The ESPR regulation decides when each product you sell in the EU needs a Digital Product Passport and what goes in it. Textiles come first, with the delegated act expected in 2027. Large companies may not destroy unsold apparel and footwear since 19 July 2026. Most of the data a passport needs sits with your suppliers, not in your PLM.
Key takeaways
Market access: once your product group's delegated act applies, a product without a valid Digital Product Passport cannot be placed on the EU market. Textiles are expected first, in 2027.
Unsold goods: since 19 July 2026 large companies may not destroy unsold apparel and footwear, and must publish what they discard each year. Medium-sized companies follow on 19 July 2030.
Customs: Article 13 creates an EU passport registry linked to the customs single window, EU CSW-CERTEX. An unregistered passport stops the shipment at the border.
Data: a passport needs structured data on materials, durability, repairability, recycled content and substances of concern. Most of it sits with suppliers, not in your own systems.
What is the ESPR regulation?
The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, entered into force on 18 July 2024. It replaces the Ecodesign Directive, which covered energy-related products, with rules the Commission can apply to almost any physical product sold in the EU.
The ESPR regulation itself sets no product rule. It creates the tools. A Digital Product Passport per product, a ban on destroying unsold consumer goods, and delegated acts that fix the requirements for one product group at a time. It binds whoever places the product on the EU market, wherever the product was made.
ESPR is the widest of the EU product rules in these guides. The Textile Labelling Regulation and the Empowering Consumers Directive ask for pieces of the same data.
Where ESPR stands
ESPR is in force. The first working plan, adopted in April 2025, names textiles and apparel, furniture, tyres, mattresses, iron, steel and aluminium as the first product groups. No delegated act has been adopted yet; the textile act is expected in 2027.
The ban on destroying unsold apparel and footwear applies to large companies since 19 July 2026. Sector detail sits in the guides: Digital Product Passports for textiles and ESPR for furniture.
The Digital Product Passport registry and customs enforcement
Once your product group's act applies, a product reaches the EU market only if its passport is registered first. Article 13 of Regulation (EU) 2024/1781 creates a central EU Digital Product Passport registry, connected to the customs single window, EU CSW-CERTEX.
At the border the check is automatic: a registered passport clears, an unregistered one is held or refused. For your team that means the passport has to exist, with its identifier, before the shipment leaves the factory, not after the goods have landed.
How the DPP data flow works
Brand / Manufacturer
Compiles product data, creates the DPP, and assigns a unique product identifier linked to a data carrier (QR code or NFC tag).
EU DPP Registry
Stores and validates all DPP records centrally. Accessible to market surveillance authorities, customs, and consumers.
EU Customs (CSW-CERTEX)
Automated border checks verify each product has a valid, registered DPP. Non-compliant shipments are flagged or refused entry.
ESPR requirements: what applies to every product
ESPR works through four requirement blocks: the Digital Product Passport, the ban on destroying unsold goods, substances of concern, and performance and information requirements. Which of them apply to your products, and with which data fields, is fixed by your product group's delegated act. Until that act is adopted, the blocks below tell you what to expect and what evidence each one will ask for.
Terms to know · Delegated Act
The legal instrument that turns ESPR's framework into concrete rules for one product category, including its DPP requirements and dates.
The ESPR Digital Product Passport
Terms to know · Digital Product Passport
A structured, machine-readable dataset attached to a physical product via a QR code or NFC tag, containing its full sustainability and compliance data.
Every product under a delegated act carries a Digital Product Passport: a structured, machine-readable record reached from a QR code, NFC tag or RFID label on the product. It holds materials, origin, durability, repairability, recycled content, end-of-life handling and a unique identifier.
Group by group, as each delegated act is adopted. Textiles, iron and steel are expected first, from 2027.
Map every style to the group it will fall under. Give each one an identifier that resolves to a live passport. Build the pipeline that fills every field, season after season, from the systems and suppliers that hold the data.
Bill of materials, recycled content percentages, durability and repairability scores, substance declarations, manufacturing origin, identifiers conforming to ISO/IEC 15459, and end-of-life instructions.
Regulation (EU) 2024/1781, Articles 9-12, Annex III
In Tappr the passport is published from Passport Builder, and its evidence is retrieved from Brand Cloud, not assembled from inboxes the week the authority writes.
Ban on destruction of unsold products and disclosure rules
Economic operators may not destroy unsold consumer products, starting with apparel, clothing accessories and footwear. Each year they must publish how many unsold products they discarded, their weight, why, and what they did to avoid it.
19 July 2026 for large enterprises. 19 July 2030 for medium-sized enterprises. Micro and small enterprises are exempt.
Know your unsold stock per style before the season closes. Route it to resale, donation or recycling channels you can document. Publish the annual disclosure on your website.
Annual inventory of unsold stock by quantity and weight, records of each disposal channel, and the public disclosure statement.
Regulation (EU) 2024/1781, Article 25
Substances of concern: disclosed per product, tracked per supplier
Products must declare the substances of concern they contain: REACH candidate-list substances (SVHCs), substances restricted under REACH Annex XVII, and any the delegated act names as hindering recycling. The declaration sits in the passport, readable by consumers, recyclers and authorities.
Per product group, in the same delegated act that sets the passport fields.
Audit the full bill of materials for regulated substances. Ask suppliers for full material disclosure per component, and ask again each time a component changes.
Chemical composition per component, SCIP notifications for articles containing SVHCs, supplier declarations, and lab results where the act requires them.
Regulation (EU) 2024/1781, Article 7(2)(b), Annex I
Performance and information requirements: set per product group by delegated act
Delegated acts may set minimum levels for durability, reliability, reusability, upgradability, repairability, energy and water use, recycled content, and the ability to remanufacture and recycle. Information requirements make you disclose an attribute even where no minimum applies.
Per product group. The first working plan, adopted in April 2025, sets the order and the timing.
Test your products against the parameters likely for your group before the act lands. Read the working plan for the order and the measures it names.
Test results for durability, reliability and repairability, recycled content certificates, energy and resource data, and a declaration of conformity referencing the delegated act.
Regulation (EU) 2024/1781, Articles 5-7, Annex I
What the Ecodesign for Sustainable Products Regulation means for textiles, furniture and heavy industry
Each delegated act fixes the fields for one product group. Textiles come first. The expected fields are fibre composition, country of manufacture, durability measures such as pilling and dimensional stability, repair information and recycled content. The unsold-goods ban already applies since 19 July 2026 for large companies and 19 July 2030 for medium-sized ones. See the apparel page and the textiles guide.
Textiles and footwear
Iron and steel are expected in the same first wave, with recycled content, carbon footprint and recyclability tied to production batches.
Iron and steel
Furniture is on the priority list, with durability testing, repairability scores, substances such as flame retardants, and recycled content expected. A piece that combines wood, metal, textile and foam carries a field set per material. See the furniture page and the furniture guide.
Furniture
Tyres, detergents, paints, lubricants, electronics and batteries follow, each with its own act. The battery passport applies from 18 February 2027 under the Battery Regulation.
Other priority categories
ESPR timeline: what applies when
Two dates already bind you. ESPR entered into force on 18 July 2024. The ban on destroying unsold apparel and footwear began for large companies on 19 July 2026. The rest arrives group by group. Textiles are expected first.
ESPR enters into force
Regulation (EU) 2024/1781 is published and enters into force. The framework for Digital Product Passports and ecodesign requirements is established.
Commission adopts first working plan
The Commission publishes its first working plan prioritising which product categories will receive delegated acts first and the expected timelines.
Ban on destruction of unsold apparel (large companies)
Large enterprises are banned from destroying unsold apparel and footwear. Annual public disclosure of unsold stock volumes becomes mandatory.
Ban extends to medium enterprises
The prohibition on destroying unsold consumer products extends to medium-sized enterprises.
Sector-specific delegated acts
Delegated acts are adopted one product group at a time. Textiles and apparel, furniture, tyres, mattresses, iron and steel, and aluminium are in the first working plan. Each act sets its own passport fields, performance levels and application date.
What to have in place before your delegated act
The delegated act fixes the fields; it does not change the plumbing. These five steps are the same whatever your group's act says.
Map your product portfolio against ESPR categories
Sort every style into the product group it will fall under, and follow the working plan for that group's timing.
Audit your product data readiness
Check which passport fields you can already fill: materials, recycled content, durability scores, substance declarations, end-of-life instructions.
Establish supplier data pipelines
Decide how substance, material and performance data will come from suppliers every season. Email threads do not hold across thousands of SKUs.
Implement unsold product tracking
If you sell apparel or footwear, count unsold stock per style and record each disposal route now; the ban and the disclosure already apply.
Choose your DPP infrastructure partner
Pick the platform that will generate, host and register the passports, with GS1 Digital Link carriers and a route to the EU registry.
Data and suppliers: what you must track
A passport is only as complete as the data behind it. The table sets what the regulation requires against what a supplier-fed system holds for you.
What ESPR means for your team, season after season
The risk under ESPR is not the ecodesign levels. It is the volume of structured data every product needs, collected, kept current and published, for every SKU and every season.
One missing field means no valid passport, and no passport means no EU market for that product once its act applies. What has to be in place:
- Passports generated, not typed: from the ERP, PIM and PLM records you already keep, one template across the range.
- A GS1 Digital Link carrier per product: a QR code or NFC identifier in the format ESPR points to.
- Supplier data from a link, every season: so your team approves instead of chases.
- Passport records ready to register: the day the EU registry opens.
- A scan the customer uses: provenance, care and sustainability data in your brand.
The first act is expected in 2027. Building the pipeline takes a season; filling it from suppliers takes longer.
ESPR questions, answered
Do I need a Digital Product Passport right now?
Does ESPR apply to products made outside the EU?
What happens if I do not comply with ESPR?
What is the ESPR timeline?
What are ESPR delegated acts?
Which products come first under ESPR?
Official sources
All claims, guidelines, and compliance frameworks in this document are drawn directly from the following official European Union legislative acts and institutional resources:
- Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for setting ecodesign requirements for sustainable products (ESPR)
- European Commission: Ecodesign for Sustainable Products Regulation overview
- European Commission: Digital Product Passport: overview and implementation
- European Parliament Legislative Train Schedule: Sustainable Products Initiative (ESPR)