EU ESPR Guide
The key facts about the EU Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport - explained concisely.
What is the ESPR?
The Ecodesign for Sustainable Products Regulation (ESPR) is the EU framework regulation that harmonises sustainability requirements for products. It came into force on 18 July 2024 and replaces the previous Ecodesign Directive.
A central instrument of the ESPR is the Digital Product Passport (DPP): an electronic data record that can be accessed via a data carrier attached to the product - usually a QR code - and that provides transparent information on origin, materials, repair and disposal.
In short: the ESPR defines the “what” (requirements for products), the DPP is the “how” (data provision via QR code and the web).
Timeline
The ESPR is brought into force step by step through delegated acts for each product category. The European Commission has published a prioritised timeline:
From 2027
Batteries (EV and LMT batteries as well as industrial batteries above 2 kWh). The first binding DPP obligation, mandatory from February 2027, arising from the separate Batteries Regulation.
From 2028
Iron and steel, construction products and packaging. The delegated acts are adopted in 2026/2027; the DPP obligation applies roughly eighteen months later.
From 2029
Textiles, aluminium, tyres, electronics and ICT products, furniture and mattresses. Acts mostly adopted in 2027/2028, applying from 2029.
From 2030
Toys (EU Toy Safety Regulation, applying from 1 August 2030). Exempt areas such as food and pharmaceuticals do not fall under the ESPR - there the DPP remains a voluntary transparency tool.
In parallel, the central EU DPP register - the index that links each product identifier to its decentrally stored passport - must be operational by 19 July 2026 under the ESPR.
The timeline is not set in stone. Political conditions and technical consultations can shift individual dates. We recommend that companies begin preparing at the latest 24 months before the binding obligation takes effect.
More on this: ESPR timeline 2027: what battery manufacturers need to know now.
Who is affected?
In principle, every economic operator that places products on the EU market or imports them into the EU from a third country. This includes:
- Manufacturers and brand owners
- Importers from third countries (incl. Switzerland, UK, USA, China)
- Distributors and sales partners (limited obligations)
- Online marketplaces and fulfilment service providers
SMEs benefit from eased rules but are not exempt as a matter of principle. The obligation depends primarily on the product category, not on the size of the company.
Mandatory data in the DPP
The exact data catalogue is defined per product category in the delegated act. Recurring mandatory content includes:
Product identification
- GTIN, serial or batch number
- Manufacturer and origin details
- Authorised economic operator in the EU
Material composition
- Components and weight shares
- Hazardous substances and REACH-relevant substances
- Recycled content and bio-based content
Environmental performance
- Carbon footprint (cradle-to-gate or cradle-to-grave)
- Water and energy consumption in manufacturing
- Service life, repairability, recyclability
Use and disposal
- Repair and maintenance instructions
- Take-back and recycling guidance
- Declarations of conformity, certificates and test reports
Interoperability and provider independence
The ESPR requires product passports to be interoperable and built on open standards - machine-readable, structured, and exchangeable between systems. The Commission’s accompanying standardisation mandate makes the goal explicit: identifiers must be portable across an open, interoperable network, without vendor lock-in and transferable between resolver services and systems.
In practice: choosing a DPP provider must not tie you to it. Already published passports have to survive a change of provider. Open standards like GS1 Digital Link and open-source rendering tools are how that is achieved - more on the Transpareo Time Machine.
Penalties
The ESPR leaves the specific definition of penalties to the member states. These must be “effective, proportionate and dissuasive”. Initial drafts envisage:
- Fines whose amount is set by the member states
- A ban on sale and placing on the market for serious infringements
- Recall of non-compliant products
- Exclusion from public tenders
The market surveillance authorities of the member states will carry out spot checks - and can draw on publicly accessible DPPs to do so, data-driven.
More on this: what the DPP obligation really costs - and what penalties cost.
Preparation
Even without a binding obligation, preparing early pays off:
- Structure your product catalogue: take stock of product data, identify data gaps.
- Involve suppliers: collect material and origin data along the supply chain.
- Choose the technical foundations: GS1 Digital Link, QR code strategy, hosting, API integration.
- Start a pilot: publish individual products as a DPP and test internally.
- Scale: connect your full product range, secure data quality.
The greatest effort here is not in the passport itself but in digitising and consolidating the product data - why you should start building your data today.
With Transpareo: you import your product data via Excel or CSV, map your data onto the curated mandatory fields of your sector and publish your first DPPs within minutes. As new delegated acts arrive we continuously extend the platform so your data structure grows with it.
Sources
As of June 2026. This guide does not replace legal advice. For binding information, please consult your legal department or a specialist ESPR adviser.