Ecodesign for Sustainable Products Regulation (ESPR): What Investors Need to Know
In 2024, the EU released the Ecodesign for Sustainable Products Regulation (ESPR), replacing the older Ecodesign Directive and expanding its scope far beyond energy-related goods.
The primary goal is to ensure that products sold across the Single Market are built for durability, repairability, recyclability and transparency, while helping transform consumption into a force for circularity and environmental stewardship.
In April 2025, the European Commission adopted its first 2025–2030 Working Plan under ESPR, laying out a phased timeline for introducing ecodesign and energy labelling standards.
Priority Sectors under the ESPR 2025-2030 Working Plan
The Commission has identified several product categories for immediate action:
These sectors have been selected for their resource intensity and substantial potential to impact material use and waste generation.
In addition, horizontal measures are set to address broader product sustainability themes. This includes requirements like repairability scoring, recyclability rules for electronics, and minimum recycled content thresholds that apply across multiple product lines.
Horizontal repairability (including scoring) obligations will start applying in 2027, whereas recyclability requirements for electrical and electronic equipment will start later, in 2029.
Companies manufacturing, importing, or marketing products in the identified categories will face new obligations like:
- Designing products for longevity and end-of-life value recovery
- Using higher percentages of recycled materials
- Providing transparent digital information through Digital Product Passports (DPPs), digital records embedded via QR codes that track a product’s materials, repair history, environmental footprint and compliance status.
These requirements will determine whether a product is marketable within the EU.
In addition, the ESPR does not fully replace the old Ecodesign Directive immediately, the energy-related products regulated under the former law will keep complying and slowly transition (in 2027) to ESPR compliance. However, such transition is only foreseen for 19 out of the 35 products covered in the Ecodesign Directive.
The remaining 16 products are already covered in the 2025-2030 ESPR plan, with more specific deadlines and requirements for each of them:
What Investors Can Do to Support Their Investments under the ESPR scope
For investors overseeing companies affected by ESPR, we’d suggest to take the following actions:
- Identify which portfolio companies produce or sell in the prioritised categories or depend on sustainable product credentials.
- Encourage investments in product redesign, materials sourcing and data systems to meet future standards.
- ESG-focused startups working on circular materials, DPP solutions or repairable product formats are likely to benefit from increasing demand. This is the moment to strengthen partnerships under that premise.
Delegated acts (the detailed rules for each product group) will follow in the next years.
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