This checklist covers every action required to comply with ESPR before placing a product on the EU market. Use it to track your compliance progress and identify gaps. The checklist is organised by phase: preparation, documentation, conformity, registration, and marking.
These actions should be completed before the delegated act for your product category is published. They are not legally required before publication, but they are practically essential — the compliance window after publication is 18–24 months, which is not enough time to complete them from scratch.
| Action | Why It Matters | Legal Basis |
|---|---|---|
| Determine whether your product is in scope of ESPR | Establishes whether ESPR applies to your product category | ESPR Article 2 |
| Identify the applicable delegated act (if published) or monitor the Working Plan | Identifies the specific requirements that will apply | ESPR Article 4; Working Plan |
| Conduct lifecycle carbon footprint assessment (ISO 14040/14044) | Carbon footprint data is required in the DPP for most product categories | ESPR Annex III(c) |
| Audit material composition (recycled content, critical raw materials, SVHC) | Material composition data is required in the DPP for all product categories | ESPR Annex III(b)(d) |
| Appoint EU Authorised Representative (non-EU manufacturers only) | Non-EU manufacturers cannot place products on the EU market without an Authorised Representative | ESPR Article 16 |
| Evaluate DPP hosting options (self-hosted vs registry service) | DPP infrastructure must be in place before the compliance date | ESPR Article 8; Article 13 |
Technical documentation must be compiled before placing the product on the EU market. ESPR Article 21 specifies the required content. The specific documentation requirements are defined in the applicable delegated act.
| Document | Content | Legal Basis |
|---|---|---|
| Product description and design drawings | General description of the product, its components, and its intended use | ESPR Article 21(1)(a) |
| Test reports | Test reports demonstrating compliance with all applicable ecodesign performance requirements | ESPR Article 21(1)(b) |
| Carbon footprint assessment | Lifecycle carbon footprint calculation per ISO 14040/14044 or EU PEF methodology | ESPR Annex III(c) |
| Material composition declaration | Material composition by weight, recycled content percentages, critical raw material content | ESPR Annex III(b) |
| Hazardous substance declaration | SVHC substances above 0.1% by weight threshold; REACH compliance declaration | ESPR Annex III(d); REACH |
| EU Declaration of Conformity | Formal declaration that the product meets all applicable ESPR requirements | ESPR Article 22 |
The conformity assessment verifies that the product meets all applicable ecodesign performance requirements. ESPR provides two procedures: Annex VI (internal production control) and Annex VII (management system). The applicable procedure is specified in the delegated act.
| Action | Annex VI | Annex VII |
|---|---|---|
| Internal testing of all performance requirements | ✓ Required | ✓ Required |
| Third-party notified body involvement | ✗ Not required | May be required |
| Quality management system documentation | ✗ Not required | ✓ Required |
| Production quality assurance procedures | ✓ Required | ✓ Required |
The DPP must be registered in the EU DPP Registry before the product is placed on the EU market. Registration requires: creating a DPP data record; uploading the DPP data to a compliant hosting infrastructure; and registering the DPP identifier in the EU DPP Registry.
| Action | Detail | Legal Basis |
|---|---|---|
| Create DPP data record | Compile all required Annex III data fields in machine-readable format (JSON-LD) | ESPR Article 8; Annex III |
| Host DPP data | Upload DPP data to self-hosted infrastructure or registry service | ESPR Article 8(3) |
| Register DPP in EU DPP Registry | Register DPP identifier and data URL in the EU DPP Registry | ESPR Article 13 |
| Generate QR code | Generate GS1 Digital Link QR code encoding the DPP identifier | ESPR Article 8(2) |
The final phase is to affix the CE marking and DPP QR code to the product or its packaging. Both must be affixed before the product is placed on the EU market.
| Marking | Requirement | Legal Basis |
|---|---|---|
| CE marking | Minimum 5mm height; affixed to product, packaging, or accompanying document; followed by last two digits of year affixed | ESPR Article 23 |
| DPP QR code | ISO/IEC 18004 compliant; encodes GS1 Digital Link URI; affixed to product where feasible, otherwise packaging | ESPR Article 8(2) |
This checklist covers the complete ESPR compliance process for manufacturers placing products on the EU market. The checklist applies to products in product categories where an ESPR delegated act is in force. For products in categories where no delegated act has yet been adopted, manufacturers should monitor the ESPR Working Plan and begin preparation when the delegated act is published.
| Task | Responsible | Lead Time |
|---|---|---|
| Identify applicable ESPR delegated act | Compliance team | Immediate |
| Appoint EU Authorised Representative (non-EU manufacturers) | Legal team | 1-3 months |
| Obtain GS1 company prefix and GTINs | Operations team | 2-4 weeks |
| Identify applicable harmonised standards | Technical team | 2-4 weeks |
| Conduct supply chain mapping | Supply chain team | 1-3 months |
| Begin supply chain data collection | Supply chain team | 3-12 months |
| Task | Responsible | Lead Time |
|---|---|---|
| Conduct product testing against ecodesign requirements | Technical team / test lab | 2-8 weeks |
| Calculate carbon footprint | Sustainability team | 4-12 weeks |
| Measure recycled content | Supply chain team | 2-8 weeks |
| Assess repairability | Product design team | 2-4 weeks |
| Identify substances of concern | Chemistry team | 2-8 weeks |
| Conduct Annex VII assessment (if required) | Notified body | 4-12 weeks |
| Task | Responsible | Lead Time |
|---|---|---|
| Compile technical documentation | Compliance team | 2-4 weeks |
| Create DPP data record in JSON-LD format | IT team / DPP service provider | 2-4 weeks |
| Register DPP with EPREL | IT team / DPP service provider | 1-4 weeks |
| Draw up EU Declaration of Conformity | Legal team | 1-2 weeks |
| Generate GS1 Digital Link QR codes | Operations team | 1-2 weeks |
| Affix QR codes to products | Manufacturing team | Per production run |
| Affix CE marking to products | Manufacturing team | Per production run |
The first phase of ESPR compliance is a thorough assessment of your current position. This assessment should cover: product portfolio mapping (which products are in scope for which delegated acts), supply chain data audit (what data do you currently collect, what data do you need to collect), technical documentation review (is your existing technical documentation sufficient for ESPR purposes), conformity assessment review (what conformity assessment procedures do you currently use, and are they sufficient for ESPR), and DPP infrastructure assessment (do you have the systems needed to create, store, and serve DPP data). The assessment should result in a gap analysis that identifies the specific actions needed to achieve ESPR compliance for each product category.
The preparation phase involves implementing the systems and processes needed to achieve ESPR compliance. Key actions in this phase include: appointing an EU Authorised Representative if you are a non-EU manufacturer, applying for a GS1 Company Prefix if you do not already have one, selecting a DPP platform or designing your self-hosted DPP system, implementing supply chain data collection systems to gather the data needed for the DPP, updating your product design processes to incorporate ESPR ecodesign requirements, updating your technical documentation to include ESPR-specific content, and engaging with your notified body if a third-party conformity assessment is required. This phase should begin at least 18 months before the compliance deadline for your product category.
The implementation phase involves deploying the DPP system, registering products in the EU product database, and updating product labels to include the DPP QR code. Key actions in this phase include: creating DPP records for all products in scope, registering products in the EU product database, printing QR codes on product labels and packaging, conducting QR code quality testing, updating the EU Declaration of Conformity to reference the ESPR delegated act, and training sales and customer service teams on the DPP requirements. This phase should begin at least 6 months before the compliance deadline to allow time for testing and correction of any issues identified during implementation.
ESPR compliance is not a one-time exercise — it requires ongoing monitoring and maintenance. Key ongoing compliance activities include: monitoring the EU Official Journal for new delegated acts and amendments to existing delegated acts that affect your product categories; updating DPP data when product designs change, components are substituted, or new substances of concern are identified; renewing conformity assessments when the delegated act requirements change; maintaining the technical documentation and ensuring it is accessible to market surveillance authorities on request; and monitoring market surveillance authority enforcement activities in your key EU markets. Manufacturers should appoint an ESPR compliance manager who is responsible for monitoring regulatory developments and coordinating compliance activities across the organisation.
Small and medium-sized enterprises (SMEs) face particular challenges in complying with ESPR — they typically have fewer resources for compliance activities than large manufacturers, and the DPP implementation costs represent a higher proportion of their revenue. The ESPR regulation includes provisions for simplified conformity assessment procedures for SMEs, and the EU Commission has committed to providing SME-specific guidance and support tools. EU member states are required to provide SME support services for ESPR compliance, including: free or subsidised access to testing and certification services, simplified technical documentation templates, and guidance on DPP implementation. SMEs should engage with their national SME support agency (such as Enterprise Europe Network) and their sector trade association to access the support available to them.
The ESPR compliance checklist is a structured list of actions that manufacturers must complete to comply with ESPR. It covers: determining product scope, compiling technical documentation, conducting conformity assessment, issuing the EU Declaration of Conformity, registering the DPP, and affixing CE marking and QR code.
Now. The EU DPP Registry goes live on 19 July 2026. The Battery Passport is mandatory from 18 February 2027. For most product categories, the compliance window after delegated act publication is 18–24 months. Starting preparation now ensures you are ready when the delegated act for your product category is published.
Waiting for the delegated act to be published before starting preparation. By the time the delegated act is published, you have 18–24 months to comply. That is not enough time to conduct lifecycle carbon footprint assessments, audit material composition, establish DPP infrastructure, and appoint an Authorised Representative from scratch.
ESPR compliance is primarily a technical and operational challenge, not a legal one. Most manufacturers can comply without legal advice by following the delegated act requirements. Legal advice may be needed for complex supply chain issues, Authorised Representative agreements, or enforcement proceedings.
ESPR compliance means meeting all requirements by the applicable compliance date. ESPR readiness means having the infrastructure, data, and processes in place to achieve compliance before the compliance date. Readiness must precede compliance by at least 6–12 months to allow time for testing, registration, and QR code affixing.
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Products without a valid DPP can be refused entry. Register now at Africa's first ESPR-compliant DPP registry.
Register Your Digital Product Passport →