Know your ESPR from your elbow

Less is more - photo by Markus Spiske on Unsplash

In July 2024, the EU ushered in a new era for sustainable consumption: the Ecodesign for Sustainable Products Regulation (ESPR).

Building on - and vastly expanding - the previous Ecodesign Directive, ESPR extends sustainability requirements far beyond energy-related products to cover almost all physical goods sold in Europe. From electronics and furniture to paints, detergents and even component materials, ESPR reshapes how products entering the EU market must be designed, made and circulated.

At its heart, ESPR establishes a new set of design expectations: products should last longer, be easier to repair, upgrade and recycle, use fewer resources and have a lower environmental footprint. For many companies, compliance won’t be just about tweaking existing processes - it will mean fundamentally rethinking product development, supply chains and business models.

One of the most high-profile features of the regulation is the forthcoming Digital Product Passport (DPP). Acting as a digital “identity card” for products, it will provide detailed data on material composition, carbon footprint, recycled content, maintenance requirements and end-of-life options. The DPP is designed to give regulators, recyclers, and even consumers deep visibility into a product’s sustainability story.

For clothing manufacturers and retailers, the impact is especially significant. Textiles are expected to be among the first product groups regulated, demanding garments designed for greater durability, repairability and recyclability. Fibre choices, chemical inputs and recycled content will come under increasing scrutiny, and the DPP will require new levels of transparency across global supply chains.

A major turning point is the ban on destroying unsold textiles: from 2026, large fashion businesses will be prohibited from sending new, unused stock to landfill or incineration, with medium-sized brands following later. This forces a long-overdue rethink of overproduction, forecasting and inventory planning.

As the first set of product-specific rules rolls out from 2025, one message is clear: ESPR doesn’t just update Europe’s sustainability rulebook - it rewrites the logic of product design entirely, accelerating the shift toward a more circular, transparent and resource-smart economy.

10-point summary for industry leaders:

1. Scope expansion
   ESPR replaces the previous 2009 Directive and extends ecodesign requirements from energy-related products to virtually all physical goods - from electronics and furniture to textiles, paints, tyres and more.

2. Core sustainability criteria
   Products will need to meet new design/performance standards around durability, reparability, upgradability, recyclability, reduced resource/energy use, transparency in materials and lower carbon or environmental footprints.

3. Mandatory Digital Product Passport (DPP)
   Nearly all regulated products must be accompanied by a machine-readable DPP, with a unique identifier and data covering materials, recycled content, environmental footprint, repair/recycling instructions, and more.

4. Transparency & traceability across the value chain
   Manufacturers, distributors and marketplaces will need to collect, maintain and expose sustainability data - not just for compliance, but for supply-chain transparency, regulatory checks, recycling and circular-economy requirements.

5. Ban on destruction of unsold textiles and footwear
   For the first time, ESPR prohibits the destruction of unsold clothes, accessories and footwear by large companies (from 2026) - and medium-size firms will follow by 2030.

6. Obligation to disclose unsold-stock disposal
   Even if not destroying stock, companies must report annually the number/weight of unsold items discarded, why, and how (e.g. reuse, recycling, energy recovery) - publicly.

7. Enforcement and compliance risk
   Non-compliant products, e.g. lacking DPP, not meeting delegated act criteria, may be barred from the EU market; national authorities in Member States will carry out checks, with potential withdrawal or recall of non-compliant products.

8. Implications for supply-chain and operations
   Companies will need robust data-collection from design through manufacturing, maintain material and product-level records, build processes for repair, recycling or resale, rethink forecasting and reduce overproduction to avoid unsold inventory risks.

9. Competitive opportunity for innovators and circular business models
   Firms that invest early in sustainable design, traceability, repairability, reused/recycled materials or circular-economy business models (resale, remanufacturing, rental, recycling) may gain a competitive edge - and can turn compliance requirements into brand strengths.

10. Long-term shift from linear to circular economy
    ESPR institutionalises a shift from “take-make-dispose” toward circular product lifecycles: better design, transparency, reuse and resource-efficiency. For sectors like apparel, furniture or electronics, this means rethinking product life cycles - from raw materials to end-of-life - for long-term sustainability and regulatory compliance.

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