Introduction
Recently, the 17th Chemical Regulatory Annual Conference (CRAC China 2025), officially concluded. During this period, Dr. Julian Schenten of Client Earth gave a detailed interpretation of the REGULATION (EU) 2024/1781 (ESPR), which attracted widespread attention at the scene. Based on the key points of the conference, this article extracts the key information of ESPR for corporate compliance reference.
What Is the Role of ESPR Under the European Green Deal?
As an important part of the European Green Deal, the core goal of ESPR is to create a unified framework for products to achieve "sustainability":
Clearly stipulates the requirements for product ecological design performance and digital information disclosure;
Improve the sustainability of products in the EU market from the source, and enhance the competitiveness and resilience of the EU economy.
Help the EU achieve the economic transformation goal of "clean, decarbonized and resource-efficient" and promote the implementation of green development strategies.
How Is ESPR Being Implemented?
The implementation of ESPR is carried out in stages, and each time node is directly related to the compliance preparation cycle of enterprises, which needs to be accurately grasped:
Basic node for the entry into force of the regulation: On June 28, 2024, the ESPR was officially released in the Official Journal of the European Union; On July 18, 2024, the regulation officially entered into force and applies to all EU member states.
The first batch of controlled products is clear: On April 16, 2025, the European Commission released first "2025-2030 Work Plan" of ESPR, which clearly includes the five categories of products such as steel and aluminum, textiles (with a focus on clothing), furniture, tires, and mattresses as the first to be included in the scope of ecological design requirements and energy label control in the next five years.
Follow-up implementation rules and transition period: The European Commission will successively issue Delegated Acts for various product groups, clarifying specific control lists, Eco-design compliance standards, and timelines. The relevant control entities are usually given 18 months of transition time to advance compliance preparations.
ESPR Scope
Scope: From "energy-related products" to "virtually full category coverage"
One of the core changes in the ESPR is the significant expansion of the scope of control, which officially replaces the previous Ecodesign Directive 2009/125/EC.
Its control targets extend from the initial energy-related products to almost all physical goods circulated or used in the EU market, although specific products such as food, feed and medicines are not included in the control for now.
It should be noted that when the ESPR came into effect, the compliance of 19 types of energy-related products had made substantial progress in accordance with the old directive.
To ensure a smooth transition, ESPR has a transition mechanism in place – until the end of 2026, these products can continue to advance compliance with the old directive without the need to immediately transition to ESPR requirements.
Who Does the ESPR Apply to?
ESPR clarifies the control subjects and corresponding obligations of each link of the supply chain, covering the entire chain from production to sales, including:
Manufacturer: any natural or legal person who designs or manufactures a product and sells it under its own name or trademark;
Importer: Any natural or legal person in the European Union who imports and places products from third countries on the Union market;
Distributor: any natural or legal person in the supply chain who supplies products to the EU market, other than the manufacturer or importer;
Distributor: any natural or legal person who sells products to end customers in the European Union;
Authorized representative: any natural or legal person in the European Union who has been authorized in writing by the manufacturer to perform an obligation on his behalf.
ESPR Core Requirements & Tools
ESPR has built a core control system for product sustainability through the combination of "mandatory requirements + innovation tools".
Ecological Design Requirements: Multi-dimensional Standards Covering the Entire Life Cycle of Products
Unlike the previous regulations that only focused on "energy saving", ESPR requires product design to run through the entire life cycle and sets mandatory "minimum sustainability requirements", which include three directions:
1. Physical Properties: Emphasis is placed on product durability, reliability, reusability, upgradeability, repairability, and maintainability and refurbishment, extending product life from the design source.
2. Energy Efficiency and Resource Efficiency: Emphasis is placed on improving the energy use and efficiency of products, resource use and efficiency, water use and efficiency, while focusing on recycled content, remanufacturing possibilities, material recycling possibilities, circularity, waste generated, and environmental impact (including carbon footprint and environmental footprint)
3. Substance of Concern: Strictly control the following harmful chemical substances in products to ensure that products are "non-toxic" and avoid the recycling and reuse of products after disposal due to the presence of harmful substances.
SVHC substances that meet the criteria of Article 57 under the EU REACH Regulation (EC) No 1907/2006 and are recognized by Article 59(1);
Substances classified as one of the following hazard classifications according to the EU CLP Regulation (EC) No 1272/2008: CMR substance class 1/2, endocrine disruptor class 1/2, substances with PMT/vPvM/PBT/vPVB properties, respiratory allergens class 1, skin sensitizers category 1, chronic category 1~4, harmful to the ozone layer, Specific target organ toxicity (repeated exposure/one-time exposure) category 1/2;
Substances controlled under the EU POPs Regulation (EU) 2019/1021;
Other substances that adversely affect the material reuse and recycling of the products in which they are located.
Digital Product Passport: A Digital Identity Card for Product Sustainability
To address supply chain information asymmetry and facilitate regulatory and compliance verification, ESPR has innovatively launched the "Digital Product Passport (DPP)" tool, with the following core values and considerations:
Core Features: Like the "ID card" of the product, it stores key information (such as Eco-design indicators, hazardous substance content, recycling plans, etc.) of the entire value chain of the product, making it convenient for manufacturers, suppliers, consumers, repairers, recyclers and other value chain entities to obtain the required information, and at the same time helping EU regulators quickly verify product compliance.
Scope of application: DPP is not required for all products – DPP is only mandatory for product groups that have explicit information requirements in the ESPR Product Specific Authorization Act. For example, the new EU battery law has introduced DPP requirements.
Conclusion
If the product is included in the DPP control requirements, the product imported into the EU market must be generated and accompanied by a digital product passport. In this case, domestic exporters and manufacturers of products need to ensure compliance with the Ecodesign requirements of specific product groups in the future and provide product information.
In the context of global resource constraints, a well-functioning circular economy is a condition for improving the sustainable competitiveness of the industry, and ESPR is an important driver of the normalization of "sustainability" in the era of competition.
All industries should pay attention to the sustainable ecological design of products, including the possibility of circular economy business models, and the upstream and downstream of the supply chain should form alliances to jointly address compliance challenges.
