EU Ecodesign for Sustainable Products Regulation Which products are in scope of the ESPR

ESPR applies broadly to physical goods placed on the EU market or put into service, including components and intermediate products. Begin the scope review with the product, its route to the EU market, and whether it is a component or intermediate product rather than only a finished consumer item.

Do not treat broad ESPR scope as proof that a specific product already has detailed ecodesign limits, passport fields, test methods, or conformity routes. Those details depend on delegated acts adopted for the relevant product group.

Article 1 excludes food, feed, human and veterinary medicinal products, living plants, animals and micro-organisms, products of human origin, and plant or animal products relating directly to future reproduction. Certain vehicles are excluded only for product aspects covered by sector-specific EU legislation.

The vehicle exclusion is not a blanket exclusion for every vehicle-related product or aspect. The regulation also states in its recitals that e-bikes and e-scooters should not be excluded from ESPR scope.

A product's history can also change the analysis. The ESPR recitals say second-hand products originating within the EU, including products repaired or refurbished, do not have to comply with delegated acts that entered into force after their original placing on the market. Remanufactured products are treated as new products and are subject to ecodesign requirements when they fall within an applicable delegated act.

ESPR is framework legislation. It establishes the system for setting ecodesign requirements, but the binding details for a product group come through delegated acts. Those acts specify the product group, requirements, methods, conformity assessment, technical documentation elements, transitional period, and review date.

For a product-scope answer, this means the strongest cited conclusion is often: the product may fall within ESPR's framework scope, but the operative obligations depend on the delegated act that covers the product group.

Monitor the ESPR working plan and delegated-act pipeline, not only the regulation text. Article 18 requires a publicly available working plan that prioritises product groups and horizontal requirements, and the Commission overview says the first ESPR and Energy Labelling Working Plan was adopted in April 2025.

The regulation itself identifies product groups to be prioritised in the first working plan: iron and steel; aluminium; textiles, especially garments and footwear; furniture, including mattresses; tyres; detergents; paints; lubricants; chemicals; certain energy-related products; and information and communication technology products and other electronics.

The DPP link follows the same delegated-act logic. Article 9 says products can only be placed on the market or put into service with a DPP where the applicable delegated act requires it, and the delegated act specifies the data, carrier, access, level, update responsibilities, and availability period.

The Commission overview describes the DPP as a digital identity card for products, components, and materials that stores relevant sustainability information and supports circularity and compliance. That is useful context, but it is not permission to invent a product's final passport data fields before the relevant act specifies them.

Keep the evidence narrow. A useful ESPR product-scope record should show the product description, EU market route, whether it is a component or intermediate product, any Article 1 exclusion analysis, the relevant Article 18 product group or working-plan item, and the delegated-act status.

The evidence should also state what is not yet supported by cited sources. If no delegated act has been identified for the product group, the record should not claim specific ESPR thresholds, passport fields, penalties, application dates, or conformity procedures.