ESPR 2024/1781 · DIGITAL PRODUCT PASSPORT · ECODESIGN

ESPR Regulation: Ecodesign for Sustainable Products in the EU.

The ESPR Regulation (EU 2024/1781) extends ecodesign requirements to all product categories and introduces the Digital Product Passport as a mandatory instrument. IgeraIndustria answers every ESPR compliance question: DPP data requirements, durability and repairability criteria, priority product categories, delegated act timelines, and the transition from Ecodesign Directive 2009/125/EC. Your product team finds the answer in seconds.

ESPR 2024/1781 pre-indexed DPP requirements and delegated acts <3s response

ESPR 2024/1781: ecodesign, Digital Product Passport and lifecycle sustainability for EU products

ESPR is the most comprehensive product sustainability regulation the EU has ever enacted. Yet many manufacturers do not know whether their product category is in the first working plan, what data fields the Digital Product Passport will require, or how existing Ecodesign implementing regulations interact with the new ESPR framework.

2026

Digital Product Passport mandatory for first product categories — batteries lead, followed by textiles and construction products from 2027 under ESPR delegated acts.

30 cat.

product categories in the first ESPR working plan (2025-2030) covering textiles, furniture, steel, aluminium, tyres, motors, heat pumps, photovoltaic panels and more.

4% turnover

maximum fine for ESPR non-compliance — Member States must establish penalties that are effective, proportionate and dissuasive, with a maximum of at least 4% of annual turnover.

Product teams spend months deciphering ESPR’s 12 sustainability parameters, determining which delegated act applies to their product, and planning the DPP data infrastructure required. IgeraIndustria answers those questions in seconds, citing the exact ESPR article and applicable delegated act timeline, so the product team can focus on designing compliant products.

Instant ESPR compliance query by requirement

IgeraIndustria locates the exact ESPR requirement that applies to each question and responds with the applicable ecodesign parameter, DPP data field requirement, and delegated act timeline.

Digital Product Passport data requirements

ESPR Art. 9 defines the DPP data that manufacturers must provide. IgeraIndustria identifies the specific DPP data fields applicable to each product category under the relevant delegated act: materials composition, recycled content, carbon footprint, repairability score, disassembly instructions.

Product durability and repairability requirements

ESPR allows delegated acts to set minimum durability (years of normal use before failure) and repairability scores. IgeraIndustria explains what repairability criteria apply to your product category and what design features contribute to a higher repairability score.

ESPR working plan and delegated act timeline

ESPR’s working plan prioritises product categories. IgeraIndustria identifies where your product sits in the working plan, which delegated act is being prepared, and the expected date when ecodesign requirements will apply to your product category.

Transition from Ecodesign Directive 2009/125/EC

Existing Ecodesign implementing regulations (ErP) remain valid until superseded by ESPR delegated acts. IgeraIndustria clarifies whether your product is still governed by an existing ErP regulation or whether a new ESPR delegated act has replaced it.

Hazardous substance restrictions under ESPR

ESPR allows delegated acts to restrict or ban substances in products that impede repair, reuse or recyclability (even if allowed under REACH or RoHS). IgeraIndustria identifies whether your product category has ESPR-specific substance restrictions in addition to REACH/RoHS.

Carbon footprint and recycled content requirements

ESPR delegated acts can set mandatory maximum carbon footprint thresholds and minimum recycled content percentages per product category. IgeraIndustria identifies the applicable thresholds for your product and what Life Cycle Assessment methodology is accepted.

Complete ESPR compliance support for product manufacturers

From DPP data infrastructure planning to repairability design reviews and delegated act monitoring, IgeraIndustria supports the product and sustainability team at every stage of ESPR compliance.

DPP data architecture planning

The Digital Product Passport requires a data infrastructure to collect, store and expose product sustainability data via a standardised data carrier. IgeraIndustria explains what DPP data systems must be capable of, what EU registry integration is required, and how to structure supplier data collection for DPP fields.

Repairability score design review

ESPR delegated acts for categories like smartphones and tablets already include repairability scoring criteria: availability of spare parts, software update duration, ease of disassembly, repair manual availability. IgeraIndustria identifies which design choices affect your product’s repairability score and what must change to meet minimum thresholds.

Supply chain data collection for DPP

DPP data on materials composition, recycled content and carbon footprint must be verified by suppliers throughout the supply chain. IgeraIndustria explains what data you must collect from tier-1 and tier-2 suppliers, what verification standards are accepted, and how to structure supplier information requests.

ESPR delegated act monitoring

ESPR delegated acts are published in the Official Journal of the EU and set category-specific requirements. IgeraIndustria monitors new delegated acts and alerts the product team when requirements that apply to your product categories are adopted or enter the stakeholder consultation phase.

LCA methodology and carbon footprint

ESPR delegated acts that set maximum carbon footprint thresholds specify the Life Cycle Assessment (LCA) methodology that manufacturers must use. IgeraIndustria explains which LCA standards are accepted for each product category and what system boundaries and allocation rules apply.

Market surveillance and ESPR enforcement

Market surveillance authorities will verify ESPR compliance through DPP data consistency checks, technical documentation audits and product testing. IgeraIndustria explains what documentation must be available to market surveillance and the most common non-conformities identified in early ESPR enforcement actions.

The 4 key sustainability parameters of ESPR 2024/1781

These parameters define what manufacturers must demonstrate under ESPR delegated acts applicable to their product category before placing products on the EU market.

Parameter 1 — Durability and reliability

ESPR delegated acts may set minimum product lifetime requirements (mean time to failure, accelerated ageing tests) and minimum duration for which software updates must be provided. Manufacturers must design products to meet minimum durability thresholds and provide spare parts for a defined period after end of sale. Documentation must demonstrate compliance with durability criteria.

Parameter 2 — Repairability and reusability

ESPR allows delegated acts to require minimum repairability scores, mandate the availability of spare parts at reasonable prices, require repair manuals for professional and non-professional repairers, and ban design features that impede repair (e.g., glued-in batteries, proprietary tools required). Repairability criteria are already defined for smartphones and tablets.

Parameter 3 — Recycled content and recyclability

ESPR delegated acts may set minimum percentages of recycled content per product category and material type, and require products to be designed for disassembly (Design for Recycling). Manufacturers must document recycled content using verified mass balance or physical segregation methods. Products that cannot be recycled at end of life face increasing restrictions.

Parameter 4 — Digital Product Passport

From the date specified in each delegated act, products must carry a DPP accessible via a data carrier (QR code, RFID or NFC) on the product or its packaging. The DPP must contain data specified in the delegated act: materials, carbon footprint, recycled content, repairability score, disassembly instructions, certifications. The DPP must remain accessible for the full product lifetime plus 10 years.

How IgeraIndustria works for ESPR 2024/1781

Five steps from loading your product sustainability data to receiving an answer with the exact ESPR article, applicable delegated act, and DPP data requirements for your product category.

01

Index your product sustainability documentation

Upload your LCA reports, existing product technical files, ErP implementing regulation compliance records, and supplier materials declarations. IgeraIndustria processes them together with the full ESPR 2024/1781 text and published delegated acts in under 24 hours.

02

Connect the assistant to your product and sustainability team

Embed it in your product development portal, Teams, Slack or as a standalone tool for the R&D, sustainability and regulatory team. One line of code. Compatible with any PLM or ERP system.

03

Ask in plain language

«When will ESPR delegated act requirements apply to our electric motors?», «What DPP data fields will be mandatory for our furniture products?», «Does our existing ErP regulation compliance cover ESPR or must we do a new assessment?»

04

IgeraIndustria searches across 2 knowledge layers

First in your internal product documentation (LCA reports, technical files, ErP compliance records), then in the indexed ESPR 2024/1781 text, working plan, and published delegated acts.

05

Answer with regulation reference and delegated act timeline

The response cites the applicable ESPR article or delegated act, states the applicable ecodesign parameters and DPP requirements for your product category, provides the compliance date, and identifies the highest-priority actions to prepare for DPP implementation.

IgeraIndustria in action — ESPR motor delegated act timeline

ESPR transition query for electric motors — ErP vs ESPR delegated act — resolved in under 3 seconds with the applicable regulation and DPP requirements.

IgeraIndustria — Widget ESPR 2024/1781

Product Compliance Manager

We manufacture IE3 electric motors currently complying with ErP Regulation 2019/1781. When will ESPR requirements apply to us and will we need a Digital Product Passport?

IgeraIndustria

ESPR — Electric motors transition from ErP 2019/1781

Current status:

  • • ErP Regulation 2019/1781 remains fully valid — your IE3/IE4 compliance is current and not affected yet
  • • ESPR delegated act for motors is in the second working plan (post-2027) — no DPP required yet

Expected ESPR delegated act for motors:

  • • Stakeholder consultation expected 2027-2028; delegated act adoption 2029-2030
  • • Will add DPP with: efficiency class, winding material, recycled content %, repairability score
  • • ErP 2019/1781 will remain valid until superseded by the ESPR delegated act (ESPR Art. 68)

⚠️ Start collecting supply chain materials data now — DPP recycled content verification will require tier-2 supplier documentation

✓ ESPR 2024/1781 Art. 68 + Working Plan 2025-2030 · Confidence: 96.2%

12

product families assessed

18 mo

DPP data infrastructure planned

2027

DPP-ready target for textiles

We manufacture both electric motors and industrial textiles and had no clear picture of how ESPR would affect each product line differently. IgeraIndustria mapped our 12 product families against the ESPR working plan in two days, identified that our textiles face a 2027 DPP requirement while our motors have more time, and helped us design a phased DPP data infrastructure that prioritises textiles first. We avoided building a single system too early and wasting resources.

Director of Regulatory Affairs

Industrial manufacturer — 12 product families — Bilbao

*Representative testimonial based on results from real customers

Frequently asked questions — ESPR Regulation 2024/1781

What is the Digital Product Passport (DPP) under ESPR?

The Digital Product Passport (DPP) is a mandatory digital record containing information about a product throughout its lifecycle: materials composition, recyclability, repairability score, carbon footprint, instructions for disassembly, and supply chain data. It must be accessible via a data carrier (QR code, RFID or NFC tag) on the product or its packaging. The DPP is managed through an EU-level registry. The first DPPs will be required for batteries (from 2027 under the Battery Regulation), textiles (from 2027) and construction products (from 2027). Other product categories will follow under ESPR delegated acts.

Which products are prioritised under ESPR and when do requirements apply?

ESPR sets a working plan that prioritises products by their environmental impact. Priority categories for first delegated acts (2025-2027): textile and footwear, furniture, steel, aluminium, tyres, detergents and cleaning products, paints and lacquers, lubricants, and chemicals. After 2027: electronic displays, photovoltaic panels, winding wire, motors, heat pumps, space heaters, water heaters, household washing machines and dishwashers. Each delegated act sets specific ecodesign requirements and DPP data fields for that category.

How does ESPR replace and extend the Ecodesign Directive 2009/125/EC?

The previous Ecodesign Directive 2009/125/EC focused exclusively on energy-related products and energy efficiency. ESPR extends ecodesign to ALL product categories (not just energy-using), adds new parameters beyond energy (durability, repairability, recyclability, hazardous substances, recycled content, carbon footprint) and introduces the Digital Product Passport as a mandatory instrument. The Ecodesign Directive’s existing implementing regulations (for motors, boilers, displays, etc.) remain valid until superseded by ESPR delegated acts.

IgeraIndustria ESPR Plans

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Starter

149/month

For product manufacturers that need to understand ESPR requirements for their product categories and plan DPP data infrastructure.

  • ESPR 2024/1781 pre-indexed
  • Working plan category lookup
  • DPP requirements guidance
  • 1,000 queries/month
  • Widget for the product team
  • Email support
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Professional

299/month

For companies with multiple product families that need systematic ESPR delegated act monitoring and DPP data architecture planning.

  • ESPR + internal product docs indexed
  • Multi-category delegated act tracking
  • DPP data architecture support
  • 5,000 queries/month
  • Delegated act alerts
  • Priority support
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Enterprise

599/month

For industrial groups managing ESPR, ErP and sustainability reporting across multiple product lines and EU markets.

  • Multi-regulation (ESPR + ErP + PPWR)
  • DPP system integration support
  • Supply chain data collection planning
  • Unlimited queries
  • 99.9% uptime SLA
  • Dedicated customer success
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