New EU Ecodesign Rules Target Unsold Consumer Products for Greater Sustainability

The European Union is set to introduce new implementing regulations under the EU Ecodesign Regulation for Sustainable Products (EU) 2024/1781 (ESPR), focusing on transparency and banning the destruction of unsold consumer goods. These measures aim to strengthen the environmental component (“E”) of ESG practices by reducing waste and fostering sustainable product lifecycle management.

Key Regulatory Highlights

• Scope and Applicability:
  These rules apply to all products placed on the EU market, regardless of whether the enterprise is established inside or outside the EU. Large enterprises face audited disclosure obligations starting as soon as 2026 (based on 2025 data), while the destruction ban on unsold products takes effect from 19 July 2026. Medium-sized enterprises will be subject to reporting requirements from 19 July 2030. – Objective:
  The ESPR targets the growing environmental concern over the systematic destruction of unsold consumer products, exacerbated by increased online sales. This practice is seen as both an ecological and economic loss across the EU. The regulation aims to harmonize Member States’ differing laws and eliminate market distortions by setting uniform rules.

Transparency and Disclosure Requirements (Article 24 ESPR)

Enterprises must annually disclose detailed information on the disposition of unsold products, including:

• Quantity: Number and weight of unsold consumer products discarded, categorized by product type.
• Reasons: Justifications for discarding products and applicable exemptions.
• Waste Treatment: Proportions allocated to reuse, recycling, recovery, or disposal processes.
• Prevention Efforts: Measures taken or planned to avoid destruction of unsold goods.

Disclosure Format and Verification

Businesses can fulfill their disclosure obligations either via:

• A clearly accessible webpage on their website, or
• Their sustainability report as per Articles 19a or 29a of the EU Accounting Directive (2013/34/EU).

A standardized reporting format will be mandated to ensure comparability, dividing disclosures into three sections: organizational details, product-related data, and preventive strategies. Large enterprises already reporting under EU accounting rules must provide a limited assurance opinion from an auditor or accredited verifier to confirm data accuracy.

Ban on Destruction and Exceptions (Article 25 ESPR)

The ESPR includes a binding ban on the destruction of unsold consumer products, with defined and justified exceptions to be detailed in a delegated regulation. Member States will establish penalties for non-compliance; for instance, under previous Ecodesign rules, German penalties could reach €50,000 per incident, adjustable based on illegal profit.

Timeline and Next Steps

The EU Commission aims to finalize the implementing and delegated acts by Q3 2025. Key deadlines are:

• July 19, 2025: Adoption of implementing acts on disclosure requirements (expected).
• July 19, 2026: Enforcement of the destruction ban.
• July 19, 2030: Expansion of transparency obligations to medium-sized enterprises.

Implications for Businesses

Enterprises marketing products in the EU must prepare for enhanced transparency obligations and comply with destruction prohibitions on unsold items. This will necessitate improved inventory management, waste tracking, and sustainability reporting practices to align with the new EU Ecodesign framework.

Sources:

• EU Ecodesign Regulation for Sustainable Products (EU) 2024/1781 (ESPR)
• Draft Commission Implementing Regulation on Disclosure Obligations (2025)
• Freshfields Bruckhaus Deringer legal analysis by Jonas Köster, Tobias Klatt, Juliane Hilf, and Sam Houshower, October 2025

By strengthening rules around unsold consumer products, the EU advances sustainability goals that reduce waste, encourage resource efficiency, and foster a circular economy, setting a precedent for global environmental governance within the product lifecycle management landscape.

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