Sustainability & Circular Economy
Priority product groups in the first ESPR Working Plan
First product-group ecodesign requirements take effect
Typical compliance window after delegated act adoption
ESPR is the EU's framework regulation for making sustainable products the norm on the European market. It replaces the Ecodesign Directive 2009/125/EC and expands scope from energy-related products to virtually all physical goods—including components and intermediate products.
For supply chain and product compliance teams, ESPR introduces two core obligation types: performance requirements (durability, recyclability, recycled content, substance restrictions) and information requirements (Digital Product Passport, substances of concern disclosure, energy labeling). Each obligation is activated through product-group delegated acts adopted by the European Commission.
ESPR compliance requires granular product data—material composition, substances of concern, recycled content percentages, carbon footprint metrics—from suppliers across your value chain. When delegated acts are adopted, your portfolio must be assessed against new requirements within an 18-month compliance window.
Key Components / Sub-Frameworks
EU/EEA manufacturers of products covered by ESPR delegated acts
Importers placing covered products on the EU market
Distributors making covered products available in the EU
Non-EU companies selling through EU importers or authorized representatives
Companies assembling products from components subject to ESPR requirements
Economic operators discarding unsold consumer products
Key Thresholds
The ESPR Working Plan prioritizes iron, steel, aluminium, textiles, furniture, tyres, detergents, paints, lubricants, chemicals, and electronics. Each product group gets its own delegated act with unique requirements. Your compliance team must track multiple parallel timelines—with different data requirements for each.
A delegated act drops for your product group. You have 18 months to collect material composition data, recycled content percentages, durability metrics, and substances of concern declarations from every supplier in your chain. Supplier 1 has no recycled content data. Supplier 2 can't identify substances of concern. Month 16: your DPP data is still incomplete.
ESPR requires disclosure of substances of concern—including SVHCs, POPs, and substances inhibiting circularity. The definition covers over 12,000 substances. Your suppliers currently declare against REACH SVHCs only. The gap between what you have and what ESPR requires is massive—and delegated acts will define the exact scope per product group.
Every covered product needs a DPP containing verified sustainability data accessible via QR code or data carrier. Material composition, recycled content, carbon footprint, repair instructions, end-of-life guidance—all linked to a unique product identifier. Manual compilation across hundreds of suppliers and thousands of SKUs is not scalable.
Certivo In Action
ESPR Workflow
Electronics Manufacturing
Pain Point
ICT products prioritized; DPP, repairability scores, SoC disclosure
Automotive Manufacturing
Pain Point
Component materials (steel, aluminium) subject to early delegated acts
Industrial & Heavy Equipment
Pain Point
Iron and steel among first regulated product groups; legacy supply chains
Construction Materials
Pain Point
CPR/ESPR overlap; DPP for construction products; environmental declarations
Consumer Goods
Pain Point
Textiles priority group; unsold goods ban; high SKU counts; rapid cycles
Electrical Equipment
Pain Point
Energy labeling transition; repairability requirements; RoHS/ESPR overlap
Furniture & Home Goods
Pain Point
Furniture prioritized; durability, recyclability, and material composition data
Chemical Manufacturing
Pain Point
Chemicals and intermediates in scope; SoC disclosure; downstream data obligations
From Manual Data Collection to Automated Evidence
CORA collects and extracts supplier sustainability data automatically. Your team focuses on compliance decisions—not chasing material declarations and compiling DPP data fields.
Digital Product Passport Acceleration
Generate complete, verified DPP data packages in hours—not the months of manual compilation across suppliers and product lines.
Proactive ESPR Compliance Assurance
When the Commission adopts new delegated acts, Certivo identifies affected products and maps new requirements instantly. Know your compliance gaps before the 18-month countdown starts.
Key Statistics
Frequently Asked Questions
What products are covered by the EU ESPR?
ESPR covers virtually all physical products placed on the EU market, including components and intermediate products. Exemptions apply to food, feed, medicinal products, and certain vehicles already regulated by sector-specific legislation. Specific ecodesign requirements are activated through product-group delegated acts—the first Working Plan prioritizes iron, steel, aluminium, textiles, furniture, tyres, detergents, paints, lubricants, chemicals, and electronics. Certivo tracks all delegated act developments and maps them to your product portfolio.
What are the penalties for ESPR non-compliance?
EU member states are responsible for enforcement through market surveillance authorities. Non-compliant products can be removed from the EU market, and authorities can require corrective actions, recalls, or sales restrictions. Specific penalty structures are defined at the member-state level. Products without valid conformity assessment and CE marking cannot be legally placed on the EU market once delegated acts are in force.
What is the Digital Product Passport and when is it required?
The DPP is a digital record attached to each product via a QR code or data carrier, containing verified information about material composition, sustainability attributes, substances of concern, and end-of-life guidance. DPPs become mandatory per product group as delegated acts are adopted—first enforcement expected from 2027. The DPP registry will be operational by July 2026. CORA collects and structures supplier data into DPP-ready formats automatically.
How does Certivo help with ESPR supplier data collection?
Certivo launches automated campaigns to collect material composition, recycled content, substances of concern, and sustainability data from suppliers in any format and language. CORA extracts and validates the data against ESPR delegated act requirements, identifies gaps, and generates DPP-ready evidence packages. This reduces data collection timelines from months to weeks and assembly from weeks to hours.
How does ESPR relate to REACH and other EU product regulations?
ESPR's substances of concern requirements build on existing frameworks like REACH, POPs, and CLP—but extend the scope to include substances that inhibit circularity. ESPR also intersects with the EU Battery Regulation (battery passport), CSRD (corporate sustainability reporting), and CBAM (carbon border adjustment). Certivo validates supplier evidence against multiple frameworks simultaneously, eliminating duplicate collection campaigns and ensuring cross-regulation consistency.