The ‘E’ of ESG: New EU Ecodesign Rules for Sustainable Products and Unsold Consumer Goods

The EU Commission is advancing new implementing rules under the EU Ecodesign Regulation for Sustainable Products (ESPR 2024/1781) to curb the environmental impact of unsold consumer products. This initiative addresses the “E” (Environmental) aspect of ESG by promoting sustainable product management in the European market.

Key Objectives of the New EU Ecodesign Rules

• Prevent Destruction of Unsold Goods: The EU aims to halt the widespread destruction of unsold consumer products, an environmental and resource loss exacerbated by growing online sales.
• Harmonization Across Member States: Existing national laws vary, leading to market distortions. The new rules create uniform obligations and incentives across the EU.
• Transparency and Accountability: Enterprises must disclose detailed data on unsold product disposal, fostering greater transparency and promoting sustainable practices.

Scope and Applicability

• Applies to all consumer products placed on the EU market, regardless of the seller’s location inside or outside the EU.
• Initially targets large enterprises, with medium-sized companies included starting 19 July 2030.
• Requirements activate progressively, with audited disclosure obligations beginning in 2026 based on 2025 data, and the destruction ban effective from 19 July 2026. ## Disclosure Obligations Under Article 24 ESPR

Participating enterprises must annually disclose:

• Quantity: Number and weight of unsold discarded products, broken down by product category.
• Reasons for Disposal: Including justified exceptions to the destruction ban.
• Waste Treatment Details: Proportions of reuse, recycling, recovery, and disposal applied.
• Prevention Measures: Actions taken or planned to reduce unsold product destruction.

Disclosure Format and Verification

• Information should be presented either on an accessible webpage or within sustainability reports (in compliance with the EU Accounting Directive 2013/34/EU).
• A standardized reporting format is mandated to ensure comparability across companies.
• Large enterprises subject to sustainability reporting must obtain a limited assurance opinion from an auditor or accredited provider verifying the disclosed data.

Implementation Timeline and Compliance

• Draft implementing acts detailing transparency requirements and exceptions to the destruction ban are slated for adoption by Q3 2025.
• Member States will enforce their own penalty regimes for non-compliance; for example, Germany has fines reaching up to EUR 50,000 per incident under previous Ecodesign laws.
• These rules signal EU’s commitment to integrating sustainability in product lifecycle management, urging companies to embed circular economy principles to align with ESG goals.

Conclusion

The EU’s new Ecodesign rules under ESPR mark a significant regulatory advancement mandating transparency and curbing wasteful practices concerning unsold consumer products. They underscore the growing importance of sustainable product policies in addressing environmental challenges and support the escalation of ESG efforts throughout the consumer goods sector. Enterprises operating in or selling to the EU market should prepare for timely compliance to navigate this emerging regulatory landscape effectively.

Sources:

• EU Commission’s draft delegated and implementing regulations under ESPR
• EU Accounting Directive 2013/34/EU
• Freshfields Bruckhaus Deringer analysis by Jonas Köster and Tobias Klatt (2025)

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