// SUB-PILLAR — ESPR BY SECTOR
ESPR by Sector — Product-Specific Ecodesign Requirements
The Ecodesign for Sustainable Products Regulation (EU 2024/1781) applies to virtually all physical products placed on the EU market, but the specific requirements for each product group are set through delegated acts. This page provides an overview of ESPR requirements by sector — covering the product groups currently in the delegated act pipeline, the expected timelines, and the specific compliance challenges for each sector.
How ESPR Applies by Sector
ESPR does not set a single compliance date for all products. Instead, the European Commission adopts delegated acts that specify the ecodesign requirements, DPP data requirements, and compliance timelines for each product group. The Commission publishes an ESPR Working Plan that identifies which product groups will be addressed and in what sequence. The first working plan (2022–2024) prioritises textiles and apparel, electronics and ICT equipment, furniture, steel and aluminium, chemicals, and tyres. Subsequent working plans will extend coverage to additional product categories.
The delegated act process typically takes three to five years from the start of the preparatory study to the entry into force of the delegated act. This means that manufacturers in product categories currently under study should be preparing now — building the data infrastructure, supplier engagement processes, and DPP systems that will be required when the delegated act enters into force.
Textiles and Apparel
Textiles is one of the highest-priority sectors in the ESPR Working Plan. The textile delegated act is expected to be adopted in 2025–2026 and to enter into force in 2027–2028. Key requirements expected for textiles include minimum recycled fibre content percentages, restrictions on microplastic-releasing fibres, durability and washability standards, repairability requirements (including availability of spare buttons and repair instructions), and a Digital Product Passport containing fibre composition, country of manufacture, recycled content, and care and end-of-life instructions. For exporters from Bangladesh, Vietnam, India, Morocco, and Ethiopia — who supply a significant proportion of EU textile imports — the textile delegated act will create direct compliance obligations that will be passed down from EU brands to their suppliers.
Electronics and ICT Equipment
Electronics is the second highest-priority sector. The electronics delegated act is expected to cover smartphones, laptops, tablets, televisions, and other consumer electronics. Key requirements include minimum battery replaceability standards, minimum software support periods (to prevent premature obsolescence), spare parts availability for a minimum of five to seven years, repairability scores, and DPPs containing battery health data, repairability information, and end-of-life instructions. The EU Battery Regulation (2023/1542) already imposes DPP requirements on batteries, which will apply from 2027. The electronics delegated act will extend DPP requirements to the devices themselves.
Furniture and Wood Products
The furniture delegated act is in the preparatory study phase and is expected to be adopted in 2026–2027. Key requirements expected for furniture include minimum recycled content for wood-based materials, restrictions on hazardous substances in surface treatments and adhesives, durability standards, disassembly requirements (to facilitate repair and end-of-life recycling), and DPPs containing material composition, recycled content, and end-of-life instructions. The furniture sector is significant for exporters from Indonesia, Vietnam, Brazil, and other major furniture manufacturing nations.
Construction Products
Construction products are addressed through both ESPR and the revised Construction Products Regulation (CPR). ESPR will apply to construction products that are not covered by the CPR, and the two regulations will be coordinated to avoid duplication. Key ESPR requirements expected for construction products include embodied carbon declarations, recycled content requirements for insulation materials and building materials, and DPPs containing material composition and environmental product declaration (EPD) data.
Steel, Aluminium, and Metals
The steel and aluminium delegated acts are expected to address recycled content requirements, carbon footprint declarations, and DPPs for steel and aluminium products placed on the EU market. These requirements will be particularly significant for steel and aluminium exporters from China, India, South Korea, Brazil, and other major producing nations. The Carbon Border Adjustment Mechanism (CBAM) already imposes carbon reporting obligations on steel and aluminium imports — ESPR will add DPP requirements on top of CBAM obligations.
Batteries
Batteries are addressed through the EU Battery Regulation (2023/1542), which is aligned with ESPR and introduces DPP requirements ahead of the ESPR delegated act programme. Battery DPPs are required for industrial batteries and EV batteries from February 2027, and for all batteries from August 2027. The battery DPP must contain state of health data, recycled content percentages for cobalt, lithium, nickel, and lead, carbon footprint per kWh, and supply chain due diligence information.
Sector Readiness Timeline
| Sector | Delegated Act Status | Expected DPP Requirement | Priority |
|---|---|---|---|
| Batteries | In force (EU Battery Regulation) | February 2027 (industrial/EV) | Immediate |
| Textiles | Preparatory study complete | 2027–2028 | High |
| Electronics | Preparatory study ongoing | 2028–2029 | High |
| Furniture | Preparatory study phase | 2029–2030 | Medium |
| Steel and aluminium | Scoping phase | 2029–2031 | Medium |
| Construction products | Scoping phase | 2030–2032 | Medium |
| Chemicals | Scoping phase | 2030–2032 | Medium |
| Tyres | Scoping phase | 2030–2032 | Medium |
What Manufacturers Should Do Now
Regardless of where your product category sits in the delegated act pipeline, there are actions that every manufacturer supplying the EU market should take now. First, identify which ESPR working plan category your products fall into and monitor the Commission's delegated act progress for your sector. Second, begin building the data infrastructure required for DPP compliance — this means establishing systems to track materials composition, recycled content, substances of concern, and carbon footprint data across your supply chain. Third, engage with your EU importer or authorised representative to understand how ESPR obligations will be allocated between you. Fourth, register with a DPP registry to establish the technical infrastructure for DPP compliance before the delegated act enters into force.
Frequently Asked Questions
Batteries (via EU Battery Regulation, DPPs required from February 2027) are first. Textiles are next, with DPPs expected from 2027–2028. Electronics follow in 2028–2029. Check the delegated act tracker for your specific product category.
Yes. ESPR applies to any product placed on the EU market, regardless of where it was manufactured. Non-EU manufacturers must comply with ESPR requirements for products exported to the EU, typically through an EU-based importer or authorised representative.
The Commission publishes the ESPR Working Plan on the EUR-Lex website and the ESPR product database. The working plan identifies product groups by NACE code and product description. If your product is not in the current working plan, it may be addressed in a future working plan.
The EU Battery Regulation (2023/1542) is a separate regulation that addresses batteries specifically and introduces DPP requirements for batteries ahead of the ESPR delegated act programme. ESPR will eventually cover batteries as part of its broader scope, but the Battery Regulation's DPP requirements apply first.
Yes, provided the system meets the technical requirements for each product group's delegated act. A well-designed DPP registry can accommodate multiple product categories with different data schemas.
Textiles and Apparel — ESPR Requirements in Depth
The textiles and apparel sector is one of the highest-priority product groups in the ESPR Working Plan. The European Commission has identified textiles as a major contributor to environmental impact — the sector is responsible for significant greenhouse gas emissions, water consumption, chemical pollution, and waste generation. The preparatory study for the textiles delegated act is underway, and the Commission has indicated that it intends to adopt the delegated act by 2025–2026.
The expected requirements for textiles under ESPR include: minimum recycled content percentages for specific fibre types; durability requirements expressed as minimum wash cycles before significant degradation; restrictions on microplastic release; information requirements about fibre composition, country of manufacture, and care instructions; and a Digital Product Passport containing detailed information about materials, substances of concern, recycled content, and end-of-life instructions. For exporters of textiles to the EU — including manufacturers in Bangladesh, India, Vietnam, Morocco, Ethiopia, and other major textile-producing countries — these requirements will fundamentally change the data that must accompany every shipment.
Electronics and ICT Equipment — ESPR Requirements in Depth
Electronics and ICT equipment are covered by both ESPR and the existing Ecodesign Regulation for electronic displays and other energy-related products. ESPR extends and deepens these requirements by adding DPP obligations, repairability scores, and recycled content requirements. The electronics delegated act is expected to cover smartphones, tablets, laptops, desktop computers, monitors, and related ICT equipment. Key expected requirements include: minimum repairability scores (building on the methodology being developed under the Right to Repair Directive); spare parts availability for a minimum of seven years after the last unit is placed on the market; software update availability for a minimum of five years; minimum percentages of recycled cobalt, lithium, and rare earth elements; and a DPP containing battery state of health data, repairability score, recycled content percentages, and end-of-life instructions.
Furniture — ESPR Requirements in Depth
The furniture sector is a significant contributor to deforestation, formaldehyde emissions, and end-of-life waste. The ESPR delegated act for furniture is expected to address: wood sourcing (requiring documentation of legal and sustainable origin); formaldehyde and other VOC emission limits; durability requirements; disassembly requirements (products must be designed to be disassembled for repair and end-of-life material recovery); recycled content requirements for wood panels and upholstery materials; and a DPP containing material composition, wood origin certification, VOC emission data, and disassembly instructions. For furniture manufacturers and exporters, the DPP requirement will require significant investment in supply chain traceability — knowing not just what materials are in a product, but where those materials came from and what certifications apply.
Construction Products — ESPR and the Construction Products Regulation
Construction products are subject to both ESPR and the revised Construction Products Regulation (CPR). The interaction between these two regulations is complex. ESPR applies to construction products placed on the EU market as physical products, while the CPR addresses the performance characteristics of construction products in use. The ESPR delegated act for construction products is expected to focus on insulation materials, building materials, and structural components — addressing embodied carbon, recycled content, and end-of-life recyclability. The DPP for construction products will need to contain information about embodied carbon (calculated using EN 15978 or equivalent methodology), recycled content, hazardous substance content, and end-of-life recyclability.
Batteries — The EU Battery Regulation and ESPR Alignment
Batteries are the first product category to be subject to mandatory DPP requirements under EU law. The EU Battery Regulation (Regulation (EU) 2023/1542) requires a Battery Passport for industrial batteries, EV batteries, and LMT batteries from February 2027. The Battery Passport is technically a DPP under the ESPR framework — it uses the same data carrier standards, the same registry infrastructure requirements, and the same data architecture. Manufacturers of batteries, electric vehicles, and battery-powered industrial equipment should treat the Battery Passport as the pilot implementation of ESPR DPP requirements and use it to build the data infrastructure that will be extended to other product categories.
// NEXT STEP
Register Your Digital Product Passport
Compliance with ESPR begins with a registered, machine-readable Digital Product Passport. The DPP Registry at digitalproductpassports.co.za provides the infrastructure to mint, host, and verify DPP records for manufacturers and exporters supplying the EU market.
Register Your Digital Product Passport →