EXPERT ANALYSIS: Ecodesign Regulation Comes into Force

The EU regulation on ecodesign has officially come into force. For many manufacturers, importers, distributors, and retailers, the question is: What happens now, particularly given tight deadlines for implementation?

Regulation (EU) 2024/1781, also known as ESPR (Ecodesign for Sustainable Products Regulation) was published in the Official Journal of the EU on 28 June 2024 and entered into force 20 days later on 18 July 2024.

ESPR is described as “the cornerstone of the EU Commission's approach to more environmentally sustainable and circular products.”

Products and the way we use them can have a significant impact on the environment,” the Commission noted, adding, “Consumption in the EU can therefore be a major cause of climate change and pollution.”

The ESPR is part of a package of measures that are central to achieving the objectives of the 2020 Circular Economy Action Plan. They will contribute to helping the EU reach its environmental and climate goals, including doubling its circularity rate of material use and achieving its energy efficiency targets by 2030.

A Year to Establish the First Work Plan

The EU Commission has until 19 April 2025 to establish a work plan in which product groups will be the subject of delegated acts with specific ecodesign requirements. As required under article 18 (5), the Commission will prioritize product groups, and has already begun to draft work plans for steel and textiles. Additional product groups include:

• aluminum
• textiles, including garments and footwear
• furniture, including mattresses
• tires
• detergents
• paints
• lubricants
• chemicals
• energy related products, and
• information and communication technology products and other electronics.

The first delegated act will enter into force after 19 July 2025. That leaves only one year until the first delegated act enters into force and organizations will have implementation instructions for a specific product group. At that point, we will know which of the many ecodesign requirements will be applied for a specific product group and which specific requirements must be included in the digital product passport.

During that time, organizations will need to become familiar with the elements of their entire product lines, including:

• durability
• reliability
• reusability
• upgradability
• repairability
• the possibility of maintenance and refurbishment
• the presence of substances of concern
• energy use and energy efficiency
• water use and water efficiency
• resource use and resource efficiency
• recycled content
• the possibility of remanufacturing
• recyclability
• the possibility of the recovery of materials
• environmental impacts, including carbon footprint and environmental footprint, and
• expected generation of waste.

How to Prepare for the Coming Deadlines

With such a tight deadline, companies have very little time to prepare. However, setting up the right IT infrastructure to handle product information for all the performance and information requirements will be a critical first step.

All the required information should be included in a digital product passport. If necessary, the information should also be made available on the product itself, on the packaging or labels, or in a user manual. This information must be freely accessible, for example, via a website or an application.

The EU Commission will also set up a Digital Product Registry by 19 July 2026. The Digital Product Registry will be an online system that enhances the traceability and transparency of products throughout their lifecycle. It will store essential information about products, enabling better compliance with ecodesign requirements and providing valuable data to consumers, businesses, and regulators.

Regulation (EU) 2024/1781 establishes a comprehensive legal framework aimed at enhancing the ecological sustainability of products and facilitating the transition to a sustainable, circular economy. The harmonized ecodesign requirements are designed to boost environmental protection and ensure the free movement of goods within the EU.

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Editor's Note: 3E is expanding news coverage to provide customers with insights into topics that enable a safer, more sustainable world by protecting people, safeguarding products, and helping businesses grow. Expert Analysis articles, produced by 3E subject matter experts, researchers, and consultants as well as external thought leaders, examine the regulations, trends, and forces impacting the use, manufacture, transport, and export/import of chemicals.