Guide to Ecodesign for Sustainable Products Regulation (ESPR)

What is the Ecodesign for Sustainable Products Regulation?

The Ecodesign for Sustainable Products Regulation (ESPR) is an EU regulation that aims to make sustainable products the norm, improving the existing Ecodesign framework (2009/125/EC) to include a broader range of products with stricter sustainability criteria. This article will provide an in-depth look at the new ESPR rules, their implications, and how manufacturers, product design managers, engineers, and sustainability professionals can adapt to these changes.

ESPR & the European Green Deal

Expanding the scope of Ecodesign — construction products in focus

The Ecodesign for Sustainable Products Regulation (ESPR) expands the scope of the existing Ecodesign Directive, which primarily focuses on energy-related products. The new regulation subjects a broader range of products, including electronics, construction materials, and textiles, to stringent sustainability requirements. This approach aims to mitigate the environmental impact of products throughout their lifecycle, from production to disposal.

Buildings are significant contributors to environmental degradation, accounting for approximately 50% of resource extraction and consumption, and generating over 30% of the EU's annual waste. They are also responsible for 40% of the EU's energy consumption and 36% of energy-related greenhouse gas emissions. However, the construction sector remains vital to the EU economy, contributing nearly 10% of the EU's value-added and providing jobs for about 25 million people. The construction products industry alone includes 430,000 companies within the EU.

To achieve the EU’s ambitious carbon reduction targets, it is crucial to enforce sustainability regulations in the construction industry. Consequently, the ESPR emphasizes the need for construction products and materials to be durable, repairable, and recyclable. This focus ensures that the industry not only reduces its environmental footprint but also supports the circular economy.

Key features of the ESPR

1. Stricter sustainability criteria

The ESPR introduces more stringent requirements for product durability, repairability, and recyclability. Manufacturers will need to ensure that products are designed to last longer, can be easily repaired, and are easier to recycle at the end of their lifecycle. This shift aims to reduce waste and promote a circular economy.

The directive also bans the destruction of unsold products to ensure manufacturers improve product longevity.

2. Product transparency — Digital Product Passports

One of the most notable features of the ESPR is the introduction of Digital Product Passports (DPPs). These digital records, in the form of a “scannable tag”, will contain detailed information about a product's materials, components, and sustainability attributes. This transparency will enable consumers and businesses to make informed choices and facilitate better resource management across the supply chain.

Digital product passports will consist of a declaration of performance (DoP), providing comprehensive details on construction products, encompassing its performance characteristics, safety specifications, and environmental footprint. This aims to eliminate information silos and empowers stakeholders across the entire value chain, from architects and engineers to contractors and building inspectors.

In the context of the ESPR, the digital product passport (DPP) is introduced as a tool to provide easy access to digital information on a product's sustainability, circularity, and compliance. The The European Commission intends to adopt a delegated act laying down rules on the operation of DPP service providers near the end of 2025.

3. Enforcing consumer information

The regulation mandates that manufacturers provide clear and accessible information about the sustainability features of their products. This includes details on energy efficiency, material composition, and recycling instructions. Market surveillance authorities will have the power to remove non-compliant products from online platforms.

To prevent sidestepping, the ESPR will ban products with built-in mechanisms that detect testing conditions and alter their performance accordingly. This will ensure that products are evaluated based on their actual environmental impact rather than their ability to deceive testing procedures.

4. Harmonized standards

The ESPR aims to harmonize sustainability standards across the EU, such as the European Green Deal and the Circular Economy Action Plan, creating a level playing field for manufacturers. This standardization will simplify compliance and reduce administrative burdens, fostering innovation and competition in the market for sustainable products.

The Ecodesign Directive enforced environmental standards through specific "implementing acts" for each product group. These acts now fall under the new Ecodesign for Sustainable Products Regulation (ESPR), which will introduce tailored sustainability rules based on scientific evidence and stakeholder input. The Commission will issue multiannual plans, starting with high-impact products to ensure clarity and preparation time. 

How does the ESPR affect construction manufacturers & product designers

Manufacturers and product designers will face several new challenges and opportunities under the ESPR. Compliance with the stricter sustainability criteria will require significant changes in product design and manufacturing processes. Here are some key considerations:

• Design for longevity and repairability

Products must be designed to withstand longer use and be easily repairable. This may involve using more durable materials, modular designs that allow for easy part replacement, and providing access to repair manuals and spare parts.

• Material transparency and traceability

Manufacturers will need to ensure full transparency about the materials used in their products. The DPPs and EPDs will play a crucial role in this, requiring accurate and comprehensive data collection and reporting. 

• Recycling and end-of-life management

Designing products for recyclability will become a priority. This includes selecting materials that can be easily separated and recycled and designing products in a way that facilitates disassembly. Manufacturers may also need to participate in take-back programs and other end-of-life management initiatives.

• Building supplier partnerships

Effective collaboration with suppliers is essential for meeting the ESPR requirements. Sustainability product managers should work closely with suppliers to ensure transparency and traceability of materials and components. 

• Leveraging digital tools and data

Leveraging digital tools and data analytics will be essential for managing compliance with the ESPR. Implementing systems for data collection, life-cycle assessment, and reporting can streamline the process and ensure accurate information for EPDs and DPPs. 

What types and sizes of companies will be affected by the ESPR?

Companies in the construction sector, given its significant environmental impact, are a priority for early delegated acts, indicating that both large manufacturers and SMEs in this space will need to prepare. The regulation aims to harmonize environmental accountability while ensuring compliance costs remain proportional to the benefits, fostering a fair transition for all stakeholders.

Implementation schedule & product groups for ESPR

The implementation of the ESPR will unfold in phases. The delegated acts, starting in Q2 2025, will progressively introduce ecodesign requirements for specific product groups. The groups expected to be tackled first based on recommendations from the European Commission's Joint Research Centre (JRC) are:

• Intermediate products: Iron and steel, commodity chemicals, non-ferrous and non-aluminium metals, aluminium, plastics and polymers, pulp and paper, and glass
• Final products: Textiles and footwear, furniture, tyres, bed mattresses, detergents, paints and varnishes, lubricants, cosmetics, toys, fishing gear, and absorbent hygiene products.

The European Commission will publish a working plan, outlining the priority product categories, timelines, and milestones for compliance. This phased approach allows companies time to adjust, but proactive preparation is essential to stay ahead of the requirements.

European Green Deal & Ecodesign for Sustainable Products Regulation (ESPR) – background 

ESPR is part of the European Green Deal, a comprehensive strategy to transform the European Union into a sustainable and resource-efficient economy by 2050. The ESPR is a key component of the Green Deal's Circular Economy Action Plan, which aims to reduce waste and promote product reuse, repair, and recycling.

The ESPR, which replaces the previous draft regulation, the Ecodesign Directive, will set sustainability requirements for a wide range of products. It focuses on reducing environmental footprint, promoting reusability, repairability, energy and resource efficiency, and ensuring compliance with chemical usage regulations.

How to comply with ESPR & deliver sustainable products

The Ecodesign for Sustainable Products Regulation (ESPR) 2024 represents a significant shift towards a more sustainable future in the European Union. For construction manufacturers and sustainability product managers, adapting to these new regulations will require coordinated efforts and strategic planning. 

Conducting life-cycle assessments (LCAs) for construction products is a great way to measure and report a product’s sustainability data. You can get your product ready to comply with the new ESPR by leveraging digital tools that align with global standards and regulations. One Click LCA, a leading sustainability software which offers a unique global database with +250,000 LCA datasets and supports +80 standards and certifications, is a powerful tool for manufacturers. With One Click LCA’s EPD Generator tools, you can conduct LCA and create product-specific EPDs.

Will EN 15804+A2 standard EPDs be compatible with DPP?

The EN 15804+A2 standard forms the basis for most Environmental Product Declarations (EPDs) across the EU, and it is expected to play a central role in the Digital Product Passport (DPP) under the Ecodesign for Sustainable Products Regulation (ESPR). However, as of now, there is no explicit confirmation from the EU that all EN 15804+A2-compliant EPDs will automatically meet DPP requirements.

The ESPR emphasizes harmonization and alignment with existing standards to ensure consistency across EU member states. This suggests that EN 15804+A2-compliant EPDs, being widely recognized as a baseline, are likely to be compatible with the DPP framework. However, challenges may arise due to national variations. For example, in France, FDES (Fiches de Déclaration Environnementale et Sanitaire) are EPDs aligned with EN 15804+A2 but include additional requirements specific to the French market. How such adaptations will be addressed remains to be clarified in the forthcoming delegated acts under the ESPR.

The delegated acts, expected from Q2 2025, will define the technical requirements for DPPs and address potential compatibility issues, including how national variations like FDES align with EU-wide standards. Until then, manufacturers and stakeholders should anticipate potential adjustments to ensure their EPDs meet both current EN 15804+A2 standards and future DPP requirements.

To stay compliant and prepared, it is recommended to monitor updates from the European Commission, particularly regarding the delegated acts and guidance from relevant standardization bodies such as CEN/TC 350.