ESPR replaces the Ecodesign Directive as the wider EU framework for sustainable product requirements.
This comparison helps separate the older energy-related product regime from ESPR's broader product scope, DPP architecture, unsold-goods rules, and transition evidence.
Regulation (EU) 2024/1781 (ESPR) repealed the Ecodesign Directive on 18 July 2024, but it did not erase the Directive's product-specific implementing measures. ESPR broadens the framework beyond energy-related products, uses delegated acts for product-group or horizontal requirements, and adds Digital Product Passport, unsold-goods, and market-surveillance rules. keeps specified Directive provisions and implementing measures alive for defined purposes and periods. The controlling rule therefore depends on the product group, the current product-specific act, the obligation, and the transition branch.
Comparison matrix
ESPR vs Ecodesign Directive: side-by-side compliance comparison
Read each row as a control point for product-roadmap, evidence, and market-access planning. The key question is whether a product is still governed by an existing Directive 2009/125/EC implementing measure, by an ESPR delegated act, or by both during transition.
Regulation (EU) 2024/1781 establishes the new framework for setting ecodesign requirements for sustainable products and repeals Directive 2009/125/EC with transition rules.
Second framework
Ecodesign Directive
Directive 2009/125/EC was the earlier framework for setting ecodesign requirements for energy-related products through implementing measures.
ESPR vs Ecodesign Directive: side-by-side compliance comparison
ESPR extends the ecodesign approach to almost all physical goods placed on the EU market or put into service, with specific exclusions and product-specific tailoring through later acts.
The Ecodesign Directive focused on energy-related products. Existing implementing measures under that framework remain important for covered product groups until they are repealed, replaced, or declared obsolete.
Do not treat an existing Ecodesign Directive product conclusion as enough for ESPR. Check whether the product is energy-related and already covered by an implementing measure, then separately check whether an ESPR product group or horizontal requirement is being developed.
ESPR assigns role-specific duties to manufacturers, authorised representatives, importers, distributors, dealers, and fulfilment service providers. Online marketplaces and search engines have cooperation duties, and covered economic operators can have separate unsold-goods duties.
The Directive framework placed core conformity duties on manufacturers and, where the manufacturer was not established in the Union and had no authorised representative, on the importer. Product-specific implementing measures could define further information and conformity requirements.
Record the operator role as well as the product rule. Do not carry a Directive-era manufacturer or importer allocation into ESPR without checking the current delegated act and ESPR's role-specific provisions.
ESPR gives the Commission power to set product-specific or horizontal ecodesign requirements through delegated acts. Those acts determine the actual requirements for a product group.
The Ecodesign Directive used implementing measures adopted for specific energy-related product groups. Those measures can still control products during the ESPR transition.
The practical trigger is not the ESPR title alone. A product team needs the current product-group act, the requirement parameter, and any transition provision before changing design, labelling, conformity, or evidence processes.
ESPR explicitly covers performance requirements and information requirements. The Commission overview lists durability, reusability, upgradability, reparability, maintenance, refurbishment, energy and resource efficiency, substances inhibiting circularity, recycled content, remanufacturing, recycling, footprint, waste, and sustainability information as possible areas.
The Ecodesign Directive was centred on energy-related products, although earlier implementing measures also included some circularity aspects such as durability, repairability, and recyclability.
Map each product requirement to its legal source and parameter. Do not infer a recycled-content, DPP, repair, or disclosure obligation for a product unless the relevant delegated or implementing act actually sets it.
ESPR strengthens market-surveillance planning and corrective-action mechanics. For products covered by ESPR delegated acts, authorities can evaluate compliance, require corrective action, restrict or withdraw products, and rely on technical documentation and declaration-of-conformity evidence.
The Ecodesign Directive also used conformity assessment, technical documentation, declarations, and safeguard mechanisms for products covered by its implementing measures.
Keep evidence at product-model level: applicable act, harmonised standards or common specifications used, measurement results, information provided under information requirements, declaration of conformity, and retained technical documentation. Transition products may need both the old implementing-measure record and ESPR market-surveillance response readiness.
ESPR entered into force on 18 July 2024. A product-group delegated act generally cannot apply earlier than 18 months after entry into force unless the act states a justified exception. Its own application date, not a working-plan or consultation date, starts the product requirement.
Directive 2009/125/EC was repealed on 18 July 2024 subject to . Specified provisions continue until 31 December 2026 for listed product groups, until 31 December 2030 only for technical amendments to existing measures, or until the relevant implementing measure is repealed or declared obsolete, depending on the branch.
Keep separate dates for framework repeal, the legacy implementing measure, the branch, the ESPR delegated act's entry into force, and its application date. Do not convert a transition end date into a universal deadline for every product or obligation.
ESPR links non-compliance to the market-surveillance framework. Authorities can require proportionate corrective action and, where it is not taken, restrict or prohibit availability, withdraw a product, or recall it. Member States set penalties, and ESPR permits recovery of document-inspection and physical-testing costs in specified non-compliance cases.
The Directive used Member State market surveillance and a safeguard procedure for products covered by implementing measures. now determines which Directive enforcement provisions continue for legacy measures, while specified ESPR free-movement, circumvention, and enforcement provisions also apply to those products.
Tie every authority response to the current product measure and transition provision. An ESPR unsold-goods breach, an ESPR delegated-act breach, and non-compliance with a surviving Directive implementing measure can require different evidence and corrective-action paths.
ESPR repealed Directive 2009/125/EC with effect from 18 July 2024, but preserves specified Directive provisions for defined transitional cases. Some provisions continue until 31 December 2026 for listed product groups; limited amendments needed to address technical issues in existing implementing measures can continue until 31 December 2030; and other legacy provisions continue for products covered by implementing measures until those measures are repealed or declared obsolete.
The Ecodesign Directive side remains relevant mainly through product-specific implementing measures and transitional provisions, not as a source for new ESPR-only obligations such as the DPP system or unsold-goods regime.
When briefing a product team, cite the exact current source: ESPR framework article, ESPR delegated act, legacy Directive implementing measure, or transition clause. Leave dates, penalties, and product obligations blank unless the cited source states them for that product group.
If a product is already covered by a valid Directive 2009/125/EC implementing measure, use that measure for the legacy requirements that still apply during the transition.
If an ESPR delegated act covers the same product group or requirement, use the ESPR act for the new framework requirements and keep the transition crosswalk in view.
First identify the current legal act, then check transition rules before retiring old evidence or replacing a product-specific implementing measure with an ESPR workflow.
ESPR extends the ecodesign approach to almost all physical goods placed on the EU market or put into service, with specific exclusions and product-specific tailoring through later acts.
The Ecodesign Directive focused on energy-related products. Existing implementing measures under that framework remain important for covered product groups until they are repealed, replaced, or declared obsolete.
Do not treat an existing Ecodesign Directive product conclusion as enough for ESPR. Check whether the product is energy-related and already covered by an implementing measure, then separately check whether an ESPR product group or horizontal requirement is being developed.
ESPR assigns role-specific duties to manufacturers, authorised representatives, importers, distributors, dealers, and fulfilment service providers. Online marketplaces and search engines have cooperation duties, and covered economic operators can have separate unsold-goods duties.
The Directive framework placed core conformity duties on manufacturers and, where the manufacturer was not established in the Union and had no authorised representative, on the importer. Product-specific implementing measures could define further information and conformity requirements.
Record the operator role as well as the product rule. Do not carry a Directive-era manufacturer or importer allocation into ESPR without checking the current delegated act and ESPR's role-specific provisions.
ESPR gives the Commission power to set product-specific or horizontal ecodesign requirements through delegated acts. Those acts determine the actual requirements for a product group.
The Ecodesign Directive used implementing measures adopted for specific energy-related product groups. Those measures can still control products during the ESPR transition.
The practical trigger is not the ESPR title alone. A product team needs the current product-group act, the requirement parameter, and any transition provision before changing design, labelling, conformity, or evidence processes.
ESPR explicitly covers performance requirements and information requirements. The Commission overview lists durability, reusability, upgradability, reparability, maintenance, refurbishment, energy and resource efficiency, substances inhibiting circularity, recycled content, remanufacturing, recycling, footprint, waste, and sustainability information as possible areas.
The Ecodesign Directive was centred on energy-related products, although earlier implementing measures also included some circularity aspects such as durability, repairability, and recyclability.
Map each product requirement to its legal source and parameter. Do not infer a recycled-content, DPP, repair, or disclosure obligation for a product unless the relevant delegated or implementing act actually sets it.
ESPR strengthens market-surveillance planning and corrective-action mechanics. For products covered by ESPR delegated acts, authorities can evaluate compliance, require corrective action, restrict or withdraw products, and rely on technical documentation and declaration-of-conformity evidence.
The Ecodesign Directive also used conformity assessment, technical documentation, declarations, and safeguard mechanisms for products covered by its implementing measures.
Keep evidence at product-model level: applicable act, harmonised standards or common specifications used, measurement results, information provided under information requirements, declaration of conformity, and retained technical documentation. Transition products may need both the old implementing-measure record and ESPR market-surveillance response readiness.
ESPR entered into force on 18 July 2024. A product-group delegated act generally cannot apply earlier than 18 months after entry into force unless the act states a justified exception. Its own application date, not a working-plan or consultation date, starts the product requirement.
Directive 2009/125/EC was repealed on 18 July 2024 subject to . Specified provisions continue until 31 December 2026 for listed product groups, until 31 December 2030 only for technical amendments to existing measures, or until the relevant implementing measure is repealed or declared obsolete, depending on the branch.
Keep separate dates for framework repeal, the legacy implementing measure, the branch, the ESPR delegated act's entry into force, and its application date. Do not convert a transition end date into a universal deadline for every product or obligation.
ESPR links non-compliance to the market-surveillance framework. Authorities can require proportionate corrective action and, where it is not taken, restrict or prohibit availability, withdraw a product, or recall it. Member States set penalties, and ESPR permits recovery of document-inspection and physical-testing costs in specified non-compliance cases.
The Directive used Member State market surveillance and a safeguard procedure for products covered by implementing measures. now determines which Directive enforcement provisions continue for legacy measures, while specified ESPR free-movement, circumvention, and enforcement provisions also apply to those products.
Tie every authority response to the current product measure and transition provision. An ESPR unsold-goods breach, an ESPR delegated-act breach, and non-compliance with a surviving Directive implementing measure can require different evidence and corrective-action paths.
ESPR repealed Directive 2009/125/EC with effect from 18 July 2024, but preserves specified Directive provisions for defined transitional cases. Some provisions continue until 31 December 2026 for listed product groups; limited amendments needed to address technical issues in existing implementing measures can continue until 31 December 2030; and other legacy provisions continue for products covered by implementing measures until those measures are repealed or declared obsolete.
The Ecodesign Directive side remains relevant mainly through product-specific implementing measures and transitional provisions, not as a source for new ESPR-only obligations such as the DPP system or unsold-goods regime.
When briefing a product team, cite the exact current source: ESPR framework article, ESPR delegated act, legacy Directive implementing measure, or transition clause. Leave dates, penalties, and product obligations blank unless the cited source states them for that product group.
If a product is already covered by a valid Directive 2009/125/EC implementing measure, use that measure for the legacy requirements that still apply during the transition.
If an ESPR delegated act covers the same product group or requirement, use the ESPR act for the new framework requirements and keep the transition crosswalk in view.
First identify the current legal act, then check transition rules before retiring old evidence or replacing a product-specific implementing measure with an ESPR workflow.
How should teams decide which framework controls a product?
Start with the product group: identify any existing Directive 2009/125/EC implementing measure and any ESPR working-plan, delegated-act, or horizontal-rule activity.
Separate old and new evidence: legacy Ecodesign Directive files may support conformity history, but ESPR DPP, unsold-goods, and wider sustainability requirements need their own source mapping.
Use as the transition checkpoint before retiring Directive 2009/125/EC evidence or assuming ESPR has displaced a product-specific implementing measure.
What changed from the Ecodesign Directive to ESPR?
The biggest change is scope. Directive 2009/125/EC was the framework for energy-related products. ESPR takes the ecodesign approach and applies it to a much broader sustainable-products framework, with later delegated acts setting the concrete requirements for specific product groups or horizontal topics.
The second change is architecture. ESPR adds Digital Product Passport mechanics, unsold-consumer-product rules, and expanded market-surveillance coordination. Those elements should not be backfilled into old Ecodesign Directive compliance files unless a current ESPR source or delegated act supports the claim.
Use Directive 2009/125/EC implementing measures for legacy covered energy-related products where transition rules keep them relevant.
Use Regulation (EU) 2024/1781 and its delegated acts for ESPR product requirements, DPP obligations, unsold-goods controls, and new evidence expectations.
Keep product obligations blank when the framework exists but the product-specific delegated act has not yet set the requirement.
Map each product group to existing Ecodesign Directive measures, ESPR transition rules, delegated-act status, DPP data needs, and retained evidence before changing public claims or conformity workflows.
Do not retire a Directive-era product file because ESPR repealed the framework directive on 18 July 2024. preserves different parts of Directive 2009/125/EC for different purposes and periods. The applicable legacy implementing measure remains the starting point for a product already covered by it.
For the product groups listed in (1)(a)(i), specified Directive provisions continue until 31 December 2026. Article 79(1)(a)(ii) also permits specified Directive provisions to continue until 31 December 2030 for products covered by existing implementing measures, but only where amendments are needed to address technical issues with those measures. Separate provisions continue under Article 79(1)(b) until the relevant implementing measures are repealed or declared obsolete.
Identify the exact legacy implementing measure and the product model it covers.
Record which branch preserves the relevant Directive provision and the end condition for that branch.
Keep the legacy conformity assessment, technical documentation, declaration, test results, and market-surveillance records until the controlling measure and retention rule allow disposal.
Add an ESPR workstream only when a new delegated act, horizontal rule, DPP requirement, or other directly applicable ESPR provision creates a separate duty.
Binding source for the 18 July 2024 repeal, the 31 December 2026 and 31 December 2030 transition branches, and the provisions that continue until a legacy implementing measure is repealed or declared obsolete.