ESPR: the Ecodesign for Sustainable Products Regulation and your data

What does ESPR require?

ESPR lets the Commission set binding sustainability and information requirements for almost any physical product, one product group at a time. Each requirement reaches product data, because compliance must be documented, declared and often published. The product data compliance pillar shows how ESPR fits with PPWR, GPSR and the other rules.

Regulation (EU) 2024/1781 entered into force on 18 July 2024 and replaces the Ecodesign Directive 2009/125/EC, which keeps operating under a transition regime until 2030. ESPR works as a framework: it sets the menu of possible requirements, and delegated acts pick from that menu per product group.

ESPR requirements fall into three groups:

1. Performance requirements, such as durability, repairability, recycled content, energy and resource use, and substances of concern.
2. Information requirements, including the Digital Product Passport and labels.
3. Rules on unsold products, with a destruction ban for apparel and footwear and a disclosure duty for discarded unsold consumer products.

For product data teams, the second group drives the work. Each delegated act will define attributes, units, measurement methods and audiences. The PIM has to hold them with evidence.

Which product data does ESPR require?

ESPR attributes depend on the delegated act, but the regulation's menu shows which attribute families to prepare. The table lists them with typical units and sources.

Two practices make delegated acts cheaper to absorb. First, store measured values separately from marketing values, with test method and evidence. Second, collect substance and composition data from suppliers in structured form now. In PIMvendors engagements, these values rarely sit in ERP.

Which products does ESPR cover first, and when?

Textiles, furniture, tyres, mattresses, iron and steel, aluminium and energy-related products are the priority groups in the first working plan, adopted on 16 April 2025. Only the unsold goods rules have fixed dates; delegated act dates are indicative.

1. 18 July 2024
   ESPR enters into force

   Regulation (EU) 2024/1781 entered into force; the Ecodesign Directive 2009/125/EC transition regime runs until 2030.

   Fixed Source

2. 16 April 2025
   First ESPR working plan

   Priority groups: textiles, furniture, tyres, mattresses, iron and steel, aluminium, energy-related products, plus repairability scoring and EEE recyclability.

   Fixed Source

3. 9 February 2026
   Unsold goods acts adopted

   Delegated act on derogations from the destruction ban and implementing act on the disclosure format adopted.

   Fixed Source

4. 19 July 2026
   Destruction ban, large companies

   Large companies may no longer destroy unsold apparel, clothing accessories and footwear, except under the adopted derogations.

   Fixed Source

5. 31 December 2026
   Iron and steel delegated act

   Commission timeline lists adoption of the iron and steel delegated act in Q4 2026.

   Expected Source

6. 1 February 2027
   Unsold goods disclosure format

   The standardised disclosure format for discarded unsold products applies from February 2027.

   Expected Source

7. 31 December 2027
   Textiles, tyres, aluminium acts

   Commission timeline lists delegated acts for textiles, tyres and aluminium in Q3 to Q4 2027, applying at least 18 months after adoption.

   Expected Source

8. 31 December 2028
   Furniture delegated act

   Commission timeline lists the furniture delegated act for 2028.

   Expected Source

9. 19 July 2030
   Destruction ban, medium companies

   The Commission states medium-sized companies follow in 2030; the exact day comes from Article 25 of the regulation.

   Expected Source

The Commission's DPP timeline lists iron and steel for the fourth quarter of 2026. Textiles, tyres and aluminium follow in the third or fourth quarter of 2027, furniture in 2028. Mattresses and recycled content measures are listed for 2029 and energy-related products between 2026 and 2029.

The working plan also includes two horizontal measures: a repairability score and recyclability requirements for electrical and electronic equipment. Horizontal measures cut across product groups, so electronics companies should plan for them even outside a specific delegated act.

Operators get at least 18 months between adoption of a delegated act and application. That window is short for a data model change that needs supplier input.

What do the unsold goods rules mean for product data?

The unsold goods rules mostly affect ERP and warehouse data, while the PIM supplies the product classification. Large companies may not destroy unsold apparel, clothing accessories and footwear from 19 July 2026. Medium-sized companies follow in 2030, and small and micro-businesses are exempt.

The delegated act adopted on 9 February 2026 allows destruction only in specific cases, such as unsafe, damaged or counterfeit items, or items rejected by donation schemes. Companies relying on a derogation must keep proof for five years.

Large companies must also disclose discarded unsold consumer products each year. The implementing act on the disclosure format applies from February 2027 and reuses customs and logistics codes.

For the PIM, this means two things:

• Product classification must map cleanly to apparel, accessories and footwear categories and to customs codes.
• Product records should carry the attributes that support resale, donation or repair, such as condition grading and repair information.

The fashion and apparel industry page covers the wider data model for these products.

How should a PIM selection prepare for ESPR?

Prepare for ESPR by designing an extensible, evidence-based data model, then testing whether each vendor can extend it without custom code. The delegated acts are not yet known in detail, so flexibility is the requirement.

1. Map your assortment to the working plan groups and record the expected delegated act dates.
2. Define an attribute group per regulation with owner, unit and evidence link.
3. Require supplier templates for composition and substances of concern.
4. Ask each vendor to add a new attribute group with validation and publish it to a test channel, live in the demo.
5. Test how the PIM feeds a Digital Product Passport, using the DPP page as the reference.

PIMvendors' scenario method scores step 4 on time, configuration effort and audit trail. The data model design page explains how to structure attribute groups before selection.