Beyond a simple legislative framework, the ESPR marks a strategic milestone. It makes mandatory principles already at the heart of circular economy approaches, such as eco-design, repairability, and reducing environmental footprint throughout a product's life cycle.
What you should remember:
- The ESPR regulation was adopted in April 2024 and will apply gradually starting in 2026.
- It extends eco-design to most consumer and industrial goods, beyond just energy-related products.
- Its main obligations: durability, repairability, reuse, limiting harmful substances, and transparency via the Digital Product Passport.
- The most affected sectors: textiles, electronics, furniture, batteries, and construction.
- The ESPR isn't just a constraint: it's an opportunity to reinvent your business models (second-hand, rental, refurbishment) and strengthen your resilience.
- To prepare, you can already: map your flows, start eco-design, anticipate DPPs, and train your teams.
ESPR, what is it?
The ESPR regulation (Ecodesign for Sustainable Products Regulation) was adopted by the European Parliament on April 25, 2024. It builds on the European Green Deal and aims to deeply transform how products are designed, manufactured, used, and treated at end of life.
Concretely, this means that product design can no longer be limited to performance or cost criteria. Companies will now have to integrate requirements around:
- Durability - Products will need to be designed to last longer, with warranties and spare parts available.
- Repairability - Manufacturers will need to make disassembly and access to components easier, to enable quick, affordable repairs.
- Reuse & repurposing - Products will need to be designed for multiple lives, for example by integrating second-hand or refurbishment models.
- Recyclability - From the design stage, materials will need to be chosen and assembled so they can be effectively separated and recycled.
- Resource sobriety - Limiting hazardous substances, reducing the use of critical resources (such as certain rare earths), and factoring in carbon footprint from the design phase onward.
The ESPR thus replaces the former eco-design directive (2009/125/EC), which only applied to energy-related products (lamps, boilers, household appliances...).
In other words, where eco-design was previously a voluntary approach or limited to certain sectors, it's now becoming a cross-cutting obligation for the entire European economy.
Why is this regulation necessary?
The figures speak for themselves: each European citizen consumes an average of 14.5 tonnes of raw materials per year, and the European Union generates more than 2.2 billion tonnes of waste every year.
These colossal volumes place direct pressure on natural resources, ecosystems, and the stability of supply chains. The ESPR thus addresses a twofold emergency:
- Ecological - Reducing resource extraction and waste.
- Economic & strategic - Reducing Europe's dependence on critical raw materials.
A key step toward the circular economy
Beyond regulatory compliance, the ESPR embodies a paradigm shift. It makes mandatory principles already tested in the circular economy: product eco-design, repairability and reuse, extended lifespans, and reduced carbon and environmental footprint across the entire life cycle.
In this sense, the ESPR isn't an additional constraint, but a lever for innovation and competitiveness. Companies are invited to move from theory to practice to create more sustainable, resilient products.
Which products are affected?
With the ESPR, the European Union takes a decisive step. Indeed, this regulation no longer targets only energy-related products, as was the case with the former 2009 directive. Most consumer and industrial products are now affected, with obligations around durability, repairability, and transparency.
The sectors directly affected
Several industries are in the regulation's crosshairs, as they account for a significant share of environmental impacts. These notably include:
- Textiles and clothing - Clothes, shoes, and accessories will need to include more recycled fibers, be designed to last, and be repairable.
- Electronics and digital - Smartphones, computers, tablets, or household appliances will need to offer accessible spare parts, replaceable batteries, and a design that facilitates software updates. For example, a laptop placed on the European market will need to allow easy replacement of its battery or hard drive, include a share of recycled materials, and come with a digital product passport detailing its carbon footprint and composition.
- Furniture - Furniture will need to be designed to be disassembled and reused, with greater use of recycled materials.
- Batteries and electrical equipment - Among the first sectors to implement the digital product passport, they'll need to display the composition, carbon footprint, and traceability of critical materials.
- Construction materials and products - This particularly energy-intensive sector accounts for nearly 50% of resources extracted in Europe, according to the European Commission. Players in this sector will need to reduce their dependence on virgin raw materials and promote reuse.
Products excluded from the scope
Some products remain outside the ESPR's scope, as they're already covered by other European regulations:
- Food and agricultural products, governed by health standards.
- Motor vehicles, already subject to emissions and energy performance directives.
- Pharmaceutical products and medical devices, covered by specific public health regulations.
The main obligations for businesses
With the ESPR, your responsibilities are evolving: it's no longer just about declaring CSR commitments, but integrating them directly into your products' design.
These obligations shouldn't be seen only as constraints. They represent an opportunity to rethink your business models, gain competitiveness, and align your practices with the expectations of your customers and partners.
Here are the four main obligations you need to anticipate.
Integrating eco-design from the design phase
You'll now need to design your products to last longer and consume fewer resources. For example, if you're in the furniture business, a table will need to be designed so it can be easily disassembled to replace a part without discarding the whole piece. In practice, this means working upstream with your design, procurement, and R&D teams to review your material choices and assembly methods.
Facilitating repair and reuse
The ESPR requires that spare parts be available for several years, accessible, and reasonably priced. If you're a household appliance manufacturer, you'll need to provide clear repair manuals and guarantee the availability of essential parts (motors, filters, seals).
As a product manager, you'll need to integrate repairability as a performance criterion, on par with price or efficiency.
Reducing the use of harmful substances and critical resources
You'll need to limit the use of hazardous substances and reduce dependence on certain critical resources, such as rare earths. The electronics sector will need to identify the critical materials used and look for alternatives or recycling loops.
Strengthening transparency and traceability
Every product will need to come with reliable information about its composition, repairability, and environmental footprint, notably through the digital product passport. Take the example of a laptop. It will need to indicate its carbon footprint, the share of recycled materials it includes, and its repairability index.
For you, this means putting in place much more detailed product data management, and working closely with your IT, compliance, and marketing teams.
The central role of Digital Product Passports (DPPs)
DPP & ESPR: two complementary environmental regulations
The Digital Product Passport (DPP) is the ESPR's key tool. It's what will make durability and circularity requirements measurable and verifiable. Accessible via a QR code or a chip, it will gather essential information on a product's composition, carbon footprint, repairability, and recyclability.
In other words, the DPP is the link between regulation and practical implementation. It brings the transparency needed to track a product throughout its life cycle and facilitate its reuse or recycling.
If you'd like to dig deeper into this topic and prepare for its rollout, Circulab Academy offers a short training dedicated to Digital Product Passports.
What concrete impacts for businesses?
The ESPR will deeply transform how you design and manage your products. Its impacts will be felt at several levels.
A shift in product design
You won't be able to launch a product anymore without integrating its durability from the design phase. This means choosing recycled or recyclable materials, making disassembly easier, and planning for available spare parts. For example, a furniture manufacturer will need to offer assembly systems that let a damaged part be easily replaced instead of discarding the whole product.
Increased pressure on the supply chain
Your suppliers will now be at the heart of the compliance process. You'll need to guarantee the traceability and transparency of the materials used. If you work in the textile industry, you'll need to be able to prove the origin of fibers and their environmental impact through the future digital product passport.
A new transparency requirement toward your customers
Consumers will have access to much more information: carbon footprint, repairability, share of recycled materials, availability period for parts. This level of detail will become a purchasing criterion.
An evolution of business models
The ESPR isn't limited to improving existing products. It encourages companies to reinvent their business model. By making repair, reuse, and refurbishment unavoidable, it becomes much harder to rely solely on a model based on selling new products. New levers are thus emerging, such as refurbishment, second-hand, rental, or subscription.
In practice, the ESPR is becoming a catalyst for transition. It forces companies to move away from the linear model toward more resilient models compatible with planetary boundaries.
How to prepare starting today?
The ESPR will come into force gradually starting in 2026. Waiting until the last minute would be risky. Not only would you expose your company to sanctions, but you'd also lose the opportunity to differentiate yourself. In this section, we offer a few levers you can activate starting today.
Map your flows and dependencies
Start by analyzing your value chain: what resources do you consume? What waste or value losses do you generate? Where are your critical dependencies (raw materials, suppliers, energy)?
Our Value Chain Canvas tool is particularly well suited to visualizing your flows and identifying risk areas or improvement opportunities.
Start an eco-design approach
Don't wait for regulation to force your hand. Integrate eco-design into your projects starting today. Among other things, you can start by using the Circular Canvas. This tool helps you rethink your products, services, and business models by integrating circular loops (reuse, repair, recycling).
Anticipate Digital Product Passports
Even though only certain sectors will be affected starting in 2026 (batteries, textiles, electronics), it's essential to start preparing your information systems to be able to collect and share product data.
Circulab Academy offers a short training dedicated to Digital Product Passports, designed to help you understand the challenges, the data to integrate, and the available technologies.
Train and mobilize your teams
The success of this transformation doesn't depend on a single department, but on all your teams: design, procurement, production, marketing, compliance.
Our « Discover Circular Economy Regulations » or « Starting an Eco-Design Approach » courses are designed to give you a solid foundation and immediately applicable tools.
Build your circular economy roadmap
The ESPR can be integrated into a broader circularity and resilience strategy. It's an opportunity to define your priorities: which products to target first? Which new models to test? Which stakeholders to involve?
The Circular Design method developed by Circulab lets you build this roadmap in a systemic, collaborative way.
In short
The ESPR marks a major turning point. Indeed, it's no longer just about reducing the impact of products, but about deeply transforming our models toward greater sustainability and circularity.
For you, it's both an obligation and a strategic opportunity: to innovate, gain competitiveness, and strengthen your resilience in the face of resource crises. The more you anticipate, the more you'll turn this regulation into a lasting lever for differentiation.