The European Union is changing the way products are designed, made, sold, and managed at the end of their useful life.
At the heart of this shift is the EU Circular Economy Action Plan (CEAP) and the Ecodesign for Sustainable Products Regulation (ESPR). Together, they are intended to make sustainable and circular products the norm across the EU, while reducing resource use, waste and the environmental impacts associated with products throughout their lifecycle.
For businesses that manufacture, import, distribute or sell products into the EU, this means sustainability is increasingly becoming a product and supply chain issue, not simply a reporting or communications issue.
One of the most significant developments is the introduction of the Digital Product Passport (DPP), which will provide digital access to information about a product’s sustainability and circularity characteristics.
What is the EU Circular Economy Action Plan?
The Circular Economy Action Plan was launched by the European Commission in March 2020 as a key part of the European Green Deal.
Its aim is to move the EU away from a linear model of take, make and dispose, towards a circular economy where products and materials stay in use for longer.
The Action Plan focuses on the full product lifecycle, including:
- Product design and manufacturing
- Resource and material use
- Durability and repairability
- Reuse and recycling
- Waste reduction
- Sustainable consumption
- Product information and transparency
- Secondary raw materials
The focus is particularly important because decisions made at the design stage can determine how long a product lasts, whether it can be repaired, how easily it can be reused and what happens to its materials at the end of its life.
The EU has also identified several resource-intensive sectors where circularity will be particularly important, including electronics, textiles, vehicles, and construction.
What is the Ecodesign for Sustainable Products Regulation (ESPR)?
The Ecodesign for Sustainable Products Regulation (ESPR) is one of the key pieces of legislation supporting the EU’s circular economy ambitions.
The regulation expands the previous eco-design approach beyond energy-related products, creating a broader framework for setting sustainability requirements for products placed on the EU market.
The aim is to improve products:
- Durability
- Reliability
- Reusability
- Upgradability
- Repairability
- Recyclability
- Resource efficiency
- Recycled content
- Environmental performance
The European Commission describes the regulation to improve the circularity, energy performance, and wider environmental sustainability of products.
Importantly, the ESPR does not mean that every product will immediately have to meet the same requirements. Instead, the EU is developing product-specific requirements through delegated acts, with priority product groups identified through its working plans.
The Commission’s 2025–2030 working plan identifies product groups including textiles, furniture, iron and steel, aluminium, alongside other priorities products, for future eco-design requirements and energy labelling.
This means businesses need to look beyond the regulation itself and understand what requirements apply to the products and markets they operate in.
What does the ESPR mean for businesses?
The ESPR represents a shift towards making product sustainability more measurable, transparent, and embedded into product design.
For businesses, this could mean greater focus on areas such as:
1. Product design
Sustainability considerations will increasingly need to be incorporated at the design stage rather than addressed at the end of a product’s lifecycle.
Businesses may need to consider how products can be made more durable, repairable, reusable, and recyclable.
2. Materials and resource use
The regulation places greater emphasis on how resources and materials are used, including recycled content and the ability to recover materials at the end of a product’s life.
This could have implications for material choices, procurement, and supplier relationships.
3. Product information
Businesses will increasingly need reliable information about their products and their supply chains.
This includes information relating to characteristics such as durability, reparability, recycled content, and other sustainability attributes.
4. Supply chain data
The information required to demonstrate product sustainability may sit across multiple tiers of a supply chain.
For manufacturers and other businesses, this makes data collection, traceability, and collaboration with suppliers increasingly important.
5. Product compliance
As product-specific requirements are introduced, businesses will need to understand which requirements apply to their products and what evidence they need to demonstrate compliance.
This is particularly relevant for businesses selling products into the EU, including businesses based outside the EU.
What is a Digital Product Passport?
One of the most essential elements of the ESPR is the Digital Product Passport (DPP).
A Digital Product Passport is a digital record containing information about a product and its sustainability and circularity characteristics.
The information can be accessed digitally, for example through a data carrier such as a QR code or another identifier, linked to a unique product identifier (UID).
Depending on the product and applicable requirements, information could include details such as:
- Durability
- Repairability
- Recycled content
- Availability of spare parts
- Product materials and components
- Environmental characteristics such as Global Warming Potential
- Information relevant to reuse, remanufacturing, or recycling
The European Commission says the Digital Product Passport is intended to make relevant product information accessible across the value chain, supporting manufacturers, importers, distributors, repairers, remanufacturers, and recyclers.
The DPP is therefore more than a digital label. It has the potential to become an important piece of infrastructure for the circular economy by connecting product information across different stages of the product lifecycle.
Why do Digital Product Passports matter?
Today, information about a product’s materials, environmental impact, repairability and end-of-life options can be fragmented across manufacturers, suppliers, and other organisations.
Digital Product Passports are intended to help change this.
Better product data could make it easier to:
Design better products
Manufacturers can use more detailed information to understand materials, components, and environmental performance.
Improve repair and reuse
Repairers and other organisations can access information that helps them extend a product’s useful life.
Support recycling and recovery
Information about materials and components can help improve end-of-life treatment.
Improve supply chain transparency
Businesses can better understand and communicate product-level information across complex supply chains.
Give consumers better information
Consumers can access relevant information to help them make more informed purchasing decisions.
The Commission sees the DPP as a valuable tool for developing new circular economy value chains and keeping products, components, and materials in use for longer.
Join our Digital Product Passports webinar
Digital Product Passports are set to play an increasingly key role in the EU’s transition towards a more circular economy. But what will they mean for businesses?
Join us on 11th November for a practical webinar exploring Digital Product Passports and what businesses need to understand as the new requirements develop.
Whether you sell products into the EU today or are preparing for future requirements, this session will help you understand what is changing and what you can do now.
The opportunity behind the regulation
The EU’s Circular Economy Action Plan and ESPR are ultimately about changing the way products move through the economy.
Rather than designing products around a linear model of production, consumption and disposal, the direction of travel is towards products that last longer, can be repaired and reused, and retain their materials and value for as long as possible.
Digital Product Passports could provide an important layer of information to make that possible.
For businesses, the priority now is to understand where they may be affected, assess the quality of their existing product and supply chain data, and start building the capability to respond.
The organisations that prepare early will be better placed not only to meet future requirements, but to identify opportunities for more circular, resilient, and resource-efficient products and business models.