Regulation (EU) 2024/1781 enters into force, replacing the 2009 Ecodesign Directive (2009/125/EC). Disclosure obligation for large companies on unsold consumer goods (Article 24) applies from the first full financial year following entry into force.
New EU rules for nearly every physical product
ESPR: Ecodesign for Sustainable Products Regulation
The Ecodesign for Sustainable Products Regulation (Regulation EU 2024/1781, "ESPR") requires companies placing physical goods on the EU market to meet ecodesign requirements on durability, recyclability, and substance transparency, defined per product category in delegated acts.
Covered product categories must carry a Digital Product Passport (DPP) once their delegated act applies. Large companies must stop destroying unsold apparel, clothing accessories, and footwear from July 19, 2026.
Next relevant deadline
July 19, 2026: Large companies can no longer destroy unsold apparel, clothing accessories, and footwear.
The destruction ban is a hard product operations restriction, not a reporting threshold. Products that would previously have been discarded must be redirected to donation, resale, or other documented alternatives before this date.
Destruction is still permitted in a narrow set of defined derogation cases, but each instance requires documented justification retained for five years.
Companies selling apparel, clothing accessories, or footwear that have not yet mapped their unsold inventory handling processes need to do so now.
Regulation timeline
What ESPR requires
The Ecodesign for Sustainable Products Regulation (ESPR) entered into force on July 18, 2024, replacing the 2009 Ecodesign Directive (2009/125/EC). It applies to manufacturers, importers, distributors, dealers, and fulfillment service providers placing or making available physical goods on the EU market, regardless of where those companies are headquartered or where their products are manufactured.
ESPR is a framework regulation. Specific ecodesign requirements covering durability, reparability, recyclability, recycled content, and substance transparency are set for individual product groups through delegated acts.
Once a delegated act on Digital Product Passports applies to a product category, covered products must carry a Digital Product Passport linking standardized lifecycle data to a physical data carrier.
ESPR also prohibits large companies from destroying unsold apparel, clothing accessories, and footwear, and requires disclosure of how unsold consumer goods are handled.
Common ESPR implementation challenges for product and compliance teams
Each product category is subject to its own delegated act under ESPR
A delegated act is a separate piece of EU legislation that defines the ecodesign and Digital Product Passport requirements for one product group, adopted by the European Commission on a rolling timeline. Companies operating across multiple product categories face different requirements and deadlines depending on which delegated acts already cover their portfolio.
Most DPP data requirements sit with suppliers, not in structured records
Under ESPR, a Digital Product Passport is required once a delegated act applies to a product category, and its data fields include material composition, substance declarations, recycled content evidence, and end-of-life information. Most of this data sits with suppliers at tier two or tier three, often without structured digital records on file.
The destruction ban and disclosure obligation apply on different timelines
Compliance teams face four separate dates for the same set of obligations rather than one fixed implementation point.
Large companies have been subject to the disclosure obligation for unsold consumer products since financial year 2025, with the standardized reporting format under Implementing Regulation (EU) 2026/2 taking effect from March 2, 2027.
The destruction ban applies separately, from July 19, 2026, with narrow, documented derogations under Delegated Regulation C(2026) 659. Medium-sized companies face both the destruction ban and the standardized disclosure requirements from July 19, 2030.
ESPR's Digital Product Passport requirements overlap with REACH, RoHS, and PPWR data fields
Companies running REACH, RoHS, or PPWR compliance have built a separate workflow for each regulation, even though ESPR's Digital Product Passport requirements draw on the same material composition, substance declaration, and recycled content data. Without a shared data structure, teams run separate supplier engagement exercises for the same underlying data, requesting it more than once from the same suppliers.
Manage ESPR, PPWR, and REACH from one product data record
The osapiens Product Compliance Suite handles ESPR obligations through the osapiens HUB for General Product Compliance and the osapiens HUB for Digital Product Passport.
Both modules run on the same product and supplier record used for PPWR, PFAS, and REACH compliance.
Collect structured product data at SKU level across every applicable regulation
The osapiens HUB for General Product Compliance maps supplier data requests to the exact fields required by each regulation, assigning products to regulatory profiles and requesting ESPR-relevant data including material composition, substances of concern, and lifecycle information. Data collected for REACH or PPWR is reused directly for the DPP without a second collection exercise.
Connect DPP records to the EU Central Registry as soon as a delegated act applies
The osapiens HUB for Digital Product Passport generates DPP records from validated product data and connects to the EU Central DPP Registry in line with GS1 standards and ESPR data carrier requirements, tracking DPP status at SKU level with full traceability to the underlying supplier declaration. DPP templates update as delegated acts define new product-specific data fields, without requiring a new implementation cycle.
Document the destruction ban and disclosure obligation in one place
The osapiens HUB for General Product Compliance structures the documentation workflow for unsold consumer products to align with the reporting format under Implementing Regulation (EU) 2026/2, capturing alternative handling routes, derogation justifications, and annual disclosure data. The same product data layer covers PPWR packaging compliance, so companies managing both obligations avoid duplicate supplier engagement for the same material and substance data.
Frequently asked questions
ESPR applies to manufacturers, importers, distributors, dealers, and fulfillment service providers placing or making available physical goods on the EU market. The regulation applies regardless of where the company is headquartered or where products are manufactured. A non-EU manufacturer selling into the EU faces the same ESPR obligations as an EU-based producer once a delegated act covers their product category. The only products excluded from ESPR scope are food, feed, medicinal products, animals, and a limited number of categories explicitly listed in the regulation text.
The ESPR destruction ban on unsold apparel, clothing accessories, and footwear applies to large companies from July 19, 2026, and to medium-sized companies from July 19, 2030. Micro and small enterprises are currently exempt. Destruction remains permitted only in narrow, documented derogation cases defined in Delegated Regulation C(2026) 659, with records retained for five years. DPP requirements apply once a delegated act covers a product category. The first ESPR Working Plan (2025-2030), adopted April 16, 2025, identifies iron and steel, textiles, aluminium, tyres, furniture, and mattresses as the first priority groups, with indicative timelines from 2026 to 2028 and a minimum 18-month implementation period before requirements take effect.
ESPR requires each EU Member State to establish penalties that are effective, proportionate, and dissuasive. The regulation does not prescribe a specific maximum fine as a percentage of turnover. Member State enforcement measures may include administrative fines, product withdrawal orders, restrictions on placing products on the EU market, and removal of CE marking for non-conforming products. For the destruction ban specifically, non-compliant large companies face enforcement action from national authorities from July 19, 2026.
Both ESPR and PPWR require product-level data on material composition, recycled content, and substance declarations. PPWR applies these requirements specifically to packaging, while ESPR applies comparable requirements, through delegated acts, across a broad range of product categories, with significant overlap between the two data fields. A company managing both obligations through the osapiens HUB for General Product Compliance collects supplier data once, structures it at SKU level, and reuses the same record for PPWR substance documentation, ESPR DPP data fields, and PFAS tracking, without running separate surveys for each regulation.
The osapiens HUB for General Product Compliance and the osapiens HUB for Digital Product Passport collect material declarations, substance data, and lifecycle information from suppliers today, structured to the data fields ESPR delegated acts are expected to require. Once the delegated act for a product category is adopted, the underlying data is already in place. The DPP record updates to reflect the confirmed data fields without a second supplier engagement exercise.
