Ecodesign
Ecodesign is the integration of environmental considerations into product design to reduce environmental impact throughout the product's lifecycle, from raw material extraction through manufacturing, use, and end-of-life. ESPR establishes ecodesign requirements for products placed on the EU market.
Full Definition
Ecodesign is defined in ESPR Article 2(1) as "the integration of environmental sustainability aspects into product characteristics with the aim of improving the environmental performance of products throughout their lifecycle." The concept covers the full product lifecycle — not just the use phase, but also raw material extraction, manufacturing, distribution, use, and end-of-life management.
ESPR sets ecodesign requirements for products across multiple environmental dimensions: durability and reliability, reusability, upgradability and reparability, the presence of substances of concern, energy and resource efficiency, recycled content, remanufacturing and recycling, and carbon and environmental footprints. These requirements are set in delegated acts for specific product categories.
The predecessor to ESPR — the Ecodesign Directive (2009/125/EC) — focused primarily on energy-related products and set minimum energy efficiency requirements. ESPR significantly expands the scope to cover all product categories and adds requirements beyond energy efficiency, including material efficiency, repairability, and the Digital Product Passport.
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Register Your Digital Product Passport →Ecodesign in EU Law: From Directive to Regulation
Ecodesign as a regulatory concept in the EU was first established by the Ecodesign Directive (2005/32/EC), which was subsequently replaced by the Ecodesign Directive (2009/125/EC). The 2009 directive focused primarily on energy-related products and energy efficiency. The ESPR (EU 2024/1781) replaces the 2009 directive and expands the ecodesign concept to cover all physical products and a much broader set of environmental parameters. The transition from directive to regulation is significant — a directive requires national transposition (each EU member state must pass national legislation implementing the directive), while a regulation is directly applicable in all member states without national transposition. This change ensures uniform application of ecodesign requirements across the EU.
Ecodesign Parameters Under ESPR
ESPR Article 5 specifies twelve ecodesign parameters that may be addressed in delegated acts: durability, reliability, reusability, upgradability, repairability, maintenance and refurbishment possibilities, presence of substances of concern, energy and resource efficiency, recycled content, remanufacturing and recycling possibilities, carbon and environmental footprint, and expected generation of waste materials. Not all twelve parameters will be addressed in every delegated act — the delegated act for each product category will specify which parameters are relevant and what the minimum requirements are for each parameter.
Ecodesign requirements under ESPR are set through delegated acts — secondary legislation adopted by the EU Commission that specifies the minimum performance thresholds for each product category. The delegated act for a product category will specify which ecodesign parameters apply (energy efficiency, durability, repairability, recycled content, carbon footprint), the minimum performance levels for each parameter, the test methods to be used for measuring performance, and the conformity assessment procedure. Manufacturers must demonstrate compliance with all applicable ecodesign requirements before placing their products on the EU market. Products that do not meet the ecodesign requirements cannot bear the CE marking and cannot be legally sold in the EU.
Under ESPR, ecodesign requirements are legally binding and enforceable through the CE marking system. A product that does not meet the applicable ecodesign requirements cannot bear the CE marking and cannot be legally placed on the EU market. Market surveillance authorities verify ecodesign compliance through product testing, documentation review, and DPP data verification. Non-compliant products are subject to market withdrawal and financial penalties. Manufacturers should treat ecodesign requirements as minimum performance floors, not aspirational targets — compliance is a legal prerequisite for EU market access, not a voluntary commitment.