Where Product Design and Compliance Collide: The EU’s Ecodesign for Sustainable Products Regulation (ESPR)

Date: July 24, 2025
Author: Mike Schmidt, AEM Director of Industry Communications
Source: Association of Equipment Manufacturers (AEM)

Introduction to ESPR

The Ecodesign for Sustainable Products Regulation (ESPR), effective since July 2024, represents a transformative approach within the European Union’s Green Deal initiative. Unlike traditional legislation with prescriptive rules, ESPR establishes a flexible framework requiring manufacturers to integrate ecological considerations into product design and development.

This shift marks a critical evolution where sustainability and regulatory compliance intersect deeply with product design processes. ESPR challenges companies, especially those treating sustainability as an add-on, to rethink product lifecycle impacts comprehensively to remain competitive in the EU market.

Scope of ESPR

Regulation EU 2024/1781 defines ESPR’s broad application to nearly all physical goods, materials, and components placed on the market or put into service within the EU. Key in-scope products and materials include:

• Raw materials like iron, steel, and aluminum
• Final products and parts containing these materials
• Chemicals, including substances of concern contained in products
• Energy-related products, telecommunications, electronics, furniture, textiles, and tires

Excluded categories currently include living plants and animals, food and feed, human and animal medicines, vehicles undergoing type approval, and packaging (covered separately under existing packaging regulations).

According to Chuck LePard, senior consultant at DXC Technology (an AEM member company), the definition of substances of concern has evolved beyond hazardous qualities to include any materials that hinder recycling, repurposing, or reuse.

Horizontal Product Grouping Concept

ESPR introduces the notion of horizontal product grouping, meaning products with similar regulatory or consumer perceptions are grouped to streamline requirements. This approach optimizes performance and reporting obligations across related product categories.

Current groupings encompass:

• Batteries (usage-based grouping)
• Chemicals in recyclate restrictors, paints/coatings
• Energy and chemistry-based materials like steel and aluminum
• Energy technology such as USB chargers
• Products with recycling challenges like textiles, tires, and furniture
• High-waste generation categories including mobile phones and computers

This methodology aims to enforce consistent sustainability criteria while addressing varied product characteristics and impacts.

Reporting and Compliance Requirements

One of ESPR’s most rigorous aspects is its unprecedented reporting demands. Manufacturers must calculate and report:

• Carbon emissions during product manufacturing
• Total lifecycle emissions (including extended use phases, e.g., tractors with 25-year lifespans)
• Data on waste reduction, repairability, reuse potential, and overall circularity

From 2026 onward, manufacturers must begin integrating digital product identifiers into registries, with reporting obligations becoming mandatory by 2027 and continuing through to 2030. —

Current Status and Industry Impact

ESPR is being implemented in stages. At present, many AEM member companies’ core equipment components are exempt, particularly vehicles covered under separate type approval regimes. However, the EU may broaden the scope over time, requiring proactive adaptation.

The regulation compels manufacturers to embed sustainability into product strategies, considering material selection, product design, and end-of-life processes—a paradigm shift towards circular economy principles.

Conclusion

The ESPR signals an era where sustainability is inseparable from product design and compliance. By framing ecological requirements broadly and flexibly, the EU challenges industries to reimagine product lifecycles with circularity and environmental stewardship at the forefront.

For companies operating within or supplying to the EU, understanding and engaging with ESPR’s evolving framework is critical to maintaining market access and advancing sustainable innovation.

Further Information

AEM continues to support its members adapting to sustainability challenges through resources and advocacy. Visit aem.org/sustainability for more details on how the industry is leading toward a sustainable future.

This summary is based on insights presented by industry experts and regulatory updates up to mid-2025.

Design Delight Studio curates high-impact, authoritative insights into sustainable and organic product trends, helping conscious consumers and innovative brands stay ahead in a fast-evolving green economy.