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ESPR Regulation (EU) 2024/1781 Explained

The Ecodesign for Sustainable Products Regulation is the legal framework that mandates the Digital Product Passport for physical goods sold in the EU. Here is what it requires, who it applies to, and when.

ESPR — Regulation (EU) 2024/1781 — entered into force on 18 July 2024. It replaces the 2009 Ecodesign Directive and extends its scope from energy-related products to virtually all physical goods sold in the EU, requiring a Digital Product Passport for each regulated product category.

Who Does ESPR Apply To?

Manufacturers, importers, distributors and retailers, and authorised representatives. The obligation follows the product onto the EU market, so it reaches whoever places it there, not only whoever made it.

Manufacturers
Any company that manufactures a product placed on the EU market. Includes manufacturers outside the EU selling into it.
Importers
Entities importing regulated products into the EU must ensure DPP compliance if the manufacturer is outside the EU.
Distributors & Retailers
Must verify that DPP data carriers are present and accessible on products they stock.
Authorised Representatives
Non-EU manufacturers must appoint an EU-based authorised representative to handle DPP obligations.

Which ESPR articles matter most?

The ones that define the passport: ecodesign requirements, the Digital Product Passport itself, the data carrier, the unique product identifier, the EU product passport registry, product information requirements, and market surveillance.

Art. 4
Ecodesign Requirements
Empowers the Commission to set product-specific ecodesign requirements via delegated acts. Covers energy use, materials, repairability, and recyclability.
Art. 9
Digital Product Passport
Defines the DPP: a data record accessible via data carrier, linked to a unique product identifier, containing performance and sustainability data.
Art. 10
Data Carrier
Mandates a physical data carrier (QR code, RFID, etc.) on the product or packaging, compliant with GS1 Digital Link standard.
Art. 11
Unique Product Identifier
Requires a persistent, globally unique identifier per product model or batch, registered in the EU DPP Registry.
Art. 12
Product Passport Registry
Establishes a European Commission-operated registry for all DPP data carriers and identifiers.
Art. 25
Market Surveillance
Member states must conduct compliance checks. Non-compliant products can be withdrawn from the market.
Annex I
Product Information Requirements
Lists all data fields that may be required: materials, hazardous substances, repairability, spare parts, carbon footprint, and lifecycle data.
Annex III
DPP Diagnostic Criteria
The conformity assessment framework used to evaluate DPP completeness — the basis for compliance scoring.

When does ESPR take effect?

In phases. The first delegated acts arrive from August 2025, the Battery Passport becomes mandatory in February 2027, and coverage widens towards full scope from there.

Phase 1Aug 2025 onwards
  • Commission publishes first delegated acts
  • Battery Passport obligations finalised (Reg. 2023/1542)
  • Consultation on textiles & electronics DPP structure
Phase 2Feb 2027
  • Battery Passport mandatory for industrial & EV batteries
  • QR code carrier required on every physical battery
  • Supplier data collection must be in place
Phase 32028–2030
  • Textiles DPP mandatory (est. mid-2028)
  • Electronics DPP mandatory (est. 2029)
  • Packaging, steel, cement, chemicals follow
Full Scope2030+
  • All 30+ product categories under ESPR scope
  • Full EU DPP Registry operational
  • Mandatory third-party audit for high-risk categories

What are the penalties for non-compliance?

ESPR does not set a single EU-wide penalty — member states set their own. However, market surveillance authorities can:

  • Order product withdrawal from the EU market
  • Issue corrective action notices with mandatory compliance deadlines
  • Impose fines — typically up to €10M or 4% of annual global turnover (per Member State law)
  • Restrict future market access for repeat violations

Official Sources

Official ESPR Regulation text (EUR-Lex)View
European Commission DPP pageView
Battery Regulation (EU) 2023/1542View
Sector Guide
Battery Passport Guide
Timelines
DPP Deadlines by Sector
All Guides
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