ESPR Requirements by Product Category

How the ESPR Applies to Different Product Categories

The Ecodesign for Sustainable Products Regulation (ESPR), formally adopted as EU Regulation 2024/1781, takes a fundamentally different approach to product regulation compared to its predecessor. Rather than applying a single set of requirements to all products, the ESPR establishes a framework regulation that is then fleshed out through product-specific delegated acts. Each delegated act sets tailored requirements for a particular product category, reflecting the unique environmental challenges, manufacturing processes, and lifecycle considerations relevant to that sector.

This category-specific approach recognises that a one-size-fits-all regulation would be both impractical and ineffective. The environmental impact of a cotton T-shirt is fundamentally different from that of a lithium-ion battery or a concrete beam, and the interventions needed to improve sustainability outcomes vary accordingly. By developing tailored requirements through delegated acts, the European Commission can set ambitious but achievable targets that reflect the specific circumstances of each product category.

Understanding which product categories are prioritised, what requirements are likely to apply, and when compliance deadlines will take effect is essential for manufacturers, importers, and distributors operating in the EU market. This article provides a comprehensive overview of the current landscape and expected developments. For a broader understanding of the regulation itself, see our complete guide to ESPR regulation.

Priority Product Categories Under the ESPR

The European Commission has identified several product categories as priorities for early delegated acts, based on their environmental impact, market size, and potential for improvement. These priority categories represent the sectors where ESPR requirements will take effect first, and where manufacturers should be focusing their compliance preparation efforts most urgently.

The initial priority product categories include:

• Textiles (apparel), addressing fast fashion, microplastics, and textile waste; footwear is studied separately, with a Commission report due by the end of 2027
• Iron and steel, targeting industrial emissions and recycled content
• Aluminium, focusing on energy-intensive production processes
• Furniture, covering durability, repairability, and material recovery
• Tyres, addressing wear particles, rolling resistance, and retreading
• Mattresses, covering durability, material recovery and end-of-life (indicative adoption 2029)
• Horizontal repairability requirements, including a repairability score, reaching electronics and other products (indicative adoption 2027)
• Horizontal recycled content and recyclability requirements for electrical and electronic equipment (indicative adoption 2029)

These categories were selected based on extensive impact assessments and stakeholder consultations. The Commission evaluated factors including the total environmental footprint of each product category, the potential for improvement through ecodesign requirements, the maturity of available alternatives, and the readiness of industry to implement changes. Products already covered by sector-specific legislation, such as batteries under the Battery Regulation, will have their DPP requirements coordinated to avoid duplication.

Textiles and Footwear Requirements

The textiles sector is one of the most high-profile targets of the ESPR, reflecting growing public concern about the environmental impact of fast fashion. The EU textile industry generates approximately 12.6 million tonnes of waste annually, with less than 1% of clothing being recycled into new garments. The ESPR's textile delegated act aims to address this by setting requirements across the entire product lifecycle.

Expected requirements for textiles and footwear include mandatory durability standards specifying minimum performance levels for fabric strength, colour fastness, and seam integrity. Manufacturers will need to declare the percentage of recycled fibres used, with likely minimum thresholds increasing over time. Microplastic release rates from synthetic textiles will be regulated, requiring manufacturers to adopt fibre technologies or finishing processes that minimise shedding during washing.

The Digital Product Passport for textiles will need to include detailed fibre composition data, country of manufacturing, chemical treatments applied, and care instructions optimised for product longevity. For footwear specifically, requirements will extend to sole durability, adhesive types used, and disassembly potential for material recovery. The ESPR timeline guide provides specific deadline information for the textiles sector.

Brands and retailers should note that the ESPR requirements will apply to all textiles sold in the EU market, regardless of where they are manufactured. This means that global supply chains will need to implement traceability and data collection capabilities that may require significant investment in supplier engagement and verification systems.

Electronics and ICT Equipment

Electronics and information and communication technology (ICT) equipment represent another critical focus area for the ESPR. The sector generates approximately 12 million tonnes of e-waste in the EU annually, and the rapid obsolescence of electronic devices has become a major environmental concern. The ESPR builds upon existing ecodesign regulations for electronics whilst introducing new requirements around repairability, software support, and critical raw material recovery.

For electronics, the ESPR is expected to mandate minimum repairability scores calculated using a standardised methodology. Manufacturers will need to provide spare parts at reasonable prices for a defined minimum period after the last unit is placed on the market. Software updates that maintain device functionality will need to be provided for specified minimum periods, addressing the growing problem of software-driven obsolescence.

Key requirements expected for electronics include:

• Minimum repairability scores based on disassembly ease, parts availability, and documentation
• Mandatory availability of spare parts for a minimum period (likely 7-10 years)
• Software update obligations to prevent premature obsolescence
• Critical raw material content declarations including rare earth elements
• Minimum recycled content requirements for specific materials such as plastics and metals
• Energy efficiency requirements building on existing energy labelling frameworks
• Battery replaceability requirements aligned with the Battery Regulation

The Digital Product Passport for electronics will serve as a comprehensive digital twin, containing everything from material composition and assembly instructions to firmware version history and repair records. This makes electronics DPPs among the most complex to implement, requiring deep integration with manufacturing execution systems, quality management platforms, and after-sales service infrastructure.

Construction Products and Building Materials

Construction products represent a massive share of the EU's total environmental footprint, with the built environment accounting for approximately 40% of energy consumption and 36% of greenhouse gas emissions. The ESPR's approach to construction products must be coordinated with the revised Construction Products Regulation (CPR), Regulation (EU) 2024/3110, in force since 7 January 2025, which introduces its own sustainability requirements and a construction product passport.

For iron, steel, and aluminium, which are both construction materials and industrial products, the ESPR is expected to set requirements around recycled content, carbon footprint declarations, and energy efficiency of manufacturing processes. These requirements will interact with the EU Carbon Border Adjustment Mechanism (CBAM), creating a comprehensive framework for decarbonising the metals value chain.

Cement, concrete, and insulation materials are also likely to receive delegated acts in later waves of ESPR implementation. Requirements will focus on embodied carbon declarations, durability specifications, and end-of-life recyclability. The long lifespan of construction products, often 50 to 100 years, creates unique challenges for DPP data management, as the digital passport must remain accessible and up to date far longer than for consumer goods.

The full text of EU Regulation 2024/1781 provides the legal basis for construction product requirements, including the coordination mechanisms between the ESPR and the revised CPR. Manufacturers of construction products should engage with both regulatory frameworks to ensure comprehensive compliance.

Furniture and Home Furnishings

The furniture sector is targeted by the ESPR due to the growing problem of disposable furniture, particularly flat-pack products with limited repairability and durability. Approximately 10 million tonnes of furniture are discarded in the EU each year, with the majority ending up in landfill or incineration because mixed-material construction makes recycling difficult.

Expected ESPR requirements for furniture include minimum durability standards based on standardised testing protocols (such as EN seat and table tests), mandatory provision of spare parts for key components like hinges, drawer runners, and upholstery fabrics, and design-for-disassembly requirements that facilitate material separation at end of life. Chemical safety requirements will address flame retardants, formaldehyde emissions, and other substances of concern commonly found in furniture materials.

The Digital Product Passport for furniture will need to include material composition data broken down by component, disassembly instructions, information on chemical treatments applied, and guidance on proper disposal or recycling at end of life. For upholstered furniture, textile composition data must comply with both the furniture-specific delegated act and any applicable textile requirements.

Furniture manufacturers should begin by mapping their product portfolios against likely requirements, identifying products that may need redesign to meet durability or repairability standards. Early engagement with component suppliers to secure spare parts commitments and material composition data will also be critical. Our ESPR compliance checklist provides a structured approach to this preparation process.

Batteries and Energy Storage

Batteries occupy a unique position in the ESPR landscape because they are already subject to the EU Battery Regulation (Regulation 2023/1542), which was adopted before the ESPR and includes its own Digital Product Passport requirements. The Battery Regulation serves as a pioneering example of how DPPs will work in practice, with battery passports required from 18 February 2027 for LMT batteries, electric vehicle batteries and industrial batteries above 2 kWh.

The Battery Regulation requires DPPs to include detailed information on battery chemistry, capacity, state of health, charging cycles completed, carbon footprint of manufacturing, recycled content percentages for cobalt, lithium, nickel, and lead, and the presence of hazardous substances. This level of detail is more granular than what most other product categories are expected to require under the ESPR, reflecting the strategic importance of batteries to the energy transition and the environmental risks associated with battery waste.

For manufacturers of products containing batteries, from smartphones and laptops to electric vehicles and home energy storage systems, the interaction between the Battery Regulation and the ESPR creates a complex compliance landscape. The product-level DPP required by the ESPR must reference or integrate the battery-specific DPP required by the Battery Regulation, creating a hierarchical data structure that links component-level and product-level information.

Understanding this interaction is critical for manufacturers to avoid duplicating effort and ensure that their DPP systems are architected to handle multi-level product structures. The technical overview of DPP systems explains how component-level and product-level passports can be linked within a unified architecture.

Preparing for Category-Specific Requirements

The category-specific nature of ESPR requirements means that preparation strategies must be tailored to the specific products a business manufactures or imports. However, several preparation activities are universally applicable and should begin immediately, regardless of when a specific delegated act is expected to be finalised.

Universal preparation steps include conducting a product portfolio analysis to identify which items fall within priority categories, establishing data collection processes for material composition, supply chain traceability, and environmental impact metrics, and evaluating existing IT systems for their ability to store, manage, and share DPP data. Businesses should also monitor the European Commission's work programme for updates on delegated act timelines and draft requirements.

Industry associations play a crucial role in the delegated act development process, and businesses should engage with relevant bodies to ensure that sector-specific requirements reflect practical manufacturing realities. The consultation periods for draft delegated acts provide formal opportunities for input, but informal engagement through trade associations often allows for earlier and more influential participation in the standard-setting process.

Finally, businesses should consider the competitive implications of ESPR compliance. Whilst the regulation imposes costs, it also creates opportunities to differentiate on sustainability credentials, access new markets, and build customer loyalty. Companies that embrace the transition proactively, rather than waiting until compliance deadlines loom, will be best positioned to capture these opportunities. For a comprehensive preparation framework, consult our step-by-step ESPR compliance checklist.