ESPR will not reward late movers: circular design as a market entry condition

The Ecodesign for Sustainable Products Regulation (ESPR) marks a fundamental shift in EU product policy — and should be read for what it really is: not a technical update to product rules, but a structural intervention in how European markets will function. 

With the European Commission’s 2025–2030 Working Plan now adopted, that shift is moving into implementation, with timelines for when new ecodesign and information requirements will begin reshaping product markets. 

ESPR replaces the former Ecodesign Directive and extends product regulation far beyond energy use to cover nearly all physical goods placed on the EU market, bringing durability, repairability, recycled content, chemical safety and material recovery into the same regulatory frame, while pushing for harmonised rules across Member States to avoid fragmentation and accelerate investment in repair, remanufacturing and recycling. 

Circularity is no longer a voluntary sustainability ambition. It is rapidly becoming a baseline condition for market access. 

From energy performance to product systems 

Under the former Ecodesign Directive, EU product policy focused on energy-related products —but it left durability, chemical safety, repairability, and material recovery largely outside the scope of regulation. 

ESPR changes that fundamentally. Product regulation now reaches upstream into design and procurement decisions, and downstream into how products and materials are managed after use. 

 For companies, this means meeting not only new concrete product performance thresholds — such as durability, repairability and recycled content — but also making reliable product and supply-chain data available, covering material composition, substances of concern and end-of-life handling. 

Why design and supply chains are now part of compliance 

Although product-specific ESPR requirements will be adopted gradually, product portfolios being developed today will still be sold when those rules apply. 

Design choices made now determine whether components can be replaced, materials separated, chemicals recycled, and suppliers are able to provide the verified data that future transparency requirements will demand. 

When these issues are not considered early, changes later often require far more than minor adjustments. New materials must be tested, suppliers renegotiated, certifications updated, and production processes validated.  

From what we see in practice when working with manufacturers, the challenge is rarely technical feasibility alone. It is the time and coordination required to move entire value chains in a new direction - steps that in many industries take years. 

Digital Product Passports will expose product design quality 

Digital Product Passports are often discussed as a future reporting obligation. In reality, they will make the inner logic of products visible in ways product regulation has never required before. 

Passports are expected to include structured information on material composition, substances of concern, repair instructions, and end-of-life handling. Companies will need to know — and be able to show — far more about how products are made, maintained and recovered after use. When products cannot document material composition, chemical safety or realistic recovery pathways, that will no longer remain an internal issue. It will be visible to regulators, business partners, and increasingly to buyers that are themselves under compliance and climate pressure. 

 Digital Product Passports therefore do more than introduce transparency and reinforce the shift already embedded in ESPR: they turn product design quality into something that can be scrutinised, compared and challenged across markets — linking regulatory compliance directly to how well products were conceived in the first place. 

Circular design strategies that support legal requirements 

This is where circular design frameworks become directly relevant to regulatory readiness. 

Cradle to Cradle design principles, developed more than two decades ago*, start from the idea that products should be designed as nutrients for continuous cycles, using safe materials that can circulate in technical or biological systems without loss of quality. 

These principles have long inspired frontrunner companies to rethink material selection, product architecture and recovery systems — well before regulation required it. 

Cradle to Cradle Certified® (C2C Certified®) translates these principles into a structured product standard, assessing products across Material Health, Product Circularity, Clean Air and Climate Protection, Water and Soil Stewardship and Social Fairness. 

In practical terms, the C2C Certified Product Standard requires companies to redesign products for repair and refurbishment, select materials compatible with high-quality recycling, and establish recovery strategies as part of the product concept — not as downstream waste solutions. 

At the same time, material composition and chemical safety are documented and verified across supply chains. This supports both better design decisions and the level of data transparency that ESPR and Digital Product Passports will increasingly require. 

ESPR will reshape competition, not just compliance 

Over time, ESPR is likely to shape access to public procurement, eligibility in regulated product categories, and the expectations of large B2B buyers that are under pressure to meet climate and circularity targets. 

Circular design performance will increasingly become a commercial qualifier. Products that cannot demonstrate durability, repairability or credible recovery pathways may struggle to compete in tenders and supply contracts. 

Companies already integrating circularity into product development are likely to face fewer structural adjustments as new requirements enter into force.  

For many companies, circular design performance will increasingly become a commercial qualifier. Products that cannot demonstrate durability, repairability or credible recovery pathways may struggle to compete in tenders, supply contracts and preferred-supplier programmes. 

Companies already integrating circularity into product development are likely to face fewer structural adjustments as new requirements enter into force. Others may have to adapt under tighter timelines and higher operational pressure, while also trying to maintain market position. 

Although voluntary standards cannot guarantee compliance with every future delegated act, they already function as forward-looking frameworks that help companies anticipate regulatory requirements, strengthen product systems and build capabilities over time — reducing regulatory risk while supporting stronger market positioning as circularity becomes embedded in product law. 

Regulation is aligning with circular design 

For years, circular economy frameworks have argued that most environmental impact is determined at the design stage. ESPR now embeds that logic into binding product law. 

Circularity is now becoming part of how product quality, durability and market suitability are defined in regulation. The companies best positioned for this transition are those that already integrate circular thinking into design, sourcing and recovery as a core product strategy. 

For them, ESPR is not just a compliance deadline on the horizon. It is confirmation that the market is moving toward the way they are already designing products today. 

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Additional reading 

Policy context: what the current ESPR Working Plan covers (2025–2030) 

To support the transition outlined above, the European Commission has adopted the first Working Plan under the Ecodesign for Sustainable Products Regulation, covering the period 2025–2030. The plan sets out which product groups will be prioritised for delegated acts introducing concrete ecodesign and information requirements, and when these are expected to be adopted. 

Priority final products (indicative timelines) 

The Working Plan identifies several final product groups with high environmental impact and strong potential for improvement: 

• Textiles and apparel — indicative adoption of ecodesign requirements: 2027 
  (with a focus on product lifetime, material efficiency, water and climate impacts, and alignment with the revised Textile Labelling Regulation) 

• Tyres — indicative adoption: 2027 
  (with emphasis on recyclability, recycled content and end-of-life management) 

• Furniture — indicative adoption: 2028 
  (addressing material efficiency, durability and impacts linked to material sourcing and waste) 

• Mattresses — indicative adoption: 2029 
  (with a focus on waste prevention, material recovery and lifetime extension) 

Priority intermediate products 

Intermediate products are addressed because of their strategic importance for climate targets, resource security and industrial competitiveness: 

• Iron and steel — indicative adoption: 2026 
  (complementing existing climate measures such as ETS and CBAM, and supporting green steel initiatives) 

• Aluminium — indicative adoption: 2027 
  (with strong focus on recycled content, energy use and supply resilience) 

Horizontal requirements 

In addition to product-specific rules, the Working Plan foresees horizontal measures that will apply across multiple product categories: 

• Repairability requirements and scoring — indicative adoption: from 2027 

• Recycled content and recyclability requirements for electrical and electronic equipment — indicative adoption: from 2029 

These measures are expected to apply progressively, building on initial product categories and expanding over time. 

Energy-related products under ESPR and Energy Labelling 

Products previously regulated under the Ecodesign Directive and Energy Labelling Regulation remain subject to updated requirements under the new framework. The Working Plan foresees new or revised measures for, among others: 

• household and professional dishwashers and washing machines (from 2026) 

• displays (from 2027) 

• EV chargers, electric motors and refrigeration appliances (from 2028) 

• mobile phones, tablets and tumble dryers (by 2030) 

These measures combine ecodesign requirements with updated energy labels where relevant. 

Products not yet included in the first Working Plan 

Some product groups are not covered in the initial 2025–2030 plan, either due to lower improvement potential or regulatory complexity, but will be reassessed in future reviews. These include: 

• Detergents, paints and lubricants 

• Footwear (assessed separately from textiles, with an environmental sustainability study expected by end of 2027) 

• Chemicals (with a study to define future scope and focus areas expected by end of 2025) 

• Certain electrical equipment already addressed under other climate legislation 

System-level enablers 

Beyond product requirements, ESPR also introduces system mechanisms that support implementation and market transformation, including: 

• Digital Product Passports for products covered by ecodesign measures, enabling structured access to product and material data 

• The possibility to set mandatory minimum requirements for Green Public Procurement 

• Measures to restrict the destruction of unsold consumer products for selected categories 

Together, these elements are intended to align product design, market incentives and regulatory oversight around circular economy objectives.