If you sell physical products into the EU, you'll need to start collecting sustainability data on every regulated product you make. The short answer: 16 categories covering durability, repairability, substances of concern, recycled content, carbon footprint and end-of-life handling. All of it feeds into a Digital Product Passport (DPP) attached to each product through a data carrier such as a QR code.
This guide is for Heads of Product, Digital and Data at mid-market and enterprise manufacturers who need to start scoping their data foundation now, before product-specific rules begin to apply from 2026.
Key Takeaways
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Every regulated EU product will need a Digital Product Passport linked through a QR code or similar data carrier.
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ESPR requires manufacturers to collect lifecycle sustainability data, with exact values set by product-specific delegated acts.
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Substances of Concern tracking covers more than 4,600 substances under the ESPR definition.
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ESPR delegated acts will roll out from 2026 to 2030, with at least 18 months before each act applies.
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Bluestone PIM helps manufacturers centralise DPP data at product, batch and item level, then share it through 700+ API endpoints.
What Is the EU Ecodesign for Sustainable Products Regulation?
The EU Ecodesign for Sustainable Products Regulation is the EU's central legal instrument for placing sustainability rules on physical products sold in the single market. ESPR replaces the 2009 Ecodesign Directive, widens scope beyond energy-related products, and gives the European Commission powers to set ecodesign rules across almost every product category.
It works in two layers. The framework text sets the architecture: the 16 product aspects, the DPP rules, the unsold-goods obligations, and the basket of priority groups. Product-specific delegated acts then translate those into binding performance or information requirements for each product group. Each act comes with a minimum 18-month transition before it applies.
For manufacturers, the practical consequence is that ESPR compliance is a data problem before it is a product redesign problem. You cannot prove durability, recyclability or recycled content without a single, governed source of product information that survives audit, customs check and consumer enquiry. This is where a properly architected PIM platform earns its place.
What Sustainability Data Does ESPR Require Manufacturers to Collect?
ESPR requires manufacturers to collect data on 16 product aspects covering the full life cycle from raw material to end of life. Each aspect must be addressed by delegated acts where relevant to the product group.
| The 16 ESPR Product Aspects | |||
|---|---|---|---|
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Durability
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Reliability
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Upgradability
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Repairability
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Possibility of maintenance and refurbishment
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Presence of substances of concern
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Energy use and energy efficiency
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Water use and water efficiency
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Resource use and resource efficiency
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Recycled content
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Possibility of remanufacturing
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Recyclability
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Possibility of recovery of materials
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Environmental and carbon footprint
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Reusability
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Expected generation of waste
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Each aspect comes with measurable parameters. In practice that means data points such as:
- guaranteed lifetime,
- mean time between failures,
- spare-parts availability and delivery time,
- modularity,
- ease of disassembly,
- recycled content percentage,
- weight,
- product-to-packaging ratio,
- microplastic and nanoplastic release,
- and material footprint.
ESPR also addresses premature obsolescence head-on. Design choices that shorten product life, software updates that disable functionality, and obstructed disassembly are all in scope.
Bluestone PIM supports these data points as structured product attributes with validation rules, completeness scoring and edit history, so a Head of Product can see at a glance which SKUs lack the data needed for any given delegated act.
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From 2026, the regulation will begin to apply to selected product groups,requiring companies to provide structured, detailed information about theproducts they place on the EU market.
What Counts as a Substance of Concern Under ESPR?
A Substance of Concern (SoC) under ESPR is any substance that meets one of four criteria:
- It is on the REACH Candidate List as a Substance of Very High Concern (SVHC)
- It falls under specified CLP hazard classes
- It is regulated under the Persistent Organic Pollutants Regulation
- It negatively affects the reuse and recycling of materials
The definition is deliberately broad. Industry estimates already put more than 4,600 substances inside it, and the number will keep growing as the EU adds new hazard classes covering endocrine disruptors (chemicals that interfere with hormones) and PMT/vPvM substances (chemicals that persist in water and spread widely through the environment).
SoC tracking is the only horizontal minimum information requirement besides the DPP itself, which means every manufacturer in scope of a delegated act will need to disclose SoC data regardless of product group.
For each Substance of Concern, manufacturers need to track:
| What to Track for Each Substance of Concern |
|---|
| IUPAC, EC and CAS names and numbers |
| Location of the substance within the product |
| Concentration at product, component or spare-part level |
| Safe-use instructions |
| Disassembly and end-of-life information |
No exemption applies for REACH SVHCs above 0.1% by weight. Every manufacturer with these substances in scope has to disclose them. Bluestone PIM holds this information as structured component-level attributes linked to the parent product, so a manufacturer with 200,000 SKUs can answer an SoC query at component, batch or item level without rebuilding the catalogue.
What Information Must a Digital Product Passport Contain?
A Digital Product Passport is the structured, machine-readable record that accompanies every ESPR-regulated product on the EU market. It is a market-access requirement: regulated products may only be placed on the market if a DPP is available, accurate, complete and up to date.
Every DPP needs the same structural elements:
| Core DPP Structural Elements |
|---|
| The information required under ESPR or other EU law. |
| Unique product identifier (UPI), GTIN and EU commodity codes (TARIC/CN). |
| Compliance documentation and the EU declaration of conformity. |
| User manuals, instructions, warnings and safety information. |
| Manufacturer, operator and facility identification. |
Delegated acts then add product-specific data on top: durability, repairability scores, recycled content, carbon footprint, end-of-life instructions, and any other sustainability data the Commission requires for that product group.
Every DPP must link to a persistent unique product identifier through a physical data carrier:
The passport itself must be machine-readable, based on open standards, accessible at model, batch or item level, and governed by differentiated access rights for consumers, repairers, recyclers and authorities.
Bluestone PIM is built to issue and maintain DPPs at scale through its API-first, MACH-certified architecture, with native support for unique product identifiers, GS1 Digital Link, and integration with third-party DPP service providers required for the mandatory back-up copy.
Which Products Will ESPR Regulate First?
ESPR will regulate energy-related products first, then expand to new categories through delegated acts under the 2025–2030 Working Plan.
The new categories in the first wave cover two intermediate products (iron and steel, aluminium) and four final products (textiles and apparel, furniture, tyres, mattresses). Two horizontal measures stand alongside the product-specific acts: a repairability scoring framework likely to cover consumer electronics and small household appliances, and a measure covering recyclability and recycled content of electrical and electronic equipment.
Sixteen carry-over energy-related products from the previous working plan are also in scope. The list includes household dishwashers and washing machines, displays, refrigerating appliances, electric motors, light sources, EV chargers, welding equipment, mobile phones and tablets, and tumble dryers.
Chemicals, footwear, detergents, paints and lubricants are not in the first plan. The Commission has scheduled a scoping study on chemicals by end-2025 and a footwear study by end-2027, with a mid-term review of the Working Plan due in 2028. Manufacturers in those categories should not assume permanent exclusion.
For the year-by-year view of when DPPs become mandatory for each product group, see the Digital Product Passport timeline.
What Do Manufacturers Need to Report About Unsold Goods?
ESPR requires economic operators that discard unsold consumer products to disclose this data annually on their website. Large enterprises are in scope now (FY 2025 data, reported in 2026). Medium-sized enterprises follow on 19 July 2030. Micro and small enterprises are exempt.
| Unsold Goods: What to Disclose |
|---|
| Number and weight discarded per year. |
| Reasons for discarding. |
| Proportion sent to reuse, recycling, other recovery, or disposal. |
| Measures taken and planned to prevent destruction. |
A standardised disclosure format using CN product codes applies from 2 March 2027. A separate destruction ban already covers unsold apparel and footwear for large enterprises from 19 July 2026, with 10 specific derogations. The Commission will not add new product categories to the destruction ban during the 2025–2030 Working Plan period.
A discrepancy of more than 10% between disclosed figures and waste-operator records counts as non-compliance. Bluestone PIM holds product, category and CN-code data as governed attributes, so the inventory team and the legal team work from the same record when preparing the annual disclosure.
How Should Manufacturers Prepare Their Product Data Systems for ESPR?
Manufacturers should prepare for ESPR in three tiers, working back from the delegated-act calendar that affects their product group. The objective is a single governed source of product data that can serve compliance, sales, marketing, customs and end-of-life partners from one record.
Tier 1: Within 12 months
- Inventory unsold-product flows against the new disclosure format, including CN codes, units, weight, reasons and waste-treatment routes.
- Map your products against the 2025–2030 Working Plan and calendar the indicative delegated-act adoption date plus 18 months.
- Build a Substance of Concern register at component and spare-part level, paying particular attention to REACH SVHCs above 0.1% by weight.
Tier 2: 2025 to 2027
- Stand up product-level life-cycle data infrastructure for carbon and environmental footprint, recycled-content traceability, durability and repairability metrics.
- Plan for DPP issuance (see the Digital Product Passport timeline for milestones and technical requirements).
- Coordinate with packaging teams. ESPR does not regulate packaging directly, but DPP data carriers often sit on packaging.
Tier 3: Toward 2030
- Design common data architecture rather than product-by-product workarounds, especially for the 2027 repairability and 2029 EEE recyclability horizontal measures that cut across multiple categories.
- Track the 2028 mid-term review for the next basket of product groups, particularly if you sell chemicals, footwear, detergents, paints or lubricants.
- Build data infrastructure that supports the parallel Green Public Procurement pathway, covered next.
How Does Bluestone PIM Support ESPR Compliance?
Bluestone PIM helps manufacturers prepare for ESPR by centralising sustainability data at product, component and item level, then making it available wherever it needs to go: retailers, channels, customs, consumers, regulators and end-of-life partners. The platform is API-first and MACH-certified, with more than 700 API endpoints for integration with ERP, PLM, LCA tools and DPP service providers.
| Capability | What It Does for ESPR |
|---|---|
| Sustainability attribute modelling | Structured product attributes for durability, repairability, recycled content, substances of concern, carbon footprint and end-of-life information, with completeness scoring so missing fields surface before a delegated act applies. |
| Substance-level governance | Component-level data linked to the parent product, enabling SoC disclosure and SVHC tracking without a separate substance database. |
| Unsold-goods reporting readiness | CN-code attributes, batch tracking and structured inventory data that feed the standardised disclosure format. |
| GPP-ready data | The same sustainability attributes that satisfy ecodesign requirements feed Green Public Procurement tenders, with no duplicate record-keeping. |
| DPP readiness | Bluestone PIM holds the data that a Digital Product Passport needs to surface. The Digital Product Passport timeline covers DPP-specific capabilities in detail. |
Manufacturers in furniture, building products, apparel and electronics already use Bluestone PIM to centralise the data they will need to disclose under ESPR. The platform handles millions of SKUs with validation rules, governance and audit-grade edit history, which means compliance teams, product teams and channel teams work from the same record rather than reconciling three.
