ESPR is Regulation (EU) 2024/1781, in force since 18 July 2024. It is a framework for setting product-specific ecodesign and information requirements for physical products placed on the EU market or put into service, with listed exclusions. A Digital Product Passport is one instrument in that framework, alongside performance rules, labels, unsold-product measures and green public procurement criteria that become concrete through later measures. This is general guidance, not legal advice.
What ESPR is — and what it is not
It is
A directly applicable EU regulation
Member States do not rewrite it. It establishes a framework for later product-specific or horizontal rules.
Broader than energy-related products
Article 1 applies to physical goods placed on the market or put into service, including components and intermediate products, with listed exclusions.
It is not
A Digital Product Passport law only
Article 1 also covers ecodesign requirements, mandatory green public procurement powers and a framework to prevent destruction of unsold consumer products.
A single 2026 or 2027 DPP deadline
Most product performance, information and passport duties wait for a delegated act. Working Plan years are not application dates.
ESPR is broader than the Digital Product Passport
Do not equate ESPR with DPP. The regulation can use several tools. Product-specific delegated acts decide which tools apply to a group.
- FrameworkESPR
- PerformanceEcodesign requirements
- InformationInformation requirements
- PassportDigital Product Passport
- Other toolsLabels, unsold-product measures, GPP
A Digital Product Passport is one instrument. It is not the whole regulation. Product-specific delegated acts decide which tools apply to a group.
In text: ESPR can set performance requirements, information requirements, Digital Product Passports, labels, unsold-product measures and green public procurement criteria. Those tools become concrete through the relevant product measure, except where the framework itself already names a duty.
Scope and exclusions
Article 1(2) applies ESPR to any physical goods placed on the market or put into service, including components and intermediate products. It does not apply to food, feed, medicinal products, veterinary medicinal products, living plants, animals and micro-organisms, products of human origin, or products of plants and animals relating directly to their future reproduction. Vehicles covered by the cited type-approval acts are excluded only for aspects already set in those sector-specific acts.
A further product-group exemption can exist where another EU law already provides a digital information system that achieves the same goals. That is a Commission decision, not a self-declared opt-out.
Energy-related products remain in scope. Named workstreams continue under the Ecodesign Directive transition until 31 December 2026, with longer amendment arrangements to 2030. Those products are on a staged path; they are not outside ESPR.
How product rules are made
Article 4 empowers the Commission to adopt delegated acts setting ecodesign requirements. Those acts can include performance requirements and information requirements. Information requirements may or may not include a Digital Product Passport.
Article 4(4): the date of application of a delegated act shall not be earlier than 18 months from its entry into force, except in duly justified cases, or where an earlier date is set for a partial repeal or amendment.
Article 18 working plans list product groups to be prioritised and estimated timelines. COM(2025) 187, adopted 16 April 2025, is the first such plan. Inclusion is preparatory. It does not adopt a delegated act, create a DPP duty, or fix a compliance date. Indicative portal years remain planning years: 2026 iron and steel; 2026–2029 energy-related products; 2027 textiles, tyres and aluminium; 2028 furniture; 2029 mattresses and ICT. As of 4 September 2026 the iron-and-steel delegated act was not identified as adopted.
Digital Product Passports inside ESPR
Chapter III (Articles 9–15) is the ESPR passport system. Article 9: where information requirements provide for a DPP, products can only be placed on the market or put into service if a passport is available. The delegated act specifies data, carrier, layout, positioning, granularity, pre-sale access, actors, updating and availability. Data must be accurate, complete and up to date.
Article 10: a data carrier connects to a persistent unique product identifier. Formats should support open standards, interoperability, machine-readability, searchability and transferability without vendor lock-in. A data carrier is broader than a QR code. Access is free of charge and based on access rights. Article 11 covers technical design, storage and persistence. Annex III is a menu of possible elements, not a universal mandatory-field list.
The Registry indexes identifiers and required registration data. It is not a warehouse of every product file. Article 15(3): customs interconnection is to be operational within four years of the registry implementing act. Standalone laws can also require a DPP — batteries, toys, detergents, construction. Those are not ESPR delegated acts.
Unsold products and green public procurement are not DPP duties
Chapter VI is separate from the passport. Article 23 requires economic operators to take measures that can reasonably be expected to prevent the need to destroy unsold consumer products. Article 24 requires operators that discard unsold consumer products to disclose volumes, reasons and destinations. Article 24 does not apply to micro and small enterprises. It applies to medium-sized enterprises from 19 July 2030. Large companies are already in the framework disclosure duty. Commission Implementing Regulation (EU) 2026/2, adopted 9 February 2026, sets the common disclosure format and applies from 2 March 2027.
Article 25(1) prohibits destruction of unsold consumer products listed in Annex VII from 19 July 2026. Annex VII covers specified apparel and clothing accessories and specified footwear — not all unsold goods. The prohibition does not apply to micro and small enterprises. It applies to medium-sized enterprises from 19 July 2030. Derogations exist (Delegated Regulation (EU) 2026/296). Do not treat the destruction rule as a ban on all unsold goods.
Article 65 allows the Commission to set minimum green public procurement requirements for products covered by an Article 4 delegated act. GPP is not a Digital Product Passport requirement and is not a current universal purchasing rule.
Economic operators
Chapter VII (Articles 27 and following) assigns role-based obligations when a product is covered by a delegated act adopted pursuant to Article 4. Manufacturer, authorised representative, importer, distributor, dealer and fulfilment-service duties are not identical. Detailed layering belongs on ESPR requirements.
What is not yet determined
- Developing
almost all ESPR product datasets, carriers, granularity and application dates.
- Developing
iron-and-steel delegated act — not located as adopted on 4 September 2026.
- Developing
whether each Working Plan group will receive a DPP.
- Developing
remaining two Official Journal-cited DPP standards (access-rights and authentication).
- Developing
Battery Regulation Article 77(9) access act — not an ESPR act, and not identified as adopted.
Primary and authoritative sources
Source links are provided for verification. Scope, consolidated versions and later measures should be checked again before implementation or reliance.
Regulatory disclaimer. This content provides general diagnostic and preparation information. It is not legal advice, certification or regulatory approval. Requirements may differ by product category, jurisdiction, market and supply-chain role and may change over time.