ESPR compliance hub: the Ecodesign for Sustainable Products Regulation

The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, sets ecodesign rules product group by product group, creates the Digital Product Passport and, since 19 July 2026, bars large companies from destroying unsold clothing, clothing accessories and footwear. This hub explains what applies to you and when, with free tools for the unsold products rules: a scope checker, a disclosure form, a checklist, a timeline and two reference tables.

44
CN headings reported at 4-digit level (Annex II)
10
Derogations from the destruction ban
9
Resources available
6
Downloadable PDFs

Three obligations, one regulation

The ESPR creates three distinct requirements for economic operators. Start by working out which of them apply to your organisation, and from when.

Disclosure
An annual public report on the unsold consumer products you discard: units, weight, CN category, reasons, treatment routes, and measures taken and planned.
Article 24 · Large: now · Medium: from 19 July 2030
Destruction ban
No destroying unsold apparel, clothing accessories or footwear, except under one of 10 derogations, each with its own documentation.
Article 25 · In force since 19 July 2026
Prevention duty
Every economic operator, whatever its size, must take the measures that can reasonably be expected to avoid destroying unsold consumer products.
Article 23 · All operators · Applies now

What ESPR is and who it applies to

ESPR replaced the Ecodesign Directive (2009/125/EC), which covered only energy-related products. It applies to almost every physical product placed on the EU market, including components and intermediate products. Food, feed, medicines, living organisms and a few other categories are excluded.

It adds three things the old Directive did not have. The Commission can set binding requirements on durability, reparability, recyclability, recycled content, substances of concern and carbon and environmental footprints, one product group at a time, through delegated acts. Products in a regulated group will need a Digital Product Passport. And rules on unsold consumer products already apply, with the prevention duty covering every economic operator.

What the unsold products rules require

ESPR obligations on unsold consumer products
ObligationArticleWhoFrom
Prevention duty23All economic operators, whatever their size18 July 2024
Disclosure24Large enterprises; medium-sized enterprises from 19 July 2030First full financial year in force (FY2025 for calendar-year companies); Annex I format from 2 March 2027
Destruction ban25Large enterprises; medium-sized enterprises from 19 July 2030. Covers apparel, clothing accessories and footwear (Annex VII)19 July 2026

Disclosure. Each year, publish the number and weight of unsold consumer products you discarded, by product category; the reasons, and any derogation you relied on; the share sent to preparing for reuse, recycling, other recovery and disposal; and the measures taken and planned to prevent destruction (Article 24(1)). It covers every unsold consumer product, not only clothing. Categories follow the 2-digit CN chapter, except the 44 headings in Annex II to Implementing Regulation (EU) 2026/2, which are reported at 4-digit level. You can publish on an easily accessible page of your website, or in your CSRD sustainability statement with a link from the website.

Destruction ban. Since 19 July 2026, large enterprises may not destroy unsold apparel, clothing accessories or footwear unless one of the 10 derogations in Delegated Regulation (EU) 2026/296 applies, for example a dangerous or damaged product. Micro and small enterprises are exempt, but they must not destroy products passed to them to get around the ban (Article 25(2)), and the Commission can extend the rules to them if it finds evidence of circumvention.

Records. Keep the evidence for a derogation for five years after the product is destroyed (Delegated Regulation, Article 3), and keep delivery and reception records, including statements from waste treatment operators, for five years after each disclosure (Implementing Regulation, Article 4).

Timing in practice. A calendar-year company’s first disclosure covered FY2025. The standardised Annex I format applies from the first full financial year after 2 March 2027, so FY2028 for a calendar-year company, published within 12 months of year end.

The Digital Product Passport

The Digital Product Passport is a digital record linked to a unique product identifier and reached through a data carrier such as a QR code. The delegated act for each product group decides what goes in it (for example materials, substances of concern, durability and repair information, recycled content or carbon footprint), which data carrier to use, and whether passports are kept at model, batch or item level.

ESPR required the Commission to set up a central registry of passport identifiers by 19 July 2026. That date does not mean every product needs a passport now: passports become mandatory group by group, as each delegated act applies. If you make or import products in a priority group, structure your product data for a passport early, because much of it overlaps with what your sustainability reporting already collects.

The ESPR Working Plan 2025–2030

The Commission adopted its first ESPR and energy labelling Working Plan on 16 April 2025 (COM(2025) 187). It names the product groups that will receive ecodesign requirements first: textiles (with a focus on apparel), furniture, tyres and mattresses as final products; iron and steel and aluminium as intermediate products; and horizontal rules on repairability and on the recycled content and recyclability of electrical and electronic equipment. It also carries over 16 energy-related products from the previous plan, such as household dishwashers, displays and EV chargers.

Indicative adoption dates include 2027 for textiles and tyres and 2029 for mattresses. Product-specific requirements bind only once each delegated act is adopted and applies, which is why this page carries a review date.

Compliance timeline at a glance

18 Jul 2024
ESPR enters into force. Prevention duty applies; large companies’ first disclosure covers the first full financial year in force (FY2025 for calendar-year companies).
In force
19 Jul 2026
Destruction ban in force for large enterprises since 19 July 2026.
In force
2 Mar 2027
Standardised Annex I format applies (Implementing Regulation (EU) 2026/2).
Upcoming
19 Jul 2030
Disclosure and the destruction ban extend to medium-sized enterprises.
Future

Penalties and enforcement

ESPR leaves penalties to the Member States. They must be effective, proportionate and dissuasive, and must take account of the nature, gravity and duration of an infringement, whether it was intentional and any economic benefit gained (Article 74). Amounts and procedures therefore differ by country, so check the rules in each market where you sell.

National authorities check disclosures on a risk basis (Annex III to the Implementing Regulation). They look, for example, at missing or unusually low figures, a high share of unknown treatment routes and a company’s past record, and they compare disclosed figures with delivery documents: a difference of less than 10% counts as compliant.

ESPR and circular economy reporting

Last reviewed 1 October 2026 against Regulation (EU) 2024/1781, Delegated Regulation (EU) 2026/296, Implementing Regulation (EU) 2026/2 and COM(2025) 187 on EUR-Lex.

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Frequently asked questions

What is the ESPR?

When did ESPR come into force?

Which companies are subject to the ESPR destruction ban?

Does the disclosure obligation cover more than just clothing?

What do companies have to disclose about unsold products?

What is the Digital Product Passport?

What is the ESPR Working Plan?

What are the penalties for breaching ESPR?

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Who should use these resources?

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