ESPRRequirement taxonomyEU

EU Ecodesign for Sustainable Products Regulation Ecodesign Requirement Types

Use this page to separate ESPR performance requirements, information requirements, product parameters, and DPP dependencies before a product-specific delegated act applies.

The page stays at framework level: it explains how requirement types are set and evidenced without inventing product-group limits, dates, penalties, or final DPP fields.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
5

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Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

ESPR does not create one universal checklist for every product. It creates a framework for product-specific or horizontal ecodesign requirements, set mainly through delegated acts, that can take the form of performance requirements, information requirements, or both. Teams should therefore track the requirement type, the product parameter it uses, the delegated act that makes it operative, the DPP or data-carrier channel used to publish information, and the technical evidence needed to verify compliance.

Section 1

What are the ESPR ecodesign requirement types?

ESPR ecodesign requirements divide into two legal types: performance requirements and information requirements. Both are tied to product aspects and are laid down for covered product groups in delegated acts adopted under Article 4.

A team should not treat the framework regulation alone as a finished product rule. The operative requirement set depends on the relevant delegated act, which must define the covered product group, the applicable ecodesign requirements, verification methods, conformity-assessment module, technical-documentation elements, and transition details.

  • Performance requirements set minimum or maximum levels, or non-quantitative requirements, for relevant product parameters.
  • Information requirements require product information, including DPP and substances-of-concern information unless an exception applies.
  • Product parameters come from Annex I and include durability, repairability, recyclability, resource use, recycled content, carbon footprint, environmental footprint, waste generation, functional performance, and related sustainability parameters.
  • Delegated acts determine which requirements actually apply to a product group and how compliance information must be verified.
  • A DPP requirement is part of the information-requirement architecture, not a standalone substitute for meeting performance requirements.
Sources for this answer
Regulation (EU) 2024/1781 (ESPR)
Articles 6 and 7 define the two requirement types, Article 8 lists the elements delegated acts must specify, and Annex I lists the product parameters.
European Commission - Ecodesign for Sustainable Products Regulation
Commission overview explaining that ESPR enables performance and information rules for almost all categories of physical goods.
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Section 2

How do performance requirements differ from information requirements?

Performance requirements control product characteristics directly. Article 6 says products must comply with performance requirements laid down in the applicable delegated act, and those requirements are based on Annex I product parameters.

Information requirements control what must be made available about the product and how it is supplied. Article 7 includes DPP requirements and substances-of-concern tracking as minimum elements, and it can also require performance information, user and repair information, treatment-facility information, and other information that influences sustainable choices or product handling.

  • Performance evidence should map the product to the threshold, level, test method, calculation method, or non-quantitative condition in the delegated act.
  • Information evidence should map each required statement to its source data, update owner, language or access channel, and publication format.
  • Information requirements may be set for a product parameter even when no performance requirement is set for that same parameter.
  • Substances-of-concern information is not a generic marketing claim; Article 7 specifies tracked data such as substance identity, product location, concentration information, safe-use instructions, and end-of-life information.
  • Where a DPP exists, Article 7 requires the relevant information to be provided in the DPP and, where necessary, through other forms such as the product, packaging, label, manual, website, or application.
Sources for this answer
Regulation (EU) 2024/1781 (ESPR)
Article 6 covers performance requirements, Article 7 covers information requirements, and Annex I supplies the product-parameter basis.
Section 3

How do delegated acts control the requirement set?

The delegated act is the hinge between ESPR's framework language and product-level obligations. Article 8 requires delegated acts to specify the covered product group, ecodesign requirements, relevant Annex I parameters for which no requirement is necessary, methods or standards, digital-tool requirements where relevant, information needed for compliance verification, conformity assessment, manufacturer information, transitional period, and review date.

This matters operationally because the same Annex I parameter can drive different outputs. A delegated act might set a performance threshold, require disclosure, require a DPP data element, require a label, or decide that no ecodesign requirement is needed for that parameter for the product group.

  • Track the product group definition and commodity-code scope before assigning obligations.
  • Record each Annex I parameter considered and whether the delegated act sets a performance rule, information rule, both, or no requirement.
  • Separate legal applicability from data readiness: a DPP schema decision does not prove the product meets a performance requirement.
  • Tie each compliance method to the test, measurement, calculation standard, harmonised standard, or common specification named in the delegated act.
  • Avoid publishing dates or product-group requirements until the relevant delegated act or working-plan source supports them.
Sources for this answer
Regulation (EU) 2024/1781 (ESPR)
Article 8 lists the elements delegated acts must specify, including product group, requirements, methods, conformity assessment, verification information, transition period, and review timing.
European Commission - Ecodesign for Sustainable Products Regulation
Commission overview confirming that ESPR establishes a framework for setting requirements on specific product groups and can also support horizontal rules.
Section 4

Where do DPPs and data carriers fit?

A DPP is part of the information-requirement system. Article 9 says products can be placed on the market or put into service only if a DPP is available in accordance with the applicable delegated act and DPP requirements, where that requirement applies.

Article 10 connects the DPP through a data carrier to a persistent unique product identifier. The delegated act specifies the data to include, the data carrier or carriers, the layout and positioning of the carrier, whether the passport is at model, batch, or item level, who can access data, who can create or update data, and how long the passport remains available.

  • Do not design a fixed DPP field list for all ESPR products; Annex III lists possible data elements and the delegated act selects what is required for the product group.
  • Keep DPP granularity explicit: model, batch, or item level changes evidence ownership and update logic.
  • Keep data-carrier placement explicit because Article 10 allows the product, packaging, or accompanying documentation as specified by the delegated act.
  • Plan access rights separately for public users, value-chain actors, market surveillance authorities, and customs authorities.
  • Treat data accuracy, completeness, currency, interoperability, security, privacy, and fraud prevention as DPP design controls, not just website-display details.
Sources for this answer
Regulation (EU) 2024/1781 (ESPR)
Articles 9 and 10 define the DPP and data-carrier relationship, while Annex III lists data categories that delegated acts may require or allow.
ETSI ES 204 082 - Digital sustainable product passport information model
ETSI source from the grounding set supports DPP design implications around product granularity, information items, conformity evidence, and access to sustainability data.
Section 5

What evidence should support each requirement type?

Evidence should mirror the requirement type. For performance requirements, keep the product data, measurements, calculations, test reports, and comparison against the delegated-act requirement. For information requirements, keep the source data, publication channel, DPP field mapping, substance-tracking data where required, and proof that the information remains accurate and accessible.

Annex IV describes internal production control and technical documentation. It expects documentation that allows conformity assessment against the delegated act, including design and manufacturing information, standards or technical specifications used, design calculations, examinations, measurements against ecodesign requirements, test reports, and a copy of the information provided under Article 7.

  • For performance rules, maintain a trace from Annex I parameter to delegated-act requirement to test or calculation result.
  • For information rules, maintain a trace from required statement to source data, publication channel, language/access decision, and update owner.
  • For DPP rules, maintain a trace from delegated-act field requirement to model, batch, or item identifier, access right, data-carrier placement, and backup or service-provider control.
  • For market-surveillance readiness, keep the technical documentation and declaration-of-conformity package aligned with the delegated act and available for authority requests.
  • For unsupported claims, record the gap instead of turning framework-level ESPR language into product-specific requirements.
Sources for this answer
Regulation (EU) 2024/1781 (ESPR)
Annex IV describes technical documentation for internal production control and requires evidence such as measurements, test reports, and copies of Article 7 information.
ETSI ES 204 082 - Digital sustainable product passport information model
ETSI source from the grounding set supports evidence implications for DPP information models, including expected evidence and references to conformity evidence.
Primary sources

References and citations

Regulation (EU) 2024/1781 (ESPR)
data.europa.eu
Referenced sections
  • Annex IV describes technical documentation for internal production control and requires evidence such as measurements, test reports, and copies of Article 7 information.
"technical documentation shall specify the applicable requirements"
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