Everything you always wanted to know about ecodesign but were too afraid to ask

By Emily Best

By Luca Boniolo

By Mathieu Rama

By Lloyd Evans

The Ecodesign for Sustainable Products Regulation (ESPR), entered into force in July 2024. The regulation aims to improve the circularity, energy performance, and overall sustainability of physical products on the EU market. ECOS long campaigned to introduce wide-reaching ecodesign legislation to the EU and we are closely involved in ESPR developments. What is the current state of play and how are EU ecodesign rules developing?

A brief summary of ESPR – the EU’s ecodesign rules

In early 2025, the European Commission adopted the first ESPR Working Plan, which includes four priority product sectors, two horizontal measures, and two intermediate products to be addressed first by ecodesign rules. Since then, work has been ongoing on apparel, textiles, tyres, iron and steel, and the horizontal measure on repairability. The European Commission also drafted and adopted a delegated act laying down the exemptions to the ban on unsold footwear and apparel.

At the same time, the European Commission and CEN/CENELEC have been working to develop standards for the soon to be rolled out Digital Product Passport (DPP), which will eventually be used to share important sustainability information about all products.

Taken together, these initiatives mark the beginning of Europe’s largest overhaul of product sustainability rules. But they also reveal the challenge ahead: ensuring implementation is both ambitious and effective.

Making repair the norm

One of the most promising developments is the work on horizontal repairability requirements for electronic products. The ability to repair electronic products is important because, too often, they end up being discarded because of only one part having worn off or being broken. Small products are especially a major source of e-waste, such as toys, microwave ovens, or e-cigarettes, representing one third of the total e-waste generated globally.

Considering the variety of products concerned, a product-by-product approach to repairability is too time-consuming and would never deliver the necessary legislation. ECOS, along with the Right to Repair Coalition, has worked for years to introduce a horizontal approach to efficiently tackle e-waste.

The Joint Research Centre (JRC)’s preparatory study for setting horizontal ecodesign requirements on repairability will advise the European Commission on which policy measures to take and it shows a commendable level of ambition. A list of spare parts has been proposed that, when present in a product in scope (ranging from audio equipment to electronic scooters, also including small kitchen appliances and personal care devices), will have to be made available to professional repairers and sometimes also to consumers. The products will have to be designed so that these parts can be replaceable, and the spare parts will have to be provided at a reasonable price (with a suggested cap at 30% of the price of the product). Repair scores will also be applied to at least five products yet to be selected.

Building the Digital Product Passport

The Digital Product Passport will be the new way to share information about products along the value chain, a key innovation of the ESPR. So far, the European Commission and stakeholders have focused on the development of the IT infrastructure, but as product requirements are progressively developed, we are starting to define what data will be shared through this infrastructure, and who will be able to see it. There are still many open questions, but ECOS works to ensure that the DPP truly supports transparency and will lead to better products, rather than being a simple reporting tool.

The EU Ecodesign Forum – making implementation more inclusive

ECOS has long championed inclusion – good ecodesign rules depend on good governance. The new Ecodesign Forum includes more civil society stakeholders than the prior Consultation Forum of the earlier Ecodesign Directive (2009). Hybrid meetings allow for both in-person and online participation facilitating more equitable access for ECOS and other civil society organisations and experts to provide valuable input.

Eco-fashion? Ecodesign rules for apparel

In December 2025, the JRC proposed a first set of ecodesign options for apparel, which relied too heavily on consumers’ goodwill and capacity to purchase more robust and sustainable products, whilst diminishing the responsibility of companies to make their own sector more sustainable. Including recycled content was the only mandatory performance requirement – which is also flawed, as it would allow the use of PET bottles as feedstock for achieving recycled polyester content – instead of promoting closed-loop, fibre-to-fibre recycling.

But ecodesign for apparel is not a done deal yet! Thanks to the reaction of many civil society stakeholders, the impact assessment of the ESPR delegated act on textiles will look into policy measures beyond the JRC’s proposal. We continue to ask for more durable, reusable, repairable, and recyclable products, made with targets in mind that minimise air, water, and soil pollution as well as generation of waste – with particular attention to substances of concern and the release of microplastics from synthetic materials.

Rolling out ecodesign for tyres

Tyres are a complex product – ecodesign requirements are needed to address material use, chemical transparency, and waste prevention, all whilst maintaining important safety and energy efficiency requirements. We are working intensively to provide input to the ESPR preparatory study on tyres and engage with stakeholders across the value chain to promptly deliver an ambitious delegated act that will improve the environmental performance of tyres. It is important that deadlines are not rushed, however, so that stakeholders and consultants have time to accurately define and measure the impact of tyres so that false solutions are not included.

Helping consumers make informed choices with an ESPR label

The methodology and some initial proposals for an ESPR label have been published, but the process is ongoing and we are continuing to provide input to improve the ESPR label design and function.

For the label to foster better consumer choice, information must be clear and relevant to consumers and the design should enable easy comparisons. The ESPR label should be displayed at the point of sale, immediately visible for consumers, including on e-commerce platforms. It should be recognisable for consumers, with a similar design replicated across different product groups even if information content varies.

Classes of performance should help identify best performers and consequently push worse performing products off the market. The ESPR label will work in combination with the DPP, but should focus on what drives consumer choice. The DPP can provide additional environmental information for interested consumers.

Greening Europe’s iron and steel

The current developments for iron and steel focus on the carbon footprint, and we hope to see later reviews bring in water and energy consumption as information requirements as well. We remain concerned, however, that the short timeline means the process has not been thorough enough and the current draft proposal by the JRC is dangerous because the recommendations would label high-emitting steel as green. We are therefore urging the European Commission to rethink the proposed values to classify green steel.

Designing furniture for a circular economy

Furniture is one of the next product groups to enter the ESPR process, and the European Commission has started work on developing ecodesign requirements to improve its environmental performance. ECOS recently responded to the Commission’s stakeholder survey, highlighting the need for ambitious requirements that address the full diversity of furniture products and materials.

A key challenge for this product group will be defining the scope of future requirements. The rules must cover all products that function as furniture, regardless of their material composition, while recognising that different types of furniture have different durability and repair needs. The ESPR also provides an opportunity to reduce the use of substances of concern, such as PVC and other chemicals that can complicate recycling or contribute to indoor pollution.

Getting the process right

The implementation timelines for many ESPR products, including the proposed timelines for furniture, tyres, steel and iron, are increasingly compressed – with accelerated timelines for consultations and preparatory study phases that are too fast. Interested and expert parties, especially civil society, will not have sufficient time to develop comprehensive feedback. This creates risks that important information will not be included in the studies. We look to the European Commission to provide a longer timeline for the study phase – to ensure adequate attention to detail, transparency among stakeholder comments, and inclusivity. This could mean adding extra feedback rounds and stakeholder meetings to the calendar – but this additional time and work should mean the proposed design and policy options are ambitious, feasible, and implementable.

Two years after the ESPR entered into force the focus has shifted from negotiating the legislation to getting the technical details right. The delegated acts, standards, and methodologies – currently under development – will determine whether Europe’s ecodesign framework delivers genuine environmental improvements in practice.

We are on the right path, but a lot of work still lies ahead to make ecodesign a reality in Europe – and ECOS will be there every step of the way.