How will the EU ESPR & DPP impact consumer product markets

Consumer CompactConsumer Goods and RetailJuly 03, 2025

The European Union (EU) is reshaping the future of consumer goods markets through new sustainability-focused regulations aimed at enhancing transparency and circularity. At the heart of this transformation are the Ecodesign for Sustainable Products Regulation (ESPR) and the digital product passport (DPP), which are set to impact the way products are designed, produced and evaluated across Europe.¹

Background

The ESPR is a cornerstone legislative initiative of the EU, forming part of the European Green Deal and the Circular Economy Action Plan.² It reflects the EU’s broader commitment to achieving climate neutrality by 2050 and building a more resource-efficient, circular economy.

The ESPR aims to significantly improve the environmental sustainability of products placed on the EU market by:

Reducing carbon and environmental footprints across the entire life cycle – from raw material extraction to end-of-life disposal or recycling
Improving energy and resource efficiency
Promoting the free movement and competitiveness of sustainable products within the internal market

The ESPR replaces and expands the Energy-related Products Directive (ErP Directive 2009/12/EC), broadening its scope beyond energy-related products to include nearly all physical goods. Exemptions include food, animal feed, pharmaceuticals and living organisms.

Key features:

Ecodesign requirements – sets minimum sustainability requirements for durability, repairability, reusability, recyclability and energy/resource use
Ban on destroying unsold goods – especially relevant to sectors such as textiles and electronics, this will reduce unnecessary waste and encourage surplus management strategies
Green public procurement (GPP) – public authorities will be encouraged to prioritize sustainable products, leveraging their purchasing power to drive market change
Digital product passport (DPP) – a standardized digital record that accompanies an individual product throughout its lifecycle

What is the Digital Product Passport?

The DPP is a forthcoming initiative within the EU aimed at enhancing sustainability and circularity across product lifecycles. It is envisioned that every consumer product sold in the EU will be accompanied by a DPP, which will collect, store and share detailed sustainability-related data from production to end-of-life. By improving transparency, traceability and resource efficiency, the DPP will empower consumers, businesses and regulators to make more informed and sustainable decisions.

The DPP will employ standardized and structured data formats to ensure consistency and interoperability across industries and digital systems. It will be continuously updated throughout the product’s lifecycle, meaning information will remain current as the product is manufactured, repaired, upgraded or recycled. Role-based access controls will be implemented to ensure that different stakeholders, such as consumers, recyclers and regulators, can access information relevant to their needs without compromising data protection, and all data must be retained for at least the product’s expected lifetime, ensuring that critical sustainability and compliance information remains accessible when needed.

Per Articles 9-12, Annex III of the ESPR, the DPP will include the following core information:

Composition and presence of substances of concern (SoC)
Energy and water use and efficiency performance
Durability, repairability, upgradability, recyclability
Lifecycle carbon footprint and environmental footprint
Compliance documentation (Declarations of Conformity, technical documentation, certificates)
User manuals, safety warnings and usage instructions
Manufacturer, importer or operator identifiers
End-of-life management and recycling instructions³

The DPP will become a central tool for managing product data over the long term. It will support transparency, circularity and trust by digitally tracking and sharing product information throughout its lifecycle, helping ensure compliance with the ESPR.

Impact on consumer products

On April 14, 2025, the European Commission published a communication entitled, ‘Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030’. This document included a list of priority product groups under the ESPR:

Textiles and apparel
Furniture
Tires
Mattresses

In addition, the ESPR will also target intermediate products – aluminum, iron and steel – that are widely used in consumer goods supply chains.

It should be noted that, while the information and communication technology (ICT) and energy-related product sectors are not directly prioritized, they will still be impacted through the transition of current ecodesign rules into the ESPR framework, the changes impacting intermediate products and the horizontal requirements being prioritized:

Repairability scoring
Requirements for recycled content and recyclability of electrical and electronic equipment⁴

Textiles and apparel

These are listed as a priority product group due to their high environmental footprint, fast turnover rates and low levels of reuse and recycling. It is expected that the regulatory focus will center on durability, material composition, microplastic shedding, recycled content and end-of-life management.

Rollout for the DPP is expected to begin before 2027, with mandatory data sharing on product origins, materials and sustainability claims.

To learn more about the impact of the DPP on the textile industry, read our Consumer Compact article How the Digital Product Passport Will Reshape Fashion Supply Chains.

Furniture

Furniture is being targeted because it uses large volumes of resources such as wood, metal, textiles and foam. Targeting the sector presents a significant opportunity to improve resource efficiency and material recovery, which will have a significant impact on environmental factors such as climate change, acidification and eutrophication.

At the same time, the complex material composition of furniture makes it difficult to recycle, resulting in low reuse and recycling rates. Enhancing modularity, repairability and recyclability at the design stage will help reduce waste generation while also improving air quality, soil health and biodiversity.

Mattresses

Every year, millions of mattresses are discarded in the EU. Most end up in landfills or incinerators due to the difficulty of recycling products with a complex combination of foams, textiles, metal springs and adhesives. A key response will be to improve durability and repairability, enabling the production of mattresses with a longer lifetime. This will not only reduce waste but also enhance material efficiency.

Toys

While toys are not being targeted as priority products, the proposed Toy Safety Regulation (TSR) will introduce a requirement to replace the declaration of conformity (DoC) with the DPP. The DPP for toys will include the following information:

A unique identifier for the toy product
Name and address of the manufacturer
Name and address of the importer
Product identification details to ensure full traceability
Commodity code (Customs classification) under which the toy is categorized
References to all applicable EU legislation the toy complies with
References to relevant harmonized standards used for conformity
If applicable, the name and identification number of the notified body involved in EC type examination
The CE marking, indicating EU compliance
A list of allergenic fragrances present in the toy
A communication channel (e.g. phone number, email address) for consumer complaints
Technical documentation for any included radio equipment, as required under the Radio Equipment Directive (2014/53/EU)
A direct link to relevant product safety information on the EU Safety Gate platform

Timeline for change

April 25, 2024 – EP Plenary voted on final ESPR text
May 27, 2024 – Final Council endorsement
June 2024 – Publication in Official Journal of the EU
Q3 2024 – Establishment of Ecodesign Forum and membership call
Late 2024/early 2025 – First meeting of Ecodesign Forum
March 2025 – First ESPR Working Plan adopted
Mid 2025 – Acts on unsold goods destruction ban and exemptions expected
Late 2025 – Acts on DPP registry, service providers, data carriers and digital credentials expected
2026 – Adoption of the first ESPR measures expected
2027/2028 – First product requirements come into force (expected)

Opportunity

The adoption of the ESPR and the introduction of the DPP will fundamentally change the way consumer product brands function in the EU. However, this is not just about sustainability and regulatory compliance, it is also about redefining the basis for competition in the EU market.

Businesses that embrace these innovation drivers – by embedding the principles of circularity into their design process, digitalizing compliance processes and turning transparency into a competitive advantage – will secure long-term relevance in an evolving, regulation-aligned, future-focused market landscape.

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