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.
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