Integrating environmental aspects into product design in order to improve their environmental performance throughout their life cycle, this is the major goal of ecodesign. The stakes are high, since, according to the European Commission, up to 80% of a product’s environmental impacts are determined during the design phase. The dedicated legislation has evolved since 2024 in a way that should significantly boost the field. What exactly is changing?

Improving the environmental durability of products placed on the EU market

While the 2009 Ecodesign Directive applied only to energy-related products (such as household appliances, cooling and heating equipment) and focused solely on their use phase, the new Ecodesign for Sustainable Products Regulation (ESPR) adopted in July 2024 greatly expands the scope in order to “make sustainable products the norm” and “reduce their overall carbon and environmental footprint throughout their life cycle.”

It is worth noting that, unlike a directive, which must be transposed into national law by each Member State, this new text, as a regulation, entered into force immediately upon its adoption and applies uniformly across all EU countries.

A much broader legislation…

The July 2024 regulation covers the entire life cycle of products (extraction, production, distribution, use, and end-of-life), rather than focusing only on the use phase, as was the case with the 2009 directive. Another key point: it addresses reuse, repairability, energy and material efficiency, recycled content, remanufacturing and recycling, carbon and environmental footprint, as well as substances that may hinder circularity (mainly chemicals).

In addition, the requirements apply equally to products manufactured within the EU and to imported products(2).

In April 2025, the Commission adopted a 2025–2030 work plan covering both the Ecodesign for Sustainable Products Regulation (ESPR) and the Energy Labelling Framework Regulation (ELFR). This plan prioritizes six product categories due to their potential to improve the circularity of value chains: textiles, mattresses, furniture, tyres, steel, and aluminium.

This initiative aims to “promote durable, repairable, circular and energy-efficient products across Europe”, thereby “strengthening the single market, preventing trade barriers, improving fair competition conditions, reducing administrative burdens and enhancing the global competitiveness of companies offering sustainable products.”

Toward a widespread adoption of ecodesign?

Integrating environmental aspects into product design in order to improve their environmental performance throughout their life cycle — this is the major goal of ecodesign. The stakes are high, since, according to the European Commission, up to 80% of a product’s environmental impacts are determined during the design phase. The dedicated legislation has evolved since 2024 in a way that should significantly boost the field. What exactly is changing?

Improving the environmental durability of products placed on the EU market

While the 2009 Ecodesign Directive applied only to energy-related products (such as household appliances, cooling and heating equipment) and focused solely on their use phase, the new Ecodesign for Sustainable Products Regulation (ESPR) adopted in July 2024 greatly expands the scope in order to “make sustainable products the norm” and “reduce their overall carbon and environmental footprint throughout their life cycle.”

It is worth noting that, unlike a directive, which must be transposed into national law by each Member State, this new text, as a regulation, entered into force immediately upon its adoption and applies uniformly across all EU countries.

A much broader legislation

The July 2024 regulation covers the entire life cycle of products (extraction, production, distribution, use, and end-of-life), rather than focusing only on the use phase, as was the case with the 2009 directive. Another key point: it addresses reuse, repairability, energy and material efficiency, recycled content, remanufacturing and recycling, carbon and environmental footprint, as well as substances that may hinder circularity (mainly chemicals).

In addition, the requirements apply equally to products manufactured within the EU and to imported products(2).

In April 2025, the Commission adopted a 2025–2030 work plan covering both the Ecodesign for Sustainable Products Regulation (ESPR) and the Energy Labelling Framework Regulation (ELFR). This plan prioritizes six product categories due to their potential to improve the circularity of value chains: textiles, mattresses, furniture, tyres, steel, and aluminium.

This initiative aims to “promote durable, repairable, circular and energy-efficient products across Europe,” thereby “strengthening the single market, preventing trade barriers, improving fair competition conditions, reducing administrative burdens and enhancing the global competitiveness of companies offering sustainable products.”

To the benefit of product performance and information

The new requirements will cover product performance, particularly through criteria such as minimum durability, energy and material efficiency, availability of spare parts, or minimum recycled content. They will also address product information, to be provided via the Digital Product Passport (DPP) — a new transparency tool designed to ensure access to reliable data on environmental performance, repairability, the presence of substances of concern, and end-of-life management — or via information registered in EPREL (European Product Registry for Energy Labelling).

Horizontal measures are also to be introduced concerning repairability for products such as consumer electronics and small household appliances, including in particular a repairability score for products with the highest potential, as well as requirements on the recyclability of electrical and electronic equipment.

Special attention to SMEs

The Commission has stated that, when developing the specific requirements, it will pay special attention to the needs of SMEs, in particular micro-enterprises and small to mid-cap companies. It will ensure that these businesses can benefit from tailored support, for example through European programs or Member State initiatives.

How to prepare?

The work plan adopted on April 16, 2025, provides that delegated acts will be adopted “product by product or for groups of similar products.” The industry will have 18 months to comply after each act is published. The first requirements applicable to product groups are expected to enter into force in 2027, meaning that companies have every interest in preparing right now.

To this end, they can already begin by analyzing their current products and evaluating their life cycles in order to identify priority areas for improvement (materials, energy efficiency, waste generation, etc.). Many organizations and consulting firms offer support services for this initial phase.

Companies can also start preparing for the development of the Digital Product Passport (DPP). This begins with the collection and organization of all possible data concerning their supply chain (materials, production methods, energy consumption, etc.). The more structured and comprehensive this product-related data is, the easier it will be to implement the future DPP.

Finally, it is not necessary to wait for the official deadlines to begin ecodesigning products. Any concerned company can already start using ecological, bio-based or recycled materials, adopting modular designs, developing recyclable packaging, or implementing design strategies that facilitate disassembly and repair.

Coming soon: a Circular Economy Act

The ESPR is part of the EU Circular Economy Action Plan, adopted in 2020 under the European Green Deal. It is expected to be followed, in 2026, by a Circular Economy Act, designed to establish a single market for secondary raw materials, increase the supply of high-quality recycled materials, and stimulate demand for such materials within the EU. All the more reason to get started now.

1. “ESPR”: Ecodesign for Sustainable Products Regulation

2. The list of products excluded includes food, animal feed, human and veterinary medicines, live plants, animals and micro-organisms, products of human origin, and vehicles (which are covered by specific regulations).