Navigating New Ecodesign Requirements for Products

Article by Siv Elin Ånestad, Senior Advisor for Circular Economy at NORSIRK.

The EU’s new Ecodesign for Sustainable Products Regulation (ESPR) is one of the most important legislative initiatives supporting the transition to a circular economy and a key component of the European Green Deal. The regulation introduces requirements for product sustainability throughout the entire lifecycle, from design and production to end-of-life management.

For businesses, this means products must increasingly be developed with durability, reparability, resource efficiency and recyclability in mind. Understanding and preparing for these requirements is essential for maintaining market access, competitiveness and regulatory compliance.

The Ecodesign Regulation entered into force in the EU on 18 July 2024. It is currently under consideration within the EEA framework and will be implemented in Norway through the proposed Act on Sustainable Products and Value Chains. Product-specific requirements will enter into force gradually over the coming years.

Which Industries and Products Will Be Covered?

In principle, the Ecodesign Regulation applies to almost all products, with exceptions for food, feed, medicinal products, plants and animals.

Only products that meet the applicable ecodesign requirements will be allowed on the EU and EEA market.

The European Commission is currently developing specific ecodesign requirements for various product categories. The first priority product groups include:

  • Textiles
  • Furniture
  • Tyres
  • Mattresses
  • Steel and iron
  • Aluminium

In addition, reparability requirements will apply to selected product categories, including electronics and household appliances.

Electronic products will also be subject to requirements related to recyclability and recycled content. These requirements will be introduced progressively up to 2029.

Additional product groups will become subject to ecodesign requirements as new EU work plans are adopted.

What Requirements Will Apply to Products?

As much as 80% of a product’s environmental and climate impact is determined during the design phase. For this reason, the regulation enables the introduction of up to 16 different types of ecodesign requirements, including requirements relating to:

  • Durability and reusability
  • Reparability and upgradability
  • The presence of substances of concern
  • Energy consumption and energy efficiency
  • Resource use and recycled material content
  • Remanufacturing and recyclability
  • Climate and environmental footprints

The regulation also introduces a ban on the destruction of unsold textiles and footwear, as well as transparency requirements related to the handling of unsold goods.

All products covered by ecodesign requirements will also be required to have a Digital Product Passport (DPP). The Digital Product Passport will support lifecycle traceability and provide information including:

  • Material composition
  • Substances of concern
  • Instructions for use
  • Reuse and recycling information
  • End-of-life treatment requirements

Why Is This Important Now?

For businesses that fail to prepare for the upcoming ecodesign requirements, the consequences could be significant.

Non-compliance may result in:

  • Sales restrictions or withdrawal of products from the EU/EEA market
  • Fines and regulatory penalties
  • Consumer liability claims
  • Reputational damage
  • Loss of market share

Early preparation is therefore critical for maintaining access to key markets and avoiding costly compliance issues.

Who Will Be Responsible?

Responsibility for ensuring compliance will typically involve several functions within a company, including:

  • Product developers and designers
  • Sustainability managers
  • Procurement and category managers
  • Legal and compliance teams
  • Senior management, responsible for overall compliance governance

What Are the Benefits of Starting Now?

There are significant advantages to preparing early for ecodesign requirements.

Early action can provide:

  • Better preparation and lower implementation costs
  • Increased innovation and competitiveness
  • Reduced risk of non-compliance
  • Stronger positioning as a sustainable business

How Can NORSIRK Help?

NORSIRK offers tailored advisory services to help businesses navigate this complex and rapidly evolving regulatory landscape.

Our circular economy advisors can help your business:

  • Identify which requirements apply to your products and operations
  • Assess compliance risks and potential areas of non-conformity
  • Recommend actions to ensure regulatory compliance
  • Develop product specifications for procurement processes
  • Ensure correct product claims and labelling to avoid greenwashing
  • Develop ecodesign strategies for products and portfolios
  • Identify circular opportunities within your industry

Contact NORSIRK Advisory Services

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