# ESPR Compliance Navigator - Verified Fact Set & Sources

> Companion reference for `SKILL.md`. Compiled and web-verified as of mid-2026 (June 2026). Items marked `// VERIFY` or [INDICATIVE] are not finally adopted or may have moved; confirm against EUR-Lex / European Commission before relying on them.

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## 1. The regulation

| Fact | Value | Source |
|---|---|---|
| Official name | Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products | EUR-Lex |
| Adopted | 13 June 2024 | EUR-Lex |
| Published in OJ | 28 June 2024 | EUR-Lex |
| In force | 18 July 2024 (20 days after publication) | EUR-Lex |
| Repeals | Ecodesign Directive 2009/125/EC (energy-related products only) | EUR-Lex summary |
| Also amends | Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 (Batteries) | EUR-Lex |
| Nature | Framework regulation - binding product rules arrive via Commission delegated acts over time | EUR-Lex summary |

Directive vs Regulation: the old 2009/125/EC was a *directive* (transposed nationally, energy products only). ESPR is a *regulation* - directly applicable in all 27 member states, no transposition, covering nearly all physical goods.

## 2. Scope

- Covered: any physical good placed on the EU market or put into service, including components and intermediate products.
- Exempt (Article 1(2)): food; feed; medicinal products; veterinary medicinal products; living plants, animals and micro-organisms; products of human origin; products of plants/animals relating directly to future reproduction; certain vehicle aspects already covered by sector vehicle legislation.
- Works by "product group" (functionally similar products regulated by one delegated act). Requirements may be product-specific or horizontal (cut across groups).

Obligated economic operators:
- Manufacturers (including non-EU manufacturers placing on the EU market) - primary burden.
- Importers - verify manufacturer compliance before placing on market; liable as manufacturer if they place non-compliant goods.
- Distributors/retailers - act with due care; must not supply goods known/suspected non-compliant.
- Authorised representatives, fulfilment service providers and online marketplaces are also drawn in.

## 3. Ecodesign requirements (types only; thresholds set per delegated act)

Performance requirements: durability/reliability; reusability, upgradability, reparability; substances of concern; energy and resource efficiency; recycled content; recyclability and ease of remanufacturing; carbon and environmental footprint; waste generation.

Information requirements: data accompanying the product, often via the DPP - composition, substances of concern, use/repair/disposal instructions, environmental performance, reparability/durability scores where defined.

`// VERIFY` Exact numeric thresholds for any product do not exist until that product's delegated act is adopted.

## 4. Digital Product Passport (DPP)

- Definition: structured, machine-readable product data set reached via a data carrier linked to a unique product identifier, carrying sustainability/circularity/value-retention data.
- Data carrier: QR code, GS1 DataMatrix, RFID tag or NFC chip on product/packaging/documentation.
- Differentiated ("need-to-know") access for consumers, repairers, recyclers/waste operators, market-surveillance and customs authorities.
- Decentralised data model - no single EU mega-database; data stays with operators/solution providers.
- Central EU registry of data carriers and unique identifiers; the Commission must set this up before 19 July 2026.
- Identifiers at three levels: unique product identifier, unique operator identifier, unique facility identifier.
- Granularity can be model-, batch- or item-level.
- `// VERIFY` Standards via CEN-CENELEC JTC 24 (EN 18000-series, e.g. EN 18222/EN 18223 for APIs/interoperability); final EN publication expected ~2026 - designations/dates still moving.
- EU support projects: CIRPASS (concept, 2022-2023); CIRPASS-2 (EUR 12.5m, Digital Europe Programme, May 2024-April 2027, 13 pilots across textiles, electronics, tyres, construction).

## 5. Working Plan & indicative timing

- First ESPR Working Plan 2025-2030 adopted 16 April 2025 (Commission Communication). Mid-term review expected ~2028.
- Priority product groups: textiles (esp. apparel), furniture, mattresses, tyres, iron & steel, aluminium, plus horizontal measures (repairability score framework; recyclability/recycled content, esp. for EEE).

[INDICATIVE - not binding; confirm against latest Working Plan and any adopted act]

| Product group | Indicative delegated-act adoption |
|---|---|
| Iron & steel | ~2026 (first) |
| Textiles (apparel) | ~2027 |
| Tyres | ~2027 |
| Aluminium | ~2027 |
| Furniture, mattresses | later in 2025-2030 window |
| Footwear | slower track; exploratory study; requirements likely ~2030+ |

- Typical ~18-month application lag after a delegated act's entry into force (exact lag set per act). So mandatory textiles DPP compliance is realistically ~2028; iron & steel DPP ~2027-2028. [INDICATIVE]
- Textiles are the most-cited first ESPR consumer DPP.

## 6. Unsold-goods destruction ban & disclosure (CONFIRMED, near-term)

On 9 February 2026 the Commission adopted two secondary acts:
- Delegated Regulation (cited C(2026) 659) - the "Derogation Regulation" setting the defined cases where destruction is allowed (reported as 10 derogations; e.g. health/safety, severe damage, returns unfit for reuse). `// VERIFY` exact derogation list and the record-retention period (commonly cited as 5 years) against the adopted text.
- Implementing Act - the "Disclosures Implementing Act" setting the standardised disclosure format (Annex).

Ban on destroying unsold apparel, clothing accessories and footwear:
- Large companies: from 19 July 2026.
- Medium companies: from 19 July 2030.
- Micro and small enterprises: exempt (Commission may revisit if circumvention shown).

Disclosure:
- Annual, standardised disclosure of volumes of unsold consumer products discarded and the reasons.
- Already in force for large companies; extends to medium companies in 2030.
- CSRD reporters may include it within the sustainability report if they use the standard Annex format and link it on the company website. `// VERIFY`

## 7. Obligations & penalties

- Manufacturers: ensure conformity, compile technical documentation, draw up the EU Declaration of Conformity, affix CE marking, create/maintain the DPP once required.
- Importers: verify manufacturer compliance/documentation before placing on market; liable as manufacturer for non-compliant goods.
- Distributors: due care; do not make available goods known/suspected non-compliant.
- Penalties set by member states - "effective, proportionate and dissuasive"; ESPR fixes no EU-wide fine.
- Market surveillance can order recalls, withdrawal and sales prohibitions; a prohibition can lock a product out of all 27 member states.

## 8. Interactions with other EU rules

- Battery Regulation (EU) 2023/1542: carries the Battery Passport - the first live DPP - mandatory from 18 February 2027 for EV, LMT and industrial batteries > 2 kWh. De-facto template for ESPR DPPs.
- Construction Products Regulation (recast (EU) 2024/3110): construction products largely governed by CPR (own DPP-style provisions) rather than ESPR.
- CSRD: entity-level reporting; ESPR/DPP is product-level data; they increasingly share underlying life-cycle data.
- EUDR (Regulation (EU) 2023/1115): separate deforestation due-diligence regime; overlaps on supply-chain data for wood furniture and rubber tyres; complementary, not merged.

## 9. Open / still-in-flux items (flag in output)

- All product-specific delegated acts (textiles, iron & steel, tyres, aluminium, furniture, mattresses) are not yet adopted; dates are indicative Working-Plan estimates. [INDICATIVE]
- DPP standards (CEN-CENELEC JTC 24, EN 18000-series): designations and publication dates still moving; expected ~2026. `// VERIFY`
- Destruction-ban derogation list, record-retention period and disclosure-format specifics: from the 9 Feb 2026 secondary acts; confirm exact details against the adopted OJ text. `// VERIFY`
- The ~18-month application lag after a delegated act is a general expectation; exact lag set per act. [INDICATIVE]

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## Source URLs (official first)

Official / EU institutional:
- EUR-Lex - Regulation (EU) 2024/1781 (full text): https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng
- EUR-Lex - official summary of ESPR: https://eur-lex.europa.eu/EN/legal-content/summary/ecodesign-requirements-for-sustainable-products.html
- European Commission (Green Forum) - 2025-2030 Working Plan: https://green-forum.ec.europa.eu/news/2025-2030-working-plan-2025-07-11_en
- European Commission (Environment) - new rules to stop destruction of unsold clothes and shoes (9 Feb 2026): https://environment.ec.europa.eu/news/new-eu-rules-stop-destruction-unsold-clothes-and-shoes-2026-02-09_en
- European Commission - who does what under ecodesign: https://energy-efficient-products.ec.europa.eu/ecodesign-and-energy-label/legislative-framework/who-does-what-under-ecodesign_en
- European Commission - PEF / environmental footprint method: https://green-forum.ec.europa.eu/green-business/environmental-footprint-methods/pef-method_en
- JRC DPP data-requirements methodology (JRC145830): https://publications.jrc.ec.europa.eu/repository/handle/JRC145830
- CEN-CENELEC (DPP standards / JTC 24): https://www.cencenelec.eu/
- EU Battery Regulation (EU) 2023/1542: https://eur-lex.europa.eu/eli/reg/2023/1542/oj

DPP projects:
- CIRPASS: https://cirpassproject.eu/
- CIRPASS-2: https://cirpass2.eu/

Secondary / explanatory (for the 9 Feb 2026 destruction-ban acts; corroboration only):
- Baker McKenzie - Commission adopts new ESPR measures (Feb 2026): https://www.bakermckenzie.com/en/insight/publications/2026/02/european-union-european-commission-adopts-new-espr-measures
- Linklaters Sustainable Futures - final acts on unsold consumer product destruction and disclosure: https://sustainablefutures.linklaters.com/post/102miiy/eu-espr-commission-adopts-final-acts-on-unsold-consumer-product-destruction-and
- Anthesis - the ban on destruction of unsold goods: https://www.anthesisgroup.com/insights/espr-the-ban-on-destruction-of-unsold-goods/