Who is Affected by the ESPR and its Digital Product Passport?

Want to start at the beginning of the ESPR journey? Start with our blog posts Introducing the ESPR and Digital Product Passports and on Preparing for the ESPR's Digital Product Passport.

Which product groups are prioritized by the ESPR?

The Ecodesign for Sustainable Products Regulation (ESPR), as detailed in a study by the Joint Research Centre (JRC), uses a rating scale from 1 (very low) to 5 (very high) to assess product groups on the basis of their environmental impact. The assessment considers several key parameters such as: improvement potential, market relevance, policy coverage within the EU, environmental impact, cost considerations and contribution to the EU's open strategic autonomy. As a result, the following key focus areas were identified:

• Eleven final product groups: textiles and footwear, furniture, tires, mattresses, detergents, paints and varnishes, lubricants, cosmetics, toys, fishing tackle and absorbent hygiene products.

• Seven intermediate products: iron and steel, basic chemicals, nonferrous and non-aluminum metals, aluminum, plastics and polymers, pulp and paper, and glass.

In order to understand the strategic importance of these products, an assessment dimension was added: their potential contribution to the EU's Open Strategic Autonomy. This rating reflects a combination of key factors, including usage of raw materials, reliance on fossil fuels, production and use of energy and vulnerability to EU import restrictions or sanctions on related materials. These results are the final recommendations of the JRC for new product priorities under the ESPR, but are subject to further review and are not binding on the Commission.

Consumer Electronics and Home Appliances 

With the global number of mobile devices expected to reach 18.22 billion by 2025, the electronics sector faces significant challenges in managing e-waste. Frequent upgrades and short product life cycles contribute to a growing environmental problem. 

The electronics industry is now incentivized to design products with repair and reuse in mind. For example, smart phones are required to have replaceable batteries, and refrigerators are expected to have accessible circuit boards. The DPP also includes guidelines for replacing components and detailed instructions for repairing the product. 

Lack of recycling infrastructure often leads to products ending up in landfills or being incinerated. To counter this, the DPP mandates end-of-life management options with clear and accessible recycling instructions. For instance, a vacuum cleaner’s digital passport might include details on recycling facilities, substances of concern, and safe disassembly techniques. 

Automotive and Transportation 

Electric vehicle batteries, along with other industrial batteries, are the first product group legally required to include a DPP, starting in 2027 under the EU Battery Regulation. This requirement aims to improve transparency by documenting battery composition and sourcing of materials like lithium, cobalt, and nickel and providing lifecycle data to minimize the environmental impact of mining and production. 

Recyclers can use this information to extract valuable components, ensuring efficient use of resources. The DPP also extends to other key vehicle components, such as engines and structural parts and onboard electronics. 

To promote repairability, vehicle components too, must be designed for disassembly. Documentation will guide users and recyclers on proper repair methods and material recycling.  

Fashion and Textiles 

The fashion and textile industry faces significant changes at all stages of a product’s lifecycle. Products are required to be built for durability, incorporating raw materials that withstand frequent use, facilitate repairability, and support recycling. Examples include the use of single-material designs and reinforced seams to enhance both durability and recyclability. 

Transparency is key with DPP, involving detailed information on material composition, sourcing, energy usage, and the carbon footprint of production. Providing this information empowers consumers to make sustainable choices and facilitates better management of product waste. 

Textile companies are encouraged to adopt practices that prevent the destruction of unsold goods, with regulations mandating disclosure of disposal methods and banning the destruction of apparel and footwear after two years. In the EU, 4–9% of unsold textiles never reach consumers, underscoring the need for measures to reduce waste and improve sustainability. 

To address these issues, companies must establish or join textile collection and recycling schemes. Businesses are further obligated to disclose: 

• The number and weight of discarded products annually. 

• The reasons for destruction. 

• Applicable waste treatment operations and measures taken to avoid destruction. 

Efforts to minimize environmental footprints include reducing water and energy use, lowering emissions, and avoiding harmful chemicals. Innovative practices such as waterless dyeing and renewable energy sourcing are encouraged. Companies that fail to comply with these measures risk losing access to the EU market. 

Packaging and Manufacturing Sectors 

Under the DPP framework, also packaging itself must carry detailed lifecycle information, including material composition, recyclability, origins and environmental footprint. DPP-compliant packaging improves recycling efficiency, especially for challenging materials like multi-layer plastics. Companies that meet these standards gain a competitive edge by offering sustainable and traceable packaging solutions. As DPP compliance becomes a requirement for EU market access, early adoption positions businesses for long-term success. 

Retailers 

Retailers face new responsibilities under the ESPR and DPP, including tracking emissions and product data. This shift requires a significant amount of adaptation, but offers opportunities for growth, such as subscription repair services. 

Some retailers, like the German chain MediaMarkt, are incorporating subscription models for product repairs. The subscription includes unlimited equipment insurance, round-the-clock technical support and repair services for different household appliances, electrical appliances and personal equipment, aligning perfectly with ESPR’s goals of durability, reusability, and repairability, demonstrating how compliance can enhance profitability.  

Small and Medium-Sized Enterprises (SMEs) 

SMEs face resource constraints in complying with ecodesign requirements. Micro-enterprises, in particular, struggle with the administrative and financial burdens. To mitigate these challenges, the ESPR provides: 

• Financial incentives and digital tools for compliance. 

• Training programs tailored to SME needs. 

• Networking opportunities and guidance through one-stop shops. 

  SMEs can turn sustainability into a competitive advantage by leveraging their agility to innovate and adapt quickly. The ESPR levels the playing field by prioritizing sustainability as a key market driver. 

Conclusion 

The DPP market is projected to reach USD 12 billion by 2032. Industries can leverage DPPs to enhance brand differentiation with sustainability credentials, optimize supply chains through better insights and promote circular economy initiatives, such as product-as-a-service models in furniture or clothing. 

The ESPR and DPP set the stage for a more sustainable future, offering opportunities for innovation while imposing necessary adjustments across industries. But by embracing these regulations, manufacturers, retailers, and SMEs can drive environmental progress while ensuring their economic resilience. 

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