What is the new Ecodesign for Sustainable Products Regulation (ESPR)?
The ESPR replaces the current Ecodesign Directive 2009/125/EC and establishes a framework for setting ecodesign requirements for specific product groups. It allows for the setting of performance and information conditions, known as ecodesign requirements, for almost all categories of physical goods (with some exceptions, such as food and feed, as defined in the EU General Food Law Regulation 178/2002). These requirements include:
- Improving product durability, reusability, upgradability, and reparability
- Enhancing energy and resource efficiency
- Addressing the presence of substances that inhibit circularity
- Increasing recycled content
- Facilitating easier remanufacture and recycling
- Setting rules on carbon and environmental footprints
- Improving the availability of information on product sustainability
The ESPR also introduces several new measures:
- Digital Product Passport
- Rules to address destruction of unsold consumer products
- Green Public Procurement
Previously, the focus of the Ecodesign Directive was primarily on energy consumption and therefore only applied to products that consume energy such as fridges, vacuum cleaners and other electronic equipment. Now, it also considers indirect energy consumption, such as the materials required for a product, resource depletion, and other environmental impact indicators. The ESPR therefore applies to any physical goods placed on the market or put into service, including components and intermediate products. Certain categories are however excluded, such as food, feed, medicinal and veterinary products, living plants and animals, products of human origin, and certain vehicles covered by sector-specific Union legislative acts.
Enlarging the scope, both regarding the products included and the requirements, is an important step towards further reducing GHG emissions from and increase the circularity of physical goods in the EU. According to data from the EU Commission, ecodesign measures have reduced GHG emissions by 114 Mt CO2eq (-9% vs business as usual) in 2020 and are expected to reduce the emissions by 160 Mt CO2eq (-17% vs business as usual) in 2030. The reduction is respectively 3.2% (2020) and 4.4% (2030) of the EU27 total emissions in 2019 (3610 Mt CO2) (European Commission, 2021).
As an example of how the principles in the ESPR have been translated into practice, Apple's Environmental Product Declaration for the MacBook Air reveals that the CO2 footprint associated to the materials that are used[AT1] constitutes almost half the product's total footprint, including its electricity consumption. By conducting Life Cycle Assessments across their entire product portfolio (already since 2015), Apple has gained valuable insights into improving their environmental performance. They have introduced more recycled content into their materials and implemented strategies such as offering battery replacements (Apple, 2024).
Apple's 2024 Environmental Progress Report (available here) demonstrates how the information from product Life Cycle Assessments is extrapolated to calculate and estimate total Scope 3 Category Purchased Goods and Services (reported under ESRS E1-6). Similar progress since 2015 can be seen across their entire product portfolio. The same information can be used to disclose many of the ESRS E5 required data points, emphasising detailed reporting on material usage, waste management, and product lifecycle impacts. This thorough approach ensures transparency and fosters improvements in environmental responsibility within the EU market.
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Curious about how your company can leverage ESPR to enhance your sustainability strategy and meet CSRD requirements?
Our expert team can guide you through the process, ensuring your business not only complies but thrives in the evolving regulatory landscape. Contact nishant@2impact.nl to discover how we can help you lead in sustainability and achieve your environmental goals.
