ESPR (Regulation (EU) 2024/1781) replaced the Ecodesign Directive (2009/125/EC) from 19 July 2026. The core energy efficiency requirements remain, but ESPR adds a Digital Product Passport requirement, broader sustainability data obligations, and a new enforcement architecture. This is not a minor update — it is a fundamental expansion of scope.
| Factor | Ecodesign Directive 2009/125/EC | ESPR Regulation (EU) 2024/1781 |
|---|---|---|
| Legal instrument | Directive (requires national transposition) | Regulation (directly applicable in all member states) |
| Primary focus | Energy efficiency and product performance | Full lifecycle sustainability + Digital Product Passport |
| Digital Product Passport | Not required | Mandatory for all products in scope of applicable delegated act |
| QR code requirement | Not required | Mandatory — QR code must resolve to DPP data record |
| Recycled content requirements | Not required | May be required by delegated act |
| Repairability requirements | Limited (some implementing regulations) | Comprehensive — repair information in DPP |
| Hazardous substance declarations | Not required (REACH applies separately) | SVHC declarations in DPP |
| Customs enforcement | No automated customs verification | Automated DPP verification from 19 July 2026 |
| Data retention | 10 years for technical documentation | Product lifetime + 10 years for DPP data |
| Product scope | Energy-related products only | Almost all physical products |
The existing Ecodesign regulations adopted under the Ecodesign Directive (2009/125/EC) remain in force after ESPR enters into application. ESPR does not repeal the Ecodesign Directive or the regulations adopted under it — instead, ESPR provides the framework for new and revised ecodesign regulations going forward. The existing regulations (for washing machines, dishwashers, refrigerators, televisions, lighting, motors, and other products) will continue to apply until they are revised or replaced by new regulations adopted under ESPR. The revision process will incorporate the new ESPR requirements — particularly the Digital Product Passport and the expanded set of ecodesign parameters — into the revised regulations.
| Aspect | Ecodesign Directive (2009/125/EC) | ESPR (EU 2024/1781) |
|---|---|---|
| Legal instrument | Directive (requires national transposition) | Regulation (directly applicable) |
| Product scope | Energy-related products only | All physical products (with exceptions) |
| Ecodesign parameters | Primarily energy efficiency | 12 parameters including durability, repairability, recycled content, carbon footprint |
| Digital Product Passport | Not required | Mandatory for all covered products |
| Substances of concern | Limited provisions | Comprehensive disclosure requirements |
| Delegated acts | Commission Regulations | Commission Delegated Regulations |
| Market surveillance | Member state authorities | Harmonised EU-level coordination |
During the transition period — from ESPR's entry into force (July 2024) until the existing Ecodesign regulations are revised under ESPR — manufacturers of products covered by existing Ecodesign regulations must comply with both the existing regulation and any new ESPR requirements that apply to their product category. For example, manufacturers of washing machines must continue to comply with Regulation (EU) 2019/2023 (the Ecodesign regulation for washing machines) while also preparing for the ESPR DPP requirements that will apply when the washing machine regulation is revised under ESPR. The EU Commission has indicated that the revision of existing Ecodesign regulations under ESPR will be prioritised based on the environmental impact of the product category and the readiness of the DPP infrastructure.
The transition from the Ecodesign Directive (2009/125/EC) to ESPR (EU 2024/1781) is a phased process. Existing implementing measures adopted under the Ecodesign Directive remain in force until they are revised or replaced by ESPR delegated acts. Manufacturers of products covered by existing Ecodesign implementing measures (such as washing machines, dishwashers, refrigerators, televisions, lighting products, and motors) must continue to comply with the existing requirements while also preparing for the additional ESPR requirements (DPP, expanded ecodesign parameters, repairability) that will be introduced when the implementing measures are revised. The EU Commission has committed to revising all existing Ecodesign implementing measures under ESPR by 2030.
ESPR introduces several significant new requirements that were not present in the Ecodesign Directive. The most important new requirements are: the Digital Product Passport (DPP), which requires manufacturers to provide machine-readable product information via a data carrier on the product; the repairability score, which requires manufacturers to assess and disclose the repairability of their products; the recycled content disclosure, which requires manufacturers to disclose the percentage of recycled materials in their products; the carbon footprint disclosure, which requires manufacturers to calculate and disclose the lifecycle carbon footprint of their products; and the substances of concern disclosure, which requires manufacturers to disclose the presence of hazardous substances in their products. These new requirements represent a significant expansion of the compliance burden for manufacturers of products already covered by the Ecodesign Directive.
The EU Energy Label Regulation (EU 2017/1369) requires energy-related products to display an energy efficiency label showing the product's energy efficiency class (A–G) and other key performance parameters. The Energy Label and ESPR DPP are complementary instruments — the Energy Label provides a simplified, consumer-facing summary of the product's energy performance, while the DPP provides comprehensive, machine-readable product information for all stakeholders. The DPP for energy-related products will include the energy efficiency class and other Energy Label parameters, making the DPP a superset of the Energy Label data. Manufacturers of energy-related products should ensure that their ESPR DPP implementation is consistent with their Energy Label compliance programme.
Yes. ESPR Article 73 repeals the Ecodesign Directive (2009/125/EC) from 19 July 2026. Existing implementing regulations adopted under the Ecodesign Directive remain in force until replaced by ESPR delegated acts.
Yes. ESPR Article 73(2) states that implementing regulations adopted under the Ecodesign Directive remain in force and are treated as ESPR delegated acts until they are replaced. Manufacturers must continue to comply with existing implementing regulations.
The biggest change is the Digital Product Passport requirement. The Ecodesign Directive focused on energy efficiency and product performance. ESPR adds comprehensive sustainability data requirements, including recycled content, hazardous substances, repairability, and end-of-life information — all accessible via a QR code.
No. CE marking was required under the Ecodesign Directive and remains required under ESPR. The format and placement requirements are unchanged. The key addition is the DPP QR code, which must be affixed alongside the CE marking.
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 →The Ecodesign Directive (2009/125/EC) established a framework for setting energy-related ecodesign requirements for specific product categories through implementing measures. Each implementing measure was a separate regulation that set specific requirements for a specific product category (washing machines, refrigerators, televisions, etc.). The Ecodesign Directive focused primarily on energy efficiency — it was designed to reduce energy consumption by products in use.
ESPR (Regulation (EU) 2024/1781) replaces the Ecodesign Directive with a broader framework that covers all aspects of product sustainability — not just energy efficiency. ESPR covers material efficiency, durability, repairability, recycled content, substances of concern, carbon footprint, and the Digital Product Passport. ESPR also extends to all physical products placed on the EU market, not just energy-related products. This is a fundamental expansion of scope.
| Dimension | Ecodesign Directive (2009/125/EC) | ESPR (EU 2024/1781) |
|---|---|---|
| Scope | Energy-related products only | All physical products (with limited exceptions) |
| Focus | Energy efficiency in use | Full lifecycle sustainability |
| Digital Product Passport | Not required | Mandatory for regulated product categories |
| Recycled content | Not addressed | Mandatory data field in DPP |
| Repairability | Limited (spare parts availability) | Comprehensive (repairability score, repair manuals) |
| Supply chain data | Not required | Required in DPP for critical raw materials |
| Secondary legislation | Implementing measures (regulations) | Delegated acts (regulations) |
| Transition | Existing measures remain valid until replaced | Replaces Ecodesign Directive; existing measures continue |
ESPR Article 79 provides that existing Ecodesign Directive implementing measures remain in force until they are replaced by ESPR delegated acts. This means that manufacturers of products currently subject to Ecodesign Directive implementing measures (washing machines, refrigerators, televisions, lighting products, etc.) must continue to comply with those measures. The transition to ESPR delegated acts will happen gradually over the period 2025-2030.
When an ESPR delegated act replaces an Ecodesign Directive implementing measure, the delegated act will typically include a transition period during which both the old implementing measure and the new delegated act are in force. This allows manufacturers time to adapt their products and compliance systems to the new requirements. The transition period is specified in each delegated act.
ESPR covers many product categories that were not previously subject to Ecodesign Directive requirements — including textiles, furniture, construction products, chemicals, and packaging. For manufacturers in these sectors, ESPR represents an entirely new regulatory framework with no precedent to draw on. These manufacturers must build ESPR compliance systems from scratch, without the benefit of experience with the Ecodesign Directive.
The repairability requirements under ESPR represent the most significant new compliance burden for manufacturers of consumer electronics, household appliances, and other durable goods. Under ESPR, manufacturers must: make spare parts available for at least 7–10 years after the last product of the model is placed on the market; make repair and maintenance instructions available to independent repairers; design products to be disassembled without specialised tools; and provide a repairability score that summarises the product's repairability on a scale of 1–10. The repairability score methodology is specified in the applicable delegated act and is based on a standardised assessment of the product's disassembly ease, spare parts availability, repair documentation quality, and software update policy. Manufacturers should conduct a repairability assessment of their product portfolio now — many products will require design changes to achieve a satisfactory repairability score, and these design changes take time to implement.
The Right to Repair Directive (EU 2024/1799), adopted in June 2024, complements ESPR by requiring manufacturers to repair products within the legal guarantee period and to provide spare parts and repair services for products after the guarantee period. The Right to Repair Directive applies to a specific list of product categories (washing machines, dishwashers, televisions, smartphones, tablets, laptops, and bicycles) and requires manufacturers to offer repair as an alternative to replacement when a product fails within the legal guarantee period. Manufacturers of products covered by both ESPR and the Right to Repair Directive face a double compliance burden — they must meet both the ESPR repairability requirements and the Right to Repair Directive's repair service requirements. Manufacturers should develop a unified repairability strategy that addresses both sets of requirements simultaneously.
Manufacturers that currently comply with the Ecodesign Directive should note that ESPR does not automatically repeal or replace the existing Ecodesign Directive implementing regulations. Existing implementing regulations remain in force until they are replaced by ESPR delegated acts. Manufacturers must continue to comply with the existing implementing regulations until the applicable ESPR delegated act comes into force. The EU Commission has published a transition roadmap specifying when each existing implementing regulation will be replaced by an ESPR delegated act — manufacturers should review this roadmap and plan their compliance transition accordingly.