EU ecodesign rules establish mandatory environmental performance and product-information requirements for products placed on the European Union market.
EU ecodesign rules establish mandatory environmental performance and product-information requirements for products placed on the European Union market.
The regulatory framework now combines:
The Ecodesign for Sustainable Products Regulation—Regulation (EU) 2024/1781, commonly called the ESPR, entered into force on 18 July 2024.
Important: The ESPR is a framework regulation. It does not impose every possible ESPR requirement on every product immediately. Most new obligations become mandatory only after the European Commission adopts a product-specific or horizontal delegated act and its application date is reached.
Ecodesign means considering a product’s environmental impacts during its design and development.
Depending on the applicable regulation, ecodesign requirements may address:
Ecodesign requirements are mandatory legal requirements. They should not be confused with voluntary environmental labels or general environmental marketing claims.
The former Ecodesign Directive 2009/125/EC was commonly called the Energy-related Products or ErP Directive.
It established a framework for product-specific ecodesign measures covering energy-related products such as electronic displays, power supplies, motors, light sources, servers, household appliances and heating equipment.
The ESPR repealed Directive 2009/125/EC as the overarching framework. However, the product-specific regulations adopted under the former directive generally remain applicable until they are amended, replaced or repealed.
Legal instrument | Present role |
|---|---|
Regulation (EU) 2024/1781—the ESPR | Framework for adopting new ecodesign requirements covering a much wider range of products |
Existing product-specific ecodesign regulations | Continue to establish binding requirements for the product groups they cover |
Regulation (EU) 2017/1369 | Framework for EU energy labelling and EPREL registration |
ESPR delegated acts | Will introduce future requirements for particular product groups or across several product groups |
A company must therefore check both the new ESPR framework and any existing product-specific ecodesign legislation.
The ESPR has a considerably broader potential scope than the former ErP Directive. It can cover most physical goods placed on the EU market, including components and intermediate products.
Its scope can include:
Certain categories are excluded or treated through sector-specific legislation. These include food and feed, medicinal and veterinary medicinal products, living organisms, products of human origin and some aspects of vehicles already regulated by sector-specific EU legislation.
Being within the ESPR’s broad potential scope does not automatically mean that a product already has detailed ESPR requirements. The applicable delegated acts, implementing acts and transitional product regulations must be examined.
The usual regulatory process includes:
A delegated act may define:
Always base a compliance decision on the final legal act—not only on a working plan, proposal or draft.
The European Commission’s ESPR and Energy Labelling Working Plan 2025–2030 identifies priority product groups and horizontal measures.
Priority | Indicative adoption timing in the Working Plan |
|---|---|
Iron and steel | 2026 |
Aluminium | 2027 |
Textiles and apparel | 2027 |
Tyres | 2027 |
Furniture | 2028 |
Mattresses | 2029 |
Horizontal repairability requirements, including possible scoring | 2027 |
Recycled content and recyclability of electrical and electronic equipment | 2029 |
These dates are indicative planning dates, not automatic compliance deadlines. Each final delegated act will establish its own scope, requirements and application dates.
Companies in these sectors should nevertheless begin organizing product and supply-chain data before the requirements become applicable.
A Digital Product Passport, or DPP, is a structured digital record connected to a product through a machine-readable data carrier.
Depending on the applicable delegated act, a DPP may contain information about:
A DPP is not automatically required for every product under the ESPR. The applicable product-specific or sector-specific legislation determines:
EU rules governing the DPP registry were further developed through Implementing Regulation (EU) 2026/1778.
A DPP does not automatically replace CE marking, an EU Declaration of Conformity, technical documentation, an energy label or EPREL registration. Several of these requirements may apply to the same product.
Learn more about Digital Product Passport preparation.
The ESPR also introduces measures intended to prevent the destruction of unsold consumer products.
Since 19 July 2026, large enterprises are prohibited, subject to specified exemptions, from destroying unsold apparel, clothing accessories and footwear. The prohibition is scheduled to apply to medium-sized enterprises from 2030.
Separate disclosure requirements can require companies to report information about discarded unsold consumer products and how those products were treated.
The scope, company-size criteria, exemptions and reporting rules should be checked before making an applicability decision. See the European Commission’s guidance on unsold clothing and footwear.
Many energy-related products remain subject to product-specific regulations adopted under the former Ecodesign Directive.
The following are important examples.
Product group | Principal ecodesign measure | Examples of regulated areas |
|---|---|---|
Regulation (EU) 2019/2021 | Energy efficiency, off and standby modes, automatic power-down, repair information, material efficiency, and disassembly | |
Regulation (EU) 2019/1782, followed by Regulation (EU) 2025/2052 from 1 January 2028 | Active efficiency, no-load consumption, standby performance, markings, technical information, and interoperability | |
Regulation (EU) 2019/1781 | Motor-efficiency classes, drive losses, product information, and anti-circumvention | |
Regulation (EU) 2019/424 | Power-supply efficiency, idle-state power, active-state efficiency, firmware, secure data deletion, and component extraction | |
Regulation (EU) 2023/826 | Off-mode, standby, and networked-standby power consumption, power-management functions, and product information | |
Regulation (EU) 2019/2020 | Energy efficiency, functional requirements, flicker, standby power, markings, and information | |
Welding equipment | Regulation (EU) 2019/1784 | Energy efficiency, idle-state power, spare parts, repair information, and disassembly |
Regulation (EU) 2023/826 has applied since 9 May 2025 and replaced the former standby Regulation (EC) No 1275/2008 and simple set-top-box Regulation (EC) No 107/2009.
For external power supplies, Regulation (EU) 2019/1782 remains relevant during the transition. The updated Regulation (EU) 2025/2052 applies from 1 January 2028 and expands the regulatory coverage to additional power-supply and charging products.
This list is not exhaustive. Additional measures cover household appliances, refrigeration, heating and cooling equipment, pumps, fans, transformers, computers, smartphones, tablets and other product groups. Consult the European Commission’s energy-efficient product list when classifying a product.
These requirements are related but have different functions.
Requirement | Main purpose |
|---|---|
Ecodesign | Establishes minimum product performance and information requirements |
EU energy label | Allows customers to compare energy and other product performance |
EPREL | Registers product and compliance information for product groups subject to EU energy-labelling requirements |
Digital Product Passport | Makes specified sustainability, circularity and compliance data digitally accessible |
A product may be subject to ecodesign without requiring an energy label. Energy labels and EPREL registration apply only when a product-specific energy-labelling regulation covers the product.
For applicable product groups, the supplier normally must register the model in EPREL before placing it on the EU market and provide the required label and product information sheet.
Learn more about EPREL registration and EU energy labels.
Many product-specific ecodesign regulations use the EU CE-marking conformity framework.
Where required by the applicable measure, the manufacturer must:
For products covered by ESPR delegated acts, technical documentation and the EU Declaration of Conformity generally must be retained for ten years after the product is placed on the market or put into service, unless the applicable rules specify otherwise.
There is no single, universal EU “ecodesign certificate” that replaces this process. Laboratory reports, assessment reports and third-party certificates may support the technical file, but the manufacturer remains responsible for the product’s conformity unless the applicable legislation expressly provides otherwise.
Read more about the EU product-compliance framework and the Blue Guide.
The exact requirements depend on the applicable regulation. A typical ecodesign technical file can include:
Market-surveillance verification tolerances should not be treated as design tolerances or used to make a non-compliant product appear compliant. Products should be designed and manufactured to meet the declared and regulated values directly.
Responsibilities depend on the economic operator’s role.
Manufacturers are generally responsible for product design, conformity assessment, technical documentation, declarations, markings, and production conformity.
A company that markets a product under its own name or trademark may assume manufacturer responsibilities even when another company physically manufactured the product.
EU importers must verify that the manufacturer has completed the required conformity procedures and that the product is accompanied by the required documentation, identification and instructions.
A manufacturer may appoint an EU authorised representative to perform specific tasks under a written mandate. The manufacturer cannot transfer every design and manufacturing responsibility to that representative.
Distributors and dealers must exercise due care and verify that applicable labels, markings and required information accompany the product. Dealers also have specific display obligations for energy-labelled products.
Distance-selling rules can require prescribed product, label and performance information to be displayed before purchase. Obligations may also apply to online marketplaces under the applicable product and digital-services legislation.
Define the product’s functions, technical characteristics, intended use, power ratings, interfaces, sales channels, and customer groups.
Small differences between models can affect regulatory classification.
Map every relevant EU requirement, not only the ESPR. Depending on the product, this may include:
See our guidance on WEEE compliance, battery compliance and the EU right to repair.
Identify the legal manufacturer, importer, authorised representative, distributor and dealer for each supply chain and sales model.
For every applicable regulation, document:
Obtain reliable information about:
Supplier declarations should be supported by suitable evidence and controlled through the company’s change-management process.
Use the methods prescribed by the applicable regulation and, where appropriate, relevant harmonised standards.
Document the test configuration, samples, firmware version, environmental conditions, instruments, uncertainty and calculations.
The file should demonstrate how the product meets every applicable requirement. It should be complete before the product is placed on the EU market.
Prepare the EU Declaration of Conformity and affix the CE marking where required. Confirm that all other mandatory markings, identifiers and instructions are present.
Where applicable:
Monitor:
A compliant prototype is not enough if later production units, components, or software changes no longer match the assessed design.
A life-cycle assessment can help identify where a product creates its most significant environmental impacts.
An LCA can evaluate:
This information can support material selection, design alternatives, durability improvements, carbon-footprint calculations and future ESPR data requirements.
However, an LCA does not automatically prove legal compliance. The assessment must use the boundaries, data-quality requirements and calculation methods specified by the applicable legislation whenever regulatory values are being declared.
Learn more about life-cycle assessment and the Enviropass EcoScan life-cycle evaluation.
Enviropass can support manufacturers, importers, and product developers with:
Our approach begins with the product’s intended use, design, and supply chain. We then identify the applicable requirements, evidence gaps, and actions required before the product is placed on the EU market.
Explore our EU regulatory-monitoring services or contact Enviropass to discuss your product.
No. The ESPR establishes the legal framework. Most detailed product requirements become mandatory through product-specific or horizontal delegated acts with defined application dates.
Existing product-specific regulations can already apply during this transition.
No. Existing product-specific implementing measures generally remain applicable until they are amended, replaced or repealed.
No. A DPP is mandatory only when the applicable ESPR delegated act or another sector-specific EU law requires one for that product.
No. EPREL and the DPP have different legal functions. A product can potentially require both.
No. An energy label is required only when a product-specific energy-labelling regulation covers the product.
There is no universal EU ecodesign certificate. The applicable legislation determines the conformity procedure. Technical reports or third-party certificates may provide supporting evidence, but they do not automatically replace the manufacturer’s legal responsibilities.
They can. Applicability depends on the product definition and exclusions in the relevant regulation, not simply on whether the customer is a consumer or another business.
Yes, when the products are placed on the EU market or put into service in the EU. The manufacturer and importer must ensure that their respective legal obligations are fulfilled.
A ten-year retention period is common under EU product legislation and is specified by the ESPR for products covered by its delegated acts. Always confirm the period in the applicable product-specific legislation.
Companies should begin when their product group appears in an official working plan or preparatory study. Early preparation is particularly useful for bills of materials, supplier data, repair information, recycled content, substances of concern and environmental-footprint data.
Ecodesign compliance begins with correct product classification. Enviropass can review your product, identify the applicable EU requirements and develop a practical compliance plan.
This page provides general regulatory information and does not constitute legal advice. Product-specific legislation and its latest amendments should always be reviewed before making a compliance decision.
Written and technically reviewed by:
Aurélien “Aury” Hathout, M.Env., VEA®, CEA
Last technical review: September 2026
This page was reviewed for technical accuracy based on applicable European Union ecodesign legislation, the Ecodesign for Sustainable Products Regulation (ESPR), product-specific implementing measures, and official European Commission guidance.
This guide is based on primary and authoritative European Union regulatory sources, including: