Sustainable NPD was not only essential for protecting the environment and society but also for ensuring the long-term success of businesses, meeting consumer expectations, and fostering a healthier, more equitable society. Increasingly regulators are also seeing as an area that requires legislation … enter The Ecodesign for Sustainable Products Regulation (ESPR).
The 2023 Made in Britain export survey found that Europe is by far the most active export region for UK manufacturers, followed by North America, Asia-Pacific and the Middle East, in that order. We must keep a very careful eye on new regulations in our largest export market. The latest ONS data shows that in 2023, the EU accounted for 49% of UK goods exported and 55% of goods imported into the UK.
Enacted in July 2024, the ESPR represents a pivotal moment in the European Union’s drive toward sustainability, a more circular economy, and a stronger commitment to environmental responsibility and links into their work on combatting greenwashing. As climate change and resource depletion become more pressing global challenges, the ESPR is designed to revolutionise product life cycles, making sustainable production, use, and disposal the new norm across Europe.
The ESPR is part of the EU’s ambitious European Green Deal, which aims to make Europe climate-neutral by 2050. It expands on the 2009 Ecodesign Directive but takes it several steps further, covering a broader array of products and incorporating stricter requirements for sustainability. This regulation addresses various issues, including product durability, repairability, recyclability, and energy efficiency, targeting products that traditionally have significant environmental impacts throughout their life cycle.
The core objective of the ESPR is to ensure that products entering the EU market are designed to be sustainable, promoting responsible consumption and production patterns. The regulation also seeks to reduce the carbon footprint associated with product manufacturing and disposal, ultimately contributing to the EU’s overall environmental goals.
Key features of the ESPR
Product design and circularity
One of the most groundbreaking aspects of the Ecodesign for Sustainable Products Regulation (ESPR) is its strong emphasis on circular economy principles, which mark a fundamental shift in how products are designed, manufactured, and consumed. A key requirement under the ESPR is that manufacturers must design products to last significantly longer than they currently do. Many consumer goods, especially electronics, textiles, and household appliances, are often designed with limited durability, forcing consumers to replace them frequently. The ESPR will enforce durability standards that require companies to create products that maintain their functionality and efficiency over an extended period. This change not only benefits consumers, who will spend less on replacements, but also reduces the environmental impact of mass production and disposal.
Beyond durability, the ESPR introduces strict requirements for repairability. Many modern products, particularly electronic devices, are designed in a way that makes repairs difficult or impossible, either due to proprietary components, glued-in batteries, or a lack of available spare parts. The ESPR will mandate that manufacturers design products that can be easily repaired and maintained, ensuring that spare parts, repair manuals, and software updates are readily available.
Recyclability is another cornerstone of the ESPR’s circular economy focus. Under the new regulations, manufacturers will need to design products in a way that allows for easy disassembly and recycling at the end of their useful life. This means using materials that can be effectively recovered and reintegrated into new products, rather than ending up in landfills or incinerators. Many existing products are composed of complex material combinations that make recycling inefficient or unfeasible. By enforcing design-for-recycling principles, the ESPR will promote the use of single-material components, modular designs, and non-toxic substances that do not hinder the recycling process.
The environmental benefits of these circular economy principles are profound. By extending product lifecycles and promoting repairability and recyclability, the ESPR helps reduce the demand for raw material extraction, which is one of the leading causes of deforestation, habitat destruction, and pollution. The mining and processing of raw materials, such as rare earth metals for electronics or petroleum-based fibres for textiles, are energy-intensive and contribute significantly to carbon emissions. If manufacturers produce goods that last longer and can be repurposed, the overall consumption of raw materials can be drastically reduced, helping to mitigate climate change and protect natural ecosystems.
Digital product passports
A standout initiative within the ESPR is the introduction of Digital Product Passports, also referred to as ‘Material Passports’. These will contain detailed information about a product’s environmental impact, materials used, and repairability. The goal is to increase transparency for consumers, making it easier for them to choose sustainable products. Additionally, these passports will aid recycling and waste management companies by providing crucial data on how to handle end-of-life products. For those in the building materials market familiar with Environmental Product Declarations (EPDs), this will take data and transparency to a new level.
New ecodesign requirements
The ESPR broadens the scope of ecodesign beyond energy-related products, applying the concept to a wider range of goods, including textiles, electronics, furniture, and construction materials. Products will now need to meet stringent criteria related not just to energy efficiency but also resource efficiency, repairability, and end-of-life disposal.
Mandatory recycled content and recyclability
The regulation will set mandatory minimums for recycled content in new products, aiming to close the loop on material use. Additionally, manufacturers will need to ensure that their products are designed to be easily recyclable, reducing the burden on waste management systems and ensuring valuable materials are recovered rather than lost in landfills.
Ban on destructive practices
In a push to prevent waste, the ESPR proposes a ban on premature obsolescence and the destruction of unsold or returned goods. This will particularly impact industries like fast fashion, where overproduction and waste have caused significant environmental problems. The regulation aims to incentivise more responsible production practices and reduce unnecessary waste.
Impact on key sectors
The ESPR will impact 29 product groups and especially industries with traditionally high environmental footprints such as:
The full list of product groups with Ecodesign criteria are:
While the ESPR is a progressive step toward sustainability, its implementation will not be without challenges. For manufacturers, adapting to these new requirements may involve significant upfront costs in redesigning products and supply chains.
However, the regulation also presents significant opportunities. Businesses that innovate in sustainable design and circular economy practices will be well-positioned to thrive in this new landscape. Consumers, increasingly concerned about environmental impact, are likely to favour brands that can demonstrate their commitment to sustainability.
Implementation, new Act for the ESPR
Each regulated product group under the Ecodesign Directive is subject to an ‘implementing act,’ which is a legally binding regulation that enforces specific ecodesign criteria for that product category. These implementing acts are crucial in ensuring that products placed on the EU market meet sustainability and energy efficiency standards. The EU continuously works on developing new implementing acts for emerging product groups while revising and updating existing ones to align with evolving technological advancements, environmental goals, and market needs.
Currently, these implementing acts are established under the existing Ecodesign Directive, which has been in place since 2009. However, with the forthcoming Ecodesign for Sustainable Products Regulation (ESPR), these acts will eventually transition under its framework. Once the ESPR comes into force, it will replace the current directive and absorb the existing implementing acts, ensuring a more comprehensive and ambitious approach to sustainable product design across all regulated product groups.
A prime example of this evolving regulatory framework is the implementing act on mobile phones and tablets, which was adopted in June 2023 and will be applied from June 2025. This new regulation mandates manufacturers to design devices that are more durable, feature longer-lasting batteries, and support prolonged availability of software updates and spare parts. This marks a significant shift in focus compared to previous energy-efficiency-driven regulations, emphasising a broader ‘Right to Repair’ approach. The act aims to extend the lifespan of electronic devices, reduce electronic waste, and empower consumers with better repairability and upgrade options.
This shift towards repairability and sustainability represents a major step in the EU’s strategy to move beyond energy efficiency alone and address the full life cycle of products. By incorporating requirements such as repair-friendly design, modular components, and mandatory support for software updates, these implementing acts aim to combat planned obsolescence, enhance product longevity, and promote a circular economy. As the ESPR takes over, it is expected to further refine these requirements, expanding them to a wider range of product groups and setting a new global benchmark for sustainable product legislation.
Global implications
The Ecodesign for Sustainable Products Regulation (ESPR) is not merely a European initiative; its impact is poised to extend far beyond the borders of the EU, influencing global markets, supply chains, and regulatory frameworks. As one of the world’s largest economic blocs, the EU holds significant sway over international trade and production standards. When the EU implements new regulations, manufacturers worldwide often adjust their practices to maintain access to this lucrative market. As a result, the ESPR has the potential to drive substantial changes in production processes, material sourcing, and product design on a global scale.
One of the primary ways the ESPR will impact global markets is through its strict sustainability criteria, which all products sold in the EU must meet. This means that non-EU companies exporting goods to the European market will have to align with the regulation’s eco-design requirements, including durability, repairability, recyclability, and resource efficiency. For many manufacturers, adapting to these new standards will necessitate significant shifts in their production processes, supply chain management, and product design strategies. Companies that fail to comply may face restrictions on selling their products within the EU, effectively losing access to one of the world’s most important consumer bases.
Beyond its direct impact on global businesses, the ESPR could also influence policymakers in other regions to introduce similar sustainability measures. Historically, the EU has played a pioneering role in setting regulatory trends that other countries and regions eventually adopt. This phenomenon, often referred to as the “Brussels Effect,” has been evident in areas such as data protection (with the General Data Protection Regulation, GDPR) and chemical safety (with the Registration, Evaluation, Authorisation, and Restriction of Chemicals, REACH). Given the EU’s track record, it is highly likely that the ESPR will inspire similar legislation in other parts of the world, particularly in major economies like the United States, China, and Japan.
For multinational corporations, this could mean a broader shift towards sustainability-driven business models, even in regions where regulations are not yet as strict. Rather than producing different versions of a product to meet varying regulatory requirements, companies may find it more efficient and cost-effective to standardise their production processes according to the highest regulatory benchmarks—likely those set by the EU under the ESPR. This would accelerate the global transition toward more sustainable production and consumption patterns.
Additionally, the ESPR’s emphasis on the circular economy, resource efficiency, and waste reduction aligns with international sustainability goals, such as the United Nations’ Sustainable Development Goals (SDGs) and global climate agreements like the Paris Agreement. As more countries commit to reducing carbon emissions and minimising environmental impact, policies similar to the ESPR could become a critical tool in achieving these broader objectives.
Ultimately, the ESPR is set to be a game-changer in sustainable product regulation. Its influence will extend beyond European borders, encouraging businesses, regulators, and policymakers worldwide to prioritise eco-friendly labels and design, responsible resource use, and circular economy principles. By leading the way with comprehensive sustainability requirements, the EU is not only transforming its own market but also shaping the future of global commerce, pushing industries worldwide toward a greener and more responsible approach to production and consumption.
