By Matthew Ekholm, Digital Product Passport and Circularity Specialist at Protokol.
Mentions of the EU’s Ecodesign for Sustainable Products Regulation (ESPR) are now arguably a familiar sight as the compliance consideration draws nearer. It has started to evolve from a vague regulatory framework to a clear and actionable directive for manufacturers across the electronics, furniture, and other industries.
Having initially come into force during mid-2024 with the ultimate aim of making sustainable products the base line in Europe, manufacturers globally are faced with the challenge of understanding the regulation’s varied complexities.
As a regulation with many layers, we currently know who the regulation is set to impact, that being any business placing products from the priority groups into the EU marketplace. Moreover, another key aspect will be the mandating of Digital Product Passports (DPPs) across product groups and target sectors.
As the regulation sets a range of complex requirements, which differ depending on the product group targeted, businesses looking to stay ahead of this shifting regulation should keep the following three milestones on their radar over the coming years.
Photo source: Protokol
Area One: The ESPR and the 2025 Energy Labelling Plan
With the ESPR having been in the public domain for a while now, there has remained a consistent demand for more clarity from those due to be affected.
In line with this, in April this year, the regulation’s first Working Plan was published.
This has outlined a range of requirements (across vertical and horizontal categories) pertinent to businesses in each sector impacted. For example, for electronics businesses, horizontal requirements such as repairability scoring (which likely includes consumer electronics), recycled content, and the recyclability of electronic equipment will be a key focus.
At the same time, for businesses in named vertical industries, such as the textile sector, the Working Plan outlines expectations for material efficiency while reducing the impact on water and waste generation, as well as energy consumption. These are just two examples of how this regulatory update is set to advise and impact different sectors accordingly.
The ESPR specifies that every product subject to ecodesign requirements will need a DPP - a digital record that largely acts as a physical item's digital twin and provides essential product information. This system is designed to improve data accessibility for businesses, consumers, and public authorities.
By understanding in advance that DPPs will be mandatory, businesses can get a head start: developing deployment strategies, mapping where the required data is stored, and collaborating with solution providers to ensure compliance.
Photo source: Protokol
Area Two: The Delegated Acts (Expected 2026–2028, varying by industry)
By 2027, the EU is set to roll out its first delegated acts, a series of formal guidelines that define exactly what data manufacturers must collect and disclose through DPPs for specific product categories. For some sectors, these detailed requirements may not arrive until 2028 or later, but the mandate will be unavoidable.
Since timelines will differ across industries, manufacturers cannot afford to wait. Now is the time to map where critical product and supply chain data resides, establish a clear implementation roadmap, and launch pilot programs with trusted partners.
Understanding early on that DPPs are mandatory gives manufacturers a significant advantage: they can prepare methodically, engage with solution providers on their own terms, and avoid last-minute, rushed compliance efforts.
Area Three: Ensuring ESPR compliance (18 months post the delegated acts being released)
Manufacturers supplying to or operating in the EU will have up to 18 months to comply once a delegated act is published. However, this window can be shortened if the EU justifies it. For example, due to environmental urgency. That means manufacturers should treat pilot programs as more than tests; they’re an opportunity to refine and de-risk their DPP implementation strategies.
Forward-looking manufacturers with later compliance deadlines can also gain an edge by closely monitoring early-priority sectors such as iron and steel, which are expected to receive delegated acts in 2026. Observing how these industries adapt can help anticipate requirements and shape best practices before rules hit their own product categories.
Even if formal deadlines appear distant, every milestone on the compliance roadmap matters. Acting early allows manufacturers to adjust production processes, secure compliant materials from suppliers, and align operations with EU mandates well ahead of the curve.
