ~2027 — first categories’ obligations, with textiles widely expected among the earliest to require a DPP.
- February 2027 — separately, the battery passport becomes mandatory for certain batteries under Regulation (EU) 2023/1542.
Exact dates shift as delegated acts are finalised, but the direction is fixed and the runway is short.
Which products are affected first?
The ESPR prioritises product groups with high environmental impact and clear improvement potential. Textiles and apparel lead the conversation, alongside iron and steel, aluminium, furniture, tyres and several others. Batteries move on their own faster track. If you make or sell in any of these, you should already be preparing.
What companies actually have to do
Under the ESPR, affected products will need to carry a Digital Product Passport that makes defined data available through a data carrier such as a QR code. In practice that means:
- Assign a standards-based identity to the product (GS1 identifiers, GS1 Digital Link).
- Collect and structure the required attributes for your category — composition, recycled content, durability, repairability, and so on.
- Record lifecycle events with an open standard such as GS1 EPCIS 2.0.
- Make the passport accessible and portable, in line with the Data Act’s openness requirements.
Does the ESPR reach beyond the EU?
Yes, in effect. The obligation is triggered by placing a product on the EU market, so manufacturers and exporters based outside Europe are pulled in as soon as their goods reach European shelves. For non-EU exporters, early preparation is a competitive advantage, not just a compliance cost.
How to prepare without over-building
The mistake is to wait for the final delegated act and then scramble. The identity and event-data foundations are common across categories, so you can build them now and layer category-specific attributes later. A distribution layer built on open standards means you issue and exchange passports once, rather than re-integrating for every partner and border.
Frequently asked questions
Is the ESPR the same as the Digital Product Passport?
No. The ESPR is the regulation; the DPP is one of the instruments it mandates. The ESPR is the “why and when”; the DPP is the “what.”
When exactly will my product need a DPP?
It depends on your category’s delegated act. Textiles are expected around 2027; batteries are required from February 2027 under a separate regulation. Track the delegated act for your product group.
What standards should I build on?
GS1 identifiers and GS1 Digital Link for identity, and GS1 EPCIS 2.0 for lifecycle events, aligned with the ESPR and the Data Act on openness and portability.
Prepare for the ESPR the right way
See how a standards-based passport distribution layer gets you ready without lock-in.
Related reading: What is a Digital Product Passport? · The research behind our approach
The ESPR article by article
For a closer look at the Digital Product Passport chapter of the ESPR, see our article-by-article explainers: