Dishwashers: ESPR Requirements, Existing Ecodesign Rules, and DPP Compliance Guide

Existing Ecodesign Requirements for Dishwashers

Commission Regulation (EU) 2019/2022 entered into force on 1 March 2021. It sets the following mandatory requirements for dishwashers placed on the EU market:

Expected DPP Data Fields for Dishwashers

Based on ESPR Annex III data categories and the existing ecodesign regulation, the dishwasher DPP is expected to require the following data fields:

What the ESPR Delegated Act Will Add

The existing Ecodesign Regulation (EU) 2019/2022 covers energy efficiency, water consumption, noise, and spare parts. The ESPR delegated act for dishwashers will add requirements that the existing regulation does not cover:

• Digital Product Passport: A machine-readable QR code linking to the DPP data record. This is the most significant new requirement for manufacturers already compliant with the existing regulation.
• Recycled content disclosure: The percentage of recycled plastics, metals, and other materials in the dishwasher. This requires a material composition audit and supply chain data collection.
• Carbon footprint: The lifecycle carbon footprint of the dishwasher, calculated using ISO 14040/14044 methodology. This requires a lifecycle assessment (LCA) study.
• Enhanced repairability requirements: The existing regulation requires spare parts availability. The ESPR delegated act may add a repairability score requirement, similar to the French repairability index.
• Substance of concern disclosure: The location of SVHC substances within the dishwasher. This requires cooperation from component suppliers.

Compliance Preparation Checklist for Dishwasher Manufacturers

1. Verify compliance with existing Regulation (EU) 2019/2022: Confirm energy efficiency class, water consumption, noise levels, and spare parts availability meet current requirements.
2. Conduct lifecycle carbon footprint assessment: Use ISO 14040/14044 methodology. Focus on manufacturing phase (materials, production energy) and use phase (energy and water consumption over product lifetime).
3. Audit recycled plastic content: Determine the percentage of recycled plastics in the dishwasher casing, inner tub, and components. Engage supply chain for data.
4. Map SVHC substance locations: Identify SVHC substances (if any) in components and their locations within the product.
5. Prepare DPP data template: Create a DPP data template for each dishwasher model, populating all required Annex III fields.
6. Select DPP registry service: Evaluate DPP registry service providers. For appliance manufacturers with multiple product lines, a single provider for all appliances is most efficient.

The EU Appliance Market: Context for Dishwasher Manufacturers

The EU sells approximately 15 million dishwashers per year. The largest manufacturers are Bosch/Siemens (Germany), Electrolux (Sweden), Whirlpool (US/Italy), Miele (Germany), and Samsung (South Korea). A significant proportion of dishwashers sold in the EU are manufactured in Turkey, Poland, and China. All manufacturers — regardless of manufacturing location — must comply with ESPR requirements for products placed on the EU market.

The existing Ecodesign Regulation (EU) 2019/2022 has already driven significant improvements in dishwasher energy and water efficiency. The ESPR delegated act will build on this foundation, adding transparency requirements (DPP) and circular economy requirements (recycled content, end-of-life). Manufacturers who have already invested in sustainable design will have a lower compliance burden.

Dishwashers Under ESPR: Building on Existing Ecodesign Requirements

Dishwashers are currently subject to the Ecodesign Regulation for dishwashers (Regulation (EU) 2019/2022), which sets minimum energy efficiency, water efficiency, and repairability requirements. The ESPR dishwasher delegated act will replace this regulation and add the Digital Product Passport requirement. Manufacturers compliant with Regulation (EU) 2019/2022 will need to add DPP registration and collect new data fields (recycled content, carbon footprint) when the ESPR delegated act enters into force.

Dishwasher DPP: Expected Data Fields

Water Efficiency: A Growing Priority

Water efficiency is increasingly important in ESPR requirements as the EU faces water stress in southern member states. The ESPR dishwasher delegated act is expected to tighten water efficiency requirements beyond those in Regulation (EU) 2019/2022. Manufacturers should ensure their products meet the highest water efficiency class (A) to remain competitive in the EU market as water efficiency requirements tighten. The DPP will make water consumption data publicly accessible, enabling consumers to compare products on water efficiency.

Non-EU Dishwasher Manufacturers

Major dishwasher markets outside the EU include China, Turkey, and South Korea. Manufacturers in these countries who export dishwashers to the EU must comply with the ESPR dishwasher delegated act from its mandatory compliance date. Turkish dishwasher manufacturers (Arçelik, Vestel) who export to the EU are already familiar with EU ecodesign requirements and should be well-positioned to add DPP registration when required. Chinese manufacturers who are newer to the EU market should begin ESPR compliance preparation now.