ESPR Labelling Requirements Beyond Digital Passports

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Introduction to ESPR Labelling

While much attention has focused on the digital product passport as the centrepiece of the Ecodesign for Sustainable Products Regulation (ESPR), the regulation's labelling requirements are considerably broader and more nuanced than many businesses realise. The ESPR establishes a multi-layered information framework that combines digital and physical labelling to ensure consumers, recyclers, and other stakeholders have access to the sustainability information they need.

Physical labelling under the ESPR serves complementary purposes to the digital product passport. Where the DPP provides comprehensive, machine-readable data accessible through a data carrier, physical labels deliver immediate, at-a-glance information that influences purchasing decisions and end-of-life handling. Understanding the full scope of these requirements is essential for businesses preparing for compliance.

This guide examines the labelling requirements that exist alongside and beyond the digital product passport, helping businesses develop a complete labelling strategy that meets all ESPR obligations.

The ESPR Labelling Framework

The ESPR establishes a framework under which delegated acts may require various types of labels and information disclosures for specific product categories. The regulation does not impose a single, universal label but instead empowers the European Commission to define labelling requirements tailored to each product group through delegated acts.

The labelling framework encompasses several distinct elements:

• Product labels affixed directly to the product or its packaging, containing key sustainability and performance information
• Energy labels for products with significant energy consumption, building on the existing EU Energy Labelling Regulation
• Product information sheets providing detailed technical data not suitable for inclusion on physical labels
• Point-of-sale information requirements for both physical retail and online sales channels
• Data carrier requirements (such as QR codes) linking to the digital product passport
• Marking requirements including the CE marking and any additional compliance marks

Each delegated act will specify which of these elements apply to the product category in question, along with detailed formatting, content, and placement requirements. Businesses must therefore monitor the development of delegated acts relevant to their products to understand their specific obligations.

Physical Product Labels

Physical product labels under the ESPR may be required to display a range of sustainability-related information. The specific content will vary by product category, but the regulation identifies several types of information that delegated acts may mandate for inclusion on physical labels.

These include performance class indicators (such as durability or reparability ratings presented on a scale from A to G), recycled content percentages, material composition information relevant to end-of-life handling, the product's carbon footprint expressed in a standardised format, and information about the presence of substances of concern.

The design and formatting of physical labels will be specified in delegated acts to ensure consistency and consumer recognition across the EU market. This includes requirements for colour schemes, typography, iconography, and minimum label dimensions. Businesses will need to integrate these label specifications into their packaging design processes, which may require modifications to existing packaging formats.

It is important to note that physical labels must be durable and legible throughout the product's expected lifespan where they are affixed to the product itself, rather than just the packaging. This presents particular challenges for products that undergo regular cleaning, exposure to weather, or other conditions that may degrade label quality. Businesses should consider label materials and attachment methods carefully.

Energy Labels and the Rescaling Challenge

For products covered by energy labelling requirements, the ESPR works in conjunction with the EU Energy Labelling Regulation (EU) 2017/1369. The energy label remains one of the most recognisable and impactful consumer information tools in the EU, and the ESPR extends its principles to additional product categories and performance parameters beyond energy efficiency.

The familiar A-to-G colour-coded scale may be applied not only to energy consumption but also to other performance parameters such as durability, reparability, or water consumption, depending on the product category. This represents a significant expansion of the labelling approach that consumers already understand from appliances and electronics.

Businesses that currently produce energy-labelled products should be aware that the ESPR may trigger rescaling exercises, where the performance classes are recalibrated to reflect technological progress. A product currently rated as Class A may find itself reclassified following a rescaling, which requires updated labels and marketing materials. The process for rescaling is defined in the Energy Labelling Regulation but may be triggered by ESPR delegated acts.

For product categories newly brought under performance class labelling by the ESPR, businesses will need to establish testing and classification processes from scratch. This includes identifying accredited testing facilities, understanding the relevant harmonised standards, and integrating label generation into production workflows.

Product Information Sheets

Product information sheets complement physical labels by providing more detailed technical information that cannot be practically displayed on a label. Under the ESPR, delegated acts may require manufacturers to produce and make available product information sheets containing comprehensive sustainability and performance data.

These sheets typically include detailed performance parameter values with testing methodology references, information about materials used and their recyclability, instructions for maintenance, repair, and end-of-life handling, environmental impact data including carbon footprint calculations, and information about spare parts availability and ordering. The product information sheet must be provided in the official languages of the member states where the product is placed on the market.

Under the ESPR, product information sheets may be provided in digital format, linked from the digital product passport or accessible via the data carrier on the product. However, delegated acts may still require that paper copies be available upon request or included with certain product types. Businesses should design their information sheet production processes to accommodate both digital and physical distribution.

The relationship between the product information sheet and the digital product passport is important to understand. While there is overlap in the data they contain, they serve different purposes and audiences. The DPP is a structured, machine-readable data repository, while the product information sheet is a human-readable document designed for consumer comprehension. Businesses should ensure consistency between the two but recognise that they are distinct compliance obligations as outlined in the ESPR regulation.

Point-of-Sale Information Requirements

The ESPR places specific requirements on the information that must be available to consumers at the point of sale, whether in physical retail environments or on online platforms. These requirements aim to ensure that sustainability information influences purchasing decisions rather than being discovered only after purchase.

In physical retail settings, products covered by labelling requirements must display their labels visibly. Where products are displayed in packaging that obscures the label, retailers may be required to reproduce labelling information on shelf displays or other point-of-sale materials. Delegated acts may specify the minimum visibility and proximity requirements for labels in retail environments.

For online sales, the requirements are particularly detailed. Online product listings must display label images in a specified format and size, key performance parameters must be visible without requiring the consumer to navigate away from the main product page, the data carrier providing access to the digital product passport must be accessible from the product listing, and any sustainability claims made in the listing must be consistent with the information in the DPP and labels.

Online marketplaces bear specific responsibilities under the ESPR to ensure that sellers on their platforms comply with information requirements. This creates a shared responsibility between manufacturers and platform operators, and businesses selling through marketplaces should proactively provide all required information and assets to facilitate compliance. Understanding the full compliance checklist helps ensure no labelling obligation is overlooked.

CE Marking and Conformity Documentation

The CE marking remains a fundamental requirement for products placed on the EU market, and the ESPR does not replace but rather supplements existing CE marking obligations. Products covered by ESPR delegated acts will need to carry the CE marking to indicate conformity with all applicable EU harmonised legislation, including the ESPR itself.

The CE marking must be affixed to the product in a visible, legible, and indelible manner. Where this is not possible due to the nature of the product, it must be affixed to the packaging and accompanying documents. The size, proportions, and placement of the CE marking are governed by existing EU legislation, and the ESPR does not modify these requirements.

Alongside the CE marking, businesses must prepare and maintain a declaration of conformity covering ESPR requirements. This declaration forms part of the broader conformity assessment documentation and must be available to market surveillance authorities upon request. The declaration must reference the specific delegated acts with which the product complies.

For products that are also subject to other EU directives and regulations requiring CE marking, the ESPR requirements are additive. The declaration of conformity may need to reference multiple pieces of legislation, and the technical documentation must cover all applicable requirements. This integrated approach to conformity assessment requires businesses to coordinate across regulatory requirements.

Language Requirements and Multi-Market Compliance

One of the practical challenges of ESPR labelling is managing language requirements across the EU's 24 official languages. Products placed on the market in a specific member state must generally provide labelling information in the official language or languages of that state. This requirement applies to physical labels, product information sheets, and online product listings.

The digital product passport offers some relief from the language challenge, as it can accommodate multilingual content more easily than physical labels. However, physical labels and printed information sheets must still be produced in the appropriate languages for each market. Businesses selling across multiple EU markets may need to produce market-specific packaging or use multilingual label formats where space permits.

Standardised icons and pictograms, which are expected to feature prominently in ESPR labelling, can help reduce language dependencies. The European Commission is developing harmonised visual symbols for common sustainability attributes, and these symbols are designed to communicate effectively without text. Businesses should adopt these standardised symbols as they become available.

For businesses managing complex multi-market labelling requirements, digital label management systems integrated with the digital product passport platform can provide significant efficiencies. These systems can generate market-specific labels and information sheets from a central data repository, ensuring consistency while accommodating local language and regulatory requirements.

Preparing Your Labelling Strategy

Developing a comprehensive ESPR labelling strategy requires early planning and cross-functional coordination. Labelling touches product design, packaging, supply chain, marketing, and regulatory affairs, making it essential to establish clear responsibilities and processes well before compliance deadlines arrive.

Start by mapping all labelling requirements that apply or are likely to apply to your product portfolio. Review existing and draft delegated acts, monitor the European Commission's ESPR updates, and engage with industry associations that participate in stakeholder consultations. Understanding requirements early allows you to influence packaging redesign timelines and avoid costly last-minute changes.

Invest in systems that integrate labelling with your digital product passport infrastructure. The data that populates your labels should flow from the same verified source as your DPP data, ensuring consistency and reducing the risk of discrepancies that could trigger enforcement action. Tools like MyProductPassport can help centralise your product sustainability data for use across both digital and physical labelling requirements.

Finally, establish quality control processes specifically for labelling compliance. This includes pre-production label reviews against delegated act specifications, post-production verification that labels are correctly applied and legible, periodic audits of online product listings for information completeness, and processes for updating labels when performance data changes or rescaling occurs. A disciplined approach to labelling compliance will significantly reduce the risk of market surveillance issues and demonstrate your commitment to transparency.