Ecodesign for Sustainable Products Regulation: what binds an online seller now, and what comes later

The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationThe whole regulationClick opens the law on the EU Publications Office. or ESPR, is the EU framework for making products last longer, repair better and recycle more easily. It has been in force since 18 July 2024 and covers almost every physical good placed on the EU market, including goods that come from outside the EU (Art. 80Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 80Click opens the article on EUR-Lex., Art. 1(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 1, paragraph 2Click opens the article on EUR-Lex., Art. 2(40)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 40Click opens the article on EUR-Lex.). By itself it sets no requirement for any product. It tells the Commission how to set requirements, product group by product group, in delegated acts. One part of it already binds: the ban on destroying unsold clothes and shoes.

What the ESPR covers

The Regulation sets a framework for ecodesign requirements that products must meet to be placed on the market or put into service. It also creates the digital product passport, provides for mandatory green public procurement requirements, and sets rules against destroying unsold consumer products (Art. 1(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 1, paragraph 1Click opens the article on EUR-Lex.). It applies to any physical good placed on the market or put into service, components and intermediate products included (Art. 1(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 1, paragraph 2Click opens the article on EUR-Lex.).

It does not apply to food, feed, medicinal and veterinary medicinal products, living plants, animals and micro-organisms, products of human origin, products of plants and animals relating directly to their future reproduction, and vehicles for the aspects that sector laws already regulate (Art. 1(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 1, paragraph 2Click opens the article on EUR-Lex., points (a) to (h)).

The ESPR replaces the Ecodesign Directive, Directive 2009/125/EC, which covered only energy-related products (Commission overview; Art. 79(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 79, paragraph 1Click opens the article on EUR-Lex.). The rules apply to products made inside and outside the EU (Commission). A product counts as placed on the market when it is first made available on the EU market (Art. 2(40)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 40Click opens the article on EUR-Lex.).

How this fits the other EU product rules for a business outside the EU is on selling into the EU.

No act amends the Regulation as of 5 October 2026. The corrigenda of 7 August 2024 and 28 April 2025 correct wording and cross-references in Articles 10Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 10Click opens the article on EUR-Lex., 20Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 20Click opens the article on EUR-Lex., 41Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 41Click opens the article on EUR-Lex., 65Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 65Click opens the article on EUR-Lex., 69Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 69Click opens the article on EUR-Lex., 77Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 77Click opens the article on EUR-Lex. and 78Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 78Click opens the article on EUR-Lex.; none changes a duty described here.

What applies now, and what waits

The measures adopted under the old Ecodesign Directive stay in place. The EU energy label is a separate law, Regulation (EU) 2017/1369Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)The whole regulationClick opens the law on the EU Publications Office., covered in the EU energy label guide. The ESPR rules on free movement (Art. 3Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 3Click opens the article on EUR-Lex.), on preventing circumvention (Art. 40Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 40Click opens the article on EUR-Lex.) and on market surveillance, products presenting a risk and formal non-compliance (Art. 66Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 66Click opens the article on EUR-Lex. to Art. 71Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 71Click opens the article on EUR-Lex.) apply to the products those measures cover (Art. 79(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 79, paragraph 1Click opens the article on EUR-Lex., Art. 79(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 79, paragraph 2Click opens the article on EUR-Lex.). Art. 40(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 40, paragraph 1Click opens the article on EUR-Lex. bars any behaviour, whether contractual, commercial, technical or other, that undermines the compliance of products. The Commission describes a transition lasting until 2030 (Commission). Under the Market Surveillance Regulation, a product subject to the old Directive may be placed on the market only if an economic operator established in the EU is responsible for it (Regulation (EU) 2019/1020, Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex. and 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex.). For an energy-labelled product, the supplier’s registration of each model in the EU database is on the EPREL guide.

How a product group gets ecodesign requirements

Requirements come by delegated act, one product group at a time, or for several groups at once in a horizontal act (Art. 4(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 5(4)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 5, paragraph 4Click opens the article on EUR-Lex., Art. 5(7)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 5, paragraph 7Click opens the article on EUR-Lex.). The Commission may also set requirements for groups that are not in its working plan (Art. 5(6)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 5, paragraph 6Click opens the article on EUR-Lex.). Each act:

• names the product group by commodity code and description;
• sets performance requirements, information requirements or both. They can cover durability, reliability, repairability, upgradability, recycled content, recyclability, energy and water use, substances of concern, carbon and environmental footprint, and waste;
• names the test methods, the conformity assessment module, the date of review and the transition for national rules (Art. 5(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 5, paragraph 1Click opens the article on EUR-Lex., Art. 6Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 6Click opens the article on EUR-Lex., Art. 7Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 7Click opens the article on EUR-Lex., Art. 8Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 8Click opens the article on EUR-Lex.).

Information requirements always include the digital product passport, with two exceptions: a horizontal act need not require one, and the Commission may exempt a group where no technical specifications exist yet or where another EU law already gives the same information digitally (Art. 7(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 7, paragraph 2Click opens the article on EUR-Lex., Art. 9(4)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 9, paragraph 4Click opens the article on EUR-Lex.). The working plan names EPREL, the EU energy label database, as such an alternative for energy-labelled products (COM(2025) 187, section 3.2). What the passport is and how it is made is in the digital product passport guide.

What changes for a product once an act applies.

• The product may be placed on the market only if it meets the act (Art. 3(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 3, paragraph 1Click opens the article on EUR-Lex.).
• The manufacturer runs the conformity assessment the act names, draws up technical documentation and an EU declaration of conformity, and affixes the CE marking (Art. 4(5)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex., Art. 27(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 27, paragraph 2Click opens the article on EUR-Lex.).
• A product that follows a harmonised standard is presumed to meet the requirements the standard covers (Art. 41(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 41, paragraph 3Click opens the article on EUR-Lex.).
• No EU country may block a compliant product with its own national requirements on the same parameters (Art. 3(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 3, paragraph 2Click opens the article on EUR-Lex.).
• A non-compliant product may be shown at a trade fair if a visible sign says it does not comply and is not for sale until it does (Art. 3(5)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 3, paragraph 5Click opens the article on EUR-Lex.).
• Where an act requires a label, the act sets its content and layout, and a look-alike label that could mislead buyers is banned (Art. 16(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex., Art. 17Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 17Click opens the article on EUR-Lex.).

The Commission has to give businesses enough time, with particular attention to SMEs and microenterprises, and EU countries have to help those businesses comply, for example with one-stop shops (Art. 4(4)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 4, paragraph 4Click opens the article on EUR-Lex., Art. 22Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 22Click opens the article on EUR-Lex.).

Which product groups the Commission plans to cover, and when

The ESPR told the Commission which groups to put first: iron and steel, aluminium, textiles (garments and footwear in particular), furniture including mattresses, tyres, detergents, paints, lubricants, chemicals, energy-related products, and ICT and other electronics (Art. 18(5)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 18, paragraph 5Click opens the article on EUR-Lex.). The first working plan, adopted on 16 April 2025, turned that into this list (COM(2025) 187, section 2.2.1):

These are years of adoption, not of application. Each act then gives at least 18 months before it binds (Art. 4(4)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 4, paragraph 4Click opens the article on EUR-Lex.). The plan carries over sixteen energy-related products from the old ecodesign plan (section 2.2.2):

ICT products are not a line of their own. They are covered through the two horizontal measures and the energy-related list. The plan leaves out detergents, paints and lubricants, which have lower impacts than the groups it picked (section 2.2.3). Footwear gets only a study, due by the end of 2027, and chemicals a scoping study.

The Commission’s own timeline for the passport adds the dates it expects for the acts: iron and steel in the fourth quarter of 2026, textiles, aluminium and tyres in the third and fourth quarters of 2027, furniture in 2028 and mattresses and ICT products in 2029 (Commission timeline). On 5 October 2026 no delegated act setting ecodesign requirements for a product group had been adopted. The acts the Publications Office lists as adopted under the Regulation concern the Ecodesign Forum, unsold goods, the passport registry and the passport standards. The plan is reviewed in 2028 and can change.

Who does what once a delegated act covers your product

The duties below bind only for products covered by a delegated act. None binds a product today. The passport duties of each role are in the digital product passport guide; the table here covers the rest.

Who the manufacturer is. The manufacturer is whoever makes a product, or has it designed or made, and markets it under their own name or trade mark (Art. 2(42)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 42Click opens the article on EUR-Lex.). If a factory makes your goods and you sell them under your brand, you carry the manufacturer’s duties.

Who the importer is when you sell from outside the EU. The Regulation defines the importer as a business established in the EU that places a product from a third country on the EU market (Art. 2(44)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 44Click opens the article on EUR-Lex.). The Market Surveillance Regulation adds the rule for a seller outside the EU. A product covered by it may be placed on the market only if an economic operator established in the EU is responsible for it. That operator is an EU manufacturer, an importer where the manufacturer is outside the EU, an authorised representative with a written mandate, or, where none of those exists, an EU fulfilment service provider (Regulation (EU) 2019/1020, Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex. and 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex., which lists the old Ecodesign Directive; Art. 79(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 79, paragraph 3Click opens the article on EUR-Lex. reads references to that Directive as references to the ESPR). The offer must name that operator (Art. 36(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 36, paragraph 1Click opens the article on EUR-Lex., point (b)). The same chain sets who answers to a consumer harmed by a non-compliant product (Art. 76Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 76Click opens the article on EUR-Lex.). The role is the one the EU Responsible Person guide covers.

What online marketplaces must do

For the ESPR, a provider of an online marketplace is an intermediary service that lets customers conclude distance contracts with businesses for products covered by a delegated act (Art. 2(54)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 54Click opens the article on EUR-Lex.). It is not an economic operator under the Regulation: that term lists the manufacturer, the authorised representative, the importer, the distributor, the dealer and the fulfilment service provider (Art. 2(46)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 46Click opens the article on EUR-Lex.). The seller on the marketplace carries the product duties above. The marketplace carries its own:

• the Digital Services Act duties on a single point of contact and on tracing the traders that sell through it (Art. 35(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 35, paragraph 1Click opens the article on EUR-Lex.; Regulation (EU) 2022/2065, Art. 11Regulation (EU) 2022/2065, Digital Services ActArticle 11Click opens the article on EUR-Lex. and 30Regulation (EU) 2022/2065, Digital Services ActArticle 30Click opens the article on EUR-Lex.);
• cooperation with market surveillance authorities, on request and in specific cases, to end or limit the non-compliance of a product offered through it (Art. 35(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 35, paragraph 1Click opens the article on EUR-Lex.);
• removal of listings: national authorities can order a marketplace to act against specific listings of a non-compliant covered product, including by removing them, and such listings count as illegal content under the Digital Services Act (Art. 35(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 35, paragraph 2Click opens the article on EUR-Lex.);
• one contact point for those authorities, which may be the one it already runs under GPSR or the Digital Services Act (Art. 35(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 35, paragraph 3Click opens the article on EUR-Lex.).

For your listings this means two things once a product group is covered. The business that placed the product on the market owes the marketplace a digital copy of the passport code within five working days of a request (Art. 10(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 10, paragraph 3Click opens the article on EUR-Lex.). And a listing for a covered product that breaks the rules can be taken down on an authority’s order. What marketplaces ask for under GPSR today is in GPSR marketplace requirements.

What the ban on destroying unsold clothes and shoes means for you

Since 19 July 2026, destroying the unsold consumer products listed in Annex VII is prohibited (Art. 25(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 1Click opens the article on EUR-Lex.). The list uses the EU’s combined nomenclature codes:

What counts. Destruction is intentionally damaging a product or discarding it as waste. Passing it on only to be prepared for reuse, refurbished or remanufactured is not destruction (Art. 2(34)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 34Click opens the article on EUR-Lex.). The recitals add that recycling, other recovery and disposal all count as destruction (recital 55; Decision (EU) 2026/1435, recital 4). Unsold covers surplus stock, excess inventory and deadstock, and goods returned by a consumer under the right of withdrawal, or during any longer period you offer (Art. 2(37)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 37Click opens the article on EUR-Lex.). Only products mainly meant for consumers count; components and intermediate products never do (Art. 2(36)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 36Click opens the article on EUR-Lex.).

Who is bound. The ban binds economic operators: manufacturers, authorised representatives, importers, distributors, dealers and fulfilment service providers (Art. 2(46)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 46Click opens the article on EUR-Lex.). The ban does not apply to micro and small enterprises, and reaches medium-sized ones from 19 July 2030 (Art. 25(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 1Click opens the article on EUR-Lex.). Everyone else is bound now: the Commission describes it as large enterprises from 19 July 2026 (Decision (EU) 2026/1435, recital 5).

The size test. The EU definition applies (Recommendation 2003/361/EC, Annex, Art. 2; Art. 2Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2Click opens the article on EUR-Lex.).

The figures are those of your latest approved accounts. You lose or gain a size only if you exceed or fall below the ceilings over two consecutive accounting periods (its Art. 4). A partner enterprise is one that holds 25 % or more of your capital or voting rights, or that you hold that much of. Its figures are added in proportion to the holding, and those of a linked enterprise are added in full, so a small company linked to a large one is counted with the large one’s figures and is not small (its Art. 3 and 6).

No way round it. A business outside the ban may not destroy goods supplied to it to get around the ban (Art. 25(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 2Click opens the article on EUR-Lex.). Every business, whatever its size, takes the measures that can reasonably be expected to prevent the need to destroy unsold consumer products (Art. 23Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 23Click opens the article on EUR-Lex.). The Commission may extend the ban or the disclosure duty to micro and small enterprises where there is sufficient evidence that they could be used to circumvent it (Art. 25(5)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 5Click opens the article on EUR-Lex., second subparagraph).

What to do with the stock instead. The Commission says: sell it, including through discounts or alternative markets; donate it to charities or social enterprises; or prepare it for reuse by repairing, refurbishing or remanufacturing it (news of 17 July 2026).

When destruction stays allowed. Delegated Regulation (EU) 2026/296 lists the cases, and you must be able to produce the proof (its Art. 2 and 3):

• the product is dangerous within the meaning of GPSR;
• it breaks another EU or national law, and destruction is required or is the proportionate corrective action;
• it infringes intellectual property rights, or a licence bars selling it after a date that has passed;
• its labels, logos or designs are protected or inappropriate and cannot be removed or made inaccessible, so it cannot be prepared for reuse;
• it is damaged, deteriorated or contaminated and repair is not technically feasible or cost-effective, or it is unfit for purpose through a defect that cannot technically be repaired;
• where none of the cases above applies, it was offered for donation for at least eight weeks, either directly to at least three suitable social economy entities in the EU or on an easily accessible page of your website, and nobody accepted it;
• it reached a social economy entity as a donation and no recipient was found, or a waste treatment operator prepared it for reuse and no recipient was found.

Keep the proof for five years, in electronic form, and hand it to the authorities within 30 days of a request. Give the waste treatment operator a statement naming the derogation you used (its Art. 3 and 4). Where a derogation applies, destruction follows the waste hierarchy and recycling comes first (its recital 3). The digital product passport guide has the proof for each case.

Other products and national rules. The Commission may add products to Annex VII by delegated act (Art. 25(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 3Click opens the article on EUR-Lex.). It says it does not intend to in the first working plan, because the disclosure data it needs for a ban are not yet in (COM(2025) 187, section 4.2). EU countries may keep or introduce national rules on destruction for products outside the ban, if those rules respect EU law (recital 59). The Commission has approved, for consumer products, France’s rule under which producers, importers and distributors of non-food products must reuse, prepare for reuse or recycle their unsold products. It applies to all businesses, for goods not in Annex VII, until harmonised EU rules at least as strict apply, and for Annex VII goods to medium-sized businesses until 19 July 2030 (Decision (EU) 2026/1435, recitals 7 to 9 and Art. 1 to 3). The ban is separate from producer responsibility for textiles, which each EU country is setting up; that is in textile EPR.

What large businesses publish about discarded stock

A business that discards unsold consumer products, itself or through someone else, publishes each year, on an easily accessible page of its website: how many it discarded and their weight, by type of product; why; the share sent to preparing for reuse, recycling, other recovery or disposal; and what it did and plans to do to prevent it. This covers every consumer product, not only clothes and shoes. It does not apply to micro and small enterprises and reaches medium-sized ones from 19 July 2030. On request it proves where the goods went within 30 days (Art. 24(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 1Click opens the article on EUR-Lex., Art. 24(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 2Click opens the article on EUR-Lex.).

The first disclosure covers the first full financial year during which the Regulation is in force, which is 2025 for a business whose financial year is the calendar year (Art. 24(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 1Click opens the article on EUR-Lex., Art. 80Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 80Click opens the article on EUR-Lex.). Implementing Regulation (EU) 2026/2 fixes the format. It applies from 2 March 2027, to goods discarded in each financial year from the first full one after that date, and the disclosure is due within 12 months after the year ends (its Art. 1 and 7). Products are grouped by the first two digits of their combined nomenclature code, four digits for the products its Annex II lists (its Art. 3). The records behind it are kept for five years after the disclosure (its Art. 4). A business that reports on sustainability in its management report may put the information there, and, if it uses the common format, link to that report from its website (Art. 24(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 1Click opens the article on EUR-Lex.; its Art. 2). Donated goods are not discarded and are not reported (its recital 3).

What happens if you do nothing

Each EU country sets the penalties for breaking the ESPR. They must be effective, proportionate and dissuasive. Each country must at least be able to impose fines and a time-limited exclusion from public procurement, which does not mean every breach carries both. The Regulation sets no amount (Art. 74(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 74, paragraph 1Click opens the article on EUR-Lex., Art. 74(3)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 74, paragraph 3Click opens the article on EUR-Lex.). For the destruction ban, the Commission says national authorities check compliance and can impose fines (news of 17 July 2026).

For a covered product, the product itself can be stopped. If an authority finds that the CE marking, the declaration of conformity, the technical documentation or the manufacturer’s or importer’s contact details are missing or wrong, or that another administrative requirement is not met, it orders the business to put it right and, if that persists, restricts or prohibits the product or has it withdrawn or recalled (Art. 71(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 71, paragraph 1Click opens the article on EUR-Lex., Art. 71(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 71, paragraph 2Click opens the article on EUR-Lex.). If it finds that a product presents a risk, it requires corrective action after an evaluation, and takes provisional measures if the business does not act (Art. 69Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 69Click opens the article on EUR-Lex.). A marketplace can be ordered to remove the listing (Art. 35(2)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 35, paragraph 2Click opens the article on EUR-Lex.).

A consumer harmed by a covered product that breaks its ecodesign requirements can claim from the manufacturer. If the manufacturer is outside the EU, the claim goes to the importer or the authorised representative; if there is neither in the EU, to the fulfilment service provider (Art. 76Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 76Click opens the article on EUR-Lex.).

What you can skip for now

What the law leaves open

• Which products and when. The working plan gives indicative years and is reviewed in 2028. An act may also reach a group outside the plan (Art. 5(6)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 5, paragraph 6Click opens the article on EUR-Lex.). Until an act exists for your product group, nobody can tell you exactly what it will require.
• Disposal orders to a warehouse. The ban does not say in terms whether a disposal order you give is your own destruction. The ban itself prohibits the destruction, whoever does it, and a fulfilment service provider is an economic operator (Art. 25(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 25, paragraph 1Click opens the article on EUR-Lex., Art. 2(46)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 2, point 46Click opens the article on EUR-Lex.). The disclosure duty counts goods discarded on a business’s behalf (Art. 24(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 1Click opens the article on EUR-Lex.). No business may act in any way, contractual or commercial included, that undermines compliance (Art. 40(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 40, paragraph 1Click opens the article on EUR-Lex.). The operator that delivers the goods to the waste treatment operator gives the statement on the derogation (Delegated Regulation (EU) 2026/296, Art. 4). Our reading: treat a disposal order you give a warehouse or a marketplace fulfilment service as your own destruction.
• The exact day of the earlier disclosures. The ESPR requires disclosure every year, covering the preceding financial year, starting with the first full financial year in force, 2025 for a calendar year (Art. 24(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 24, paragraph 1Click opens the article on EUR-Lex.). So the 2025 disclosure falls due in 2026 and the 2026 one in 2027. Recital 8 of Implementing Regulation (EU) 2026/2 says the later start of the common format does not affect that duty. The 12-month deadline counts only from the first full financial year after 2 March 2027 (its Art. 1). No text gives a day-level deadline for the years before.
• More products under the ban. Annex VII holds clothing, accessories and footwear. The Commission can add products, and has said it does not plan to in the first working plan.
• Pending changes. A Commission proposal of 21 May 2025 would amend the ESPR as regards digitalisation and common specifications (COM(2025) 504). A proposal of 9 September 2026 on public procurement would delete Art. 65 (green public procurement) and the procurement-exclusion penalty in Art. 74(3), point (b), and move both into the new Act (COM(2026) 590, Art. 147(1)). Neither proposal had been adopted by 5 October 2026.