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ESPR Compliance Checklist

The Ecodesign for Sustainable Products Regulation is coming into force in waves. This practical checklist walks through what every economic operator selling in the EU should have ready, product by product. It is a starting point, not legal advice.

1. Timeline and scope

Confirm whether your products fall under ESPR delegated acts (textiles and footwear lead the way, then furniture, tyres, electronics and more).
Map which EU market requirements already apply to you today: GPSR, CE marking, batteries, packaging, textiles labelling, and how ESPR interacts with them.
Track the application dates of the delegated acts for your product group, not the adoption date. Compliance deadlines arrive after the acts enter into force.
Check whether your products are exempt (for example aircraft parts, used goods sold as-is, some components).

2. Data you need to collect

Supply chain data: where the product and its components are manufactured, and who the suppliers are at each step.
Composition data: materials, weight, recycled content, hazardous substances.
Durability and repair data: expected lifetime, repairability information, availability of spare parts.
Energy and resource use data: for energy-related products, consumption in use and efficiency figures.
End-of-life data: recyclability, disassembly instructions, waste collection information.

3. The Digital Product Passport

Identify which of your products will require a DPP and by which date under the relevant delegated act.
Choose a data carrier to print or embed (usually a QR code, Data Matrix or RFID) with the required identifier format.
Make sure the passport is accessible free of charge and without registration, by consumers and by authorities.
Keep the passport data accurate and up to date for the full lifecycle of the product, including changes after sale.
Restrict access levels: consumer view, market surveillance view, supply chain view with appropriate data fields per actor.

4. Compliance documentation

Prepare a technical documentation file for each product or product family covered by a delegated act.
Carry out and document the conformity assessment required by the delegated act before placing the product on the market.
Draft or update the EU declaration of conformity for products already subject to harmonised legislation.
Set up a process to provide documentation and evidence to market surveillance authorities within the requested time.
Keep records for the retention period required by the applicable delegated act.

5. Roles and obligations

Define who is the responsible economic operator for each product: manufacturer, importer or authorised representative.
Confirm importers verify the manufacturer has done the paperwork, and that products carry the required data carrier.
Confirm distributors check the marking and documentation before placing products on the market.
Prepare for the ban on destroying unsold consumer products and the related reporting duties (textiles first).
Plan for repairability obligations and how they change your product design and spare parts policy.

6. Sanctions and risk

Check the penalty regime of every EU member state where you sell: fines can reach millions of euros or a percentage of annual turnover.
Plan for market surveillance checks and corrective measures, including withdrawal or recall of non-compliant products.
Set up an internal compliance review at least quarterly, since delegated acts and timelines keep moving.
Verify whether any purchased compliance software or certificate actually covers your product group, not just the regulation in general.

Want to put this checklist into practice?

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