--- title: "Which products are in scope of the EU ESPR?" canonical_url: "https://www.sorena.io/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/products-in-scope" source_url: "https://www.sorena.io/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/products-in-scope" author: "Sorena AI" description: "Standalone FAQ on ESPR product scope, excluded products, delegated-act dependency, working-plan monitoring, and the digital product passport link." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "ESPR product scope" - "EU Ecodesign for Sustainable Products Regulation" - "delegated acts" - "digital product passport" - "product groups" - "ESPR" - "product scope" - "ecodesign requirements" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # Which products are in scope of the EU ESPR? Standalone FAQ on ESPR product scope, excluded products, delegated-act dependency, working-plan monitoring, and the digital product passport link. *FAQ* *ESPR* *EU* ## EU Ecodesign for Sustainable Products Regulation Which products are in scope of the ESPR ESPR is a framework for physical goods placed on the EU market or put into service, including components and intermediate products. The practical answer depends on the regulation's exclusions and on whether a delegated act or working-plan priority covers the product group. ESPR product scope is broad, but it is not the same as an immediate product-by-product obligation. The regulation covers physical goods placed on the EU market or put into service unless an exclusion applies, and concrete ecodesign and digital product passport requirements are set through delegated acts for product groups. ## Scope basics for physical goods The starting point is broad: ESPR applies to physical goods placed on the EU market or put into service, including components and intermediate products. That means a scope review should begin with the product itself, 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. - Start with the Article 1 scope test: physical goods, EU market placement or putting into service, components, and intermediate products. - Check Article 1 exclusions before assigning an ESPR workstream. - Then check whether the product group is already covered by an applicable delegated act or is being prioritised in the working plan. Sources for this answer: - [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Article 1 sets the broad scope for physical goods, including components and intermediate products, and Article 4 makes product-group requirements dependent on delegated acts. - [European Commission - Ecodesign for Sustainable Products Regulation](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview explains that ESPR extends ecodesign beyond energy-related products to virtually all physical products, with concrete rules developed later. ## Which products are excluded or need caveats? 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 caveat matters: the exclusion is not a blanket statement that every vehicle-related product or aspect is outside ESPR. The regulation also states in its recitals that e-bikes and e-scooters should not be excluded from ESPR scope. - Record the exact exclusion relied on, not a generic statement that the product is outside ESPR. - For vehicles, identify the product aspect and the sector-specific EU act before treating the aspect as excluded. - If the fact pattern is medical, food, chemical, vehicle-related, or mixed-use, avoid turning the ESPR FAQ into a sector-law conclusion without source support. Sources for this answer: - [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Article 1 lists the excluded product categories and limits the vehicle exclusion to aspects already covered by sector-specific EU legislation. - [Regulation (EU) 2024/1781 (ESPR)](https://data.europa.eu/eli/reg/2024/1781/oj?ref=sorena.io) - Official ELI text cross-check for the Article 1 exclusions and the recital caveat that e-bikes and e-scooters should not be excluded. ## Why does delegated-act status matter? 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 grounded 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. - Do not invent product-specific performance thresholds, DPP fields, labels, conformity modules, penalties, or dates from the broad scope rule. - Tie obligations to the applicable delegated act once one exists for the product group. - Where no delegated act is identified in the grounding, describe the product as a monitoring item rather than a settled detailed-obligation item. Sources for this answer: - [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Articles 4 and 8 explain that ecodesign requirements and required act contents are set by delegated acts for product groups. - [European Commission - Ecodesign for Sustainable Products Regulation](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission implementation text describes ESPR as framework legislation followed by concrete product-by-product or horizontal rules. ## How should teams monitor product groups? 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. - Maintain a product-group watchlist mapped to Article 18 priorities and any published working-plan updates. - Track whether a rule is product-specific or horizontal because horizontal requirements can cover multiple product groups. - Update the scope answer when a delegated act defines the covered product group and its commodity codes or product descriptions. Sources for this answer: - [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Article 18 provides the prioritisation criteria, working-plan mechanism, first working-plan product groups, and annual progress reporting. - [European Commission - Ecodesign for Sustainable Products Regulation](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview identifies implementation through the first ESPR and Energy Labelling Working Plan and later product rules. ## How does product scope link to the Digital Product Passport? 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. - Use ESPR scope to decide whether DPP monitoring is relevant for a product group. - Use the applicable delegated act to identify actual DPP data fields, access rights, and product/model/batch/item level. - Keep DPP evidence separate from general product-scope evidence until a product-group act connects them. Sources for this answer: - [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Articles 7, 9, 10, and 11 ground the DPP link, including delegated-act dependency and essential technical requirements. - [European Commission - Ecodesign for Sustainable Products Regulation](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview explains the DPP as a digital identity card for products, components, and materials with sustainability information. ## What evidence should support a products-in-scope answer? 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 grounded. If no delegated act has been identified for the product group, the file should not claim specific ESPR thresholds, passport fields, penalties, application dates, or conformity procedures. - Article 1 scope and exclusion citation. - Product-group mapping and working-plan monitoring note. - Delegated-act citation or a clear note that no product-group act was identified in the reviewed grounding. - DPP citation limited to Article 9 and the applicable product-group act where available. - Source URL list using external HTTPS URLs with ref=sorena.io. Sources for this answer: - [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Primary legal source for scope, exclusions, delegated acts, working-plan priorities, and DPP dependency. - [European Commission - Ecodesign for Sustainable Products Regulation](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission context source for reader-facing explanation of ESPR objectives, implementation, DPP, and working-plan process. ## Primary sources - [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Primary ESPR legal text used for Article 1 scope and exclusions, Article 4 delegated acts, Article 8 act contents, Article 9 DPP dependency, and Article 18 working-plan priorities. - Quote: "any physical goods that are placed on the market or put into service" - [Regulation (EU) 2024/1781 (ESPR) - ELI](https://data.europa.eu/eli/reg/2024/1781/oj?ref=sorena.io) - Official ELI version used as a stable cross-check for ESPR scope, exclusions, and delegated-act dependency. - Quote: "delegated acts adopted pursuant to Article 4" - [European Commission - Ecodesign for Sustainable Products Regulation](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview used for public-facing explanation of broad product scope, DPP purpose, implementation through product-specific or horizontal rules, and the working-plan process. - Quote: "cover virtually all physical products" ## Topic Guides - [ESPR and DPP connection: delegated acts, identifiers, and access](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-and-dpp-connection.md): How ESPR connects ecodesign information requirements to Digital Product Passports, including delegated acts, data carriers, identifiers, access rights, registry, and architecture choices. - [ESPR Applicability Test for Products and DPP Readiness](/artifacts/eu/ecodesign-for-sustainable-products-regulation/applicability-test.md): A source-linked ESPR applicability test for physical product scope, exclusions, delegated-act dependency, economic operator triage, DPP readiness, unsold goods, and evidence. - [ESPR compliance checklist for delegated acts and DPP readiness](/artifacts/eu/ecodesign-for-sustainable-products-regulation/checklist.md): A source-linked ESPR checklist for monitoring delegated acts, mapping product requirements, preparing technical documentation, and building DPP and unsold-goods evidence. - [ESPR compliance program operating model](/artifacts/eu/ecodesign-for-sustainable-products-regulation/compliance-program-operating-model.md): Build an ESPR operating model for product-group intake, delegated-act monitoring, supplier evidence, DPP governance, release gates, and authority response. - [ESPR compliance: delegated acts, DPP and evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/compliance.md): Practical ESPR compliance guidance for mapping product delegated acts, Digital Product Passport dependencies, unsold goods duties, technical documentation, standards, and market-surveillance evidence. - [ESPR deadlines and compliance calendar](/artifacts/eu/ecodesign-for-sustainable-products-regulation/deadlines-and-compliance-calendar.md): Source-linked ESPR calendar for framework dates, delegated-act dependency, working-plan monitoring, unsold-goods disclosure, and DPP readiness limits. - [ESPR delegated act intake by product group](/artifacts/eu/ecodesign-for-sustainable-products-regulation/delegated-act-intake-by-product-group.md): A grounded intake checklist for tracking ESPR delegated acts by product group, covering product identification, DPP data, ecodesign requirements, conformity evidence, and source limits. - [ESPR delegated act intake workflow](/artifacts/eu/ecodesign-for-sustainable-products-regulation/delegated-act-intake-workflow.md): A source-grounded intake workflow for ESPR delegated acts: trigger checks, product-group scope, requirement extraction, DPP impacts, release gates, owners, and evidence outputs. - [ESPR delegated acts FAQ: product rules, DPP impact, and monitoring](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/delegated-acts.md): Standalone FAQ on ESPR delegated acts, why product-group duties depend on them, what teams should monitor, and how they shape Digital Product Passport information. - [ESPR delegated acts watchlist for product and DPP teams](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-delegated-acts-watchlist.md): Track ESPR delegated-act priorities without inventing dates: product groups, source status, likely requirement types, DPP impact, evidence owners, and open source gaps. - [ESPR destruction ban and unsold goods FAQ](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/destruction-ban.md): What ESPR says about preventing destruction of unsold consumer products, annual disclosure, the Annex VII apparel and footwear ban, and grounded derogation evidence. - [ESPR destruction of unsold goods: disclosure, ban scope, and records](/artifacts/eu/ecodesign-for-sustainable-products-regulation/destruction-of-unsold-goods.md): Source-linked ESPR guide to unsold consumer product disclosure, destruction-ban scope, records, derogations, and national enforcement limits. - [ESPR DPP information mapping workflow](/artifacts/eu/ecodesign-for-sustainable-products-regulation/dpp-information-mapping-workflow.md): Map ESPR delegated-act information requirements into DPP data elements, source systems, access levels, identifiers, carriers, validation evidence, and unresolved design decisions. - [ESPR durability, repairability, and recyclability evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/durability-repairability-and-recyclability-evidence.md): Build ESPR evidence for durability, repairability, and recyclability without inventing product-group tests before the applicable delegated act is known. - [ESPR Ecodesign Evidence Checklist](/artifacts/eu/ecodesign-for-sustainable-products-regulation/ecodesign-evidence-checklist.md): Checklist for collecting ESPR ecodesign evidence from delegated acts, technical documentation, supplier substantiation, DPP mapping, standards, and market surveillance records. - [ESPR ecodesign requirement types: performance, information, and DPP links](/artifacts/eu/ecodesign-for-sustainable-products-regulation/ecodesign-requirement-types.md): Source-grounded guide to ESPR ecodesign requirement types, product parameters, delegated-act dependency, DPP links, and evidence implications. - [ESPR FAQ: scope, delegated acts, DPP, unsold goods](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq.md): Standalone ESPR FAQ answers on product scope, delegated acts, Digital Product Passports, unsold goods, product priorities, standards, surveillance, and source limits. - [ESPR harmonised standards and common specifications](/artifacts/eu/ecodesign-for-sustainable-products-regulation/standards-and-common-specifications.md): How ESPR uses harmonised standards, common specifications, delegated acts, and DPP standards evidence without inventing product-specific requirements. - [ESPR Information Requirements to DPP Mapping](/artifacts/eu/ecodesign-for-sustainable-products-regulation/information-requirements-to-dpp-mapping.md): Map ESPR information requirements into Digital Product Passport data classes, source systems, access rules, carrier choices, validation checks, and evidence records. - [ESPR Information Requirements, Labels, and Disclosure](/artifacts/eu/ecodesign-for-sustainable-products-regulation/information-requirements-labeling-and-disclosure.md): Grounded ESPR guide to delegated-act information requirements, product labels, digital product passport access, data carriers, and unsold-goods disclosure. - [ESPR market surveillance FAQ: evidence, DPP data, and authority requests](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/market-surveillance.md): Standalone FAQ on ESPR market surveillance: technical documentation, conformity evidence, DPP data, authority response, delegated-act limits, and national penalties. - [ESPR market surveillance technical documentation checklist](/artifacts/eu/ecodesign-for-sustainable-products-regulation/market-surveillance-technical-documentation.md): Source-grounded ESPR checklist for technical documentation, conformity evidence, DPP records, and responses to market surveillance authority requests. - [ESPR penalties and fines: Member State rules and evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/penalties-and-fines.md): A conservative ESPR penalties guide explaining Article 74, why fine amounts depend on Member State law, and which conformity and market-surveillance evidence matters. - [ESPR Product Priorities and Delegated Acts Tracker](/artifacts/eu/ecodesign-for-sustainable-products-regulation/product-priorities-and-delegated-acts-tracker.md): Track ESPR priority product groups, source status, delegated-act progress, expected DPP impact, owners, evidence, and source gaps without treating preliminary studies as binding obligations. - [ESPR product priorities FAQ: working plan and delegated acts](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/product-priorities.md): Standalone FAQ on ESPR product priorities, the Commission working plan, delegated-act dependency, monitoring points, and limits of preliminary source material. - [ESPR requirements: delegated acts, ecodesign, DPP, and evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/requirements.md): ESPR requirements explained as a framework for delegated acts, ecodesign performance and information rules, Digital Product Passports, unsold goods, technical documentation, and market surveillance. - [ESPR unsold goods disclosure FAQ](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/unsold-goods-disclosure.md): Standalone FAQ on the ESPR Article 24 duty to disclose discarded unsold consumer products, its relationship to the destruction ban, records, and source limits. - [ESPR unsold goods disclosure tracker](/artifacts/eu/ecodesign-for-sustainable-products-regulation/unsold-goods-disclosure-tracker.md): Track ESPR unsold consumer product disclosure fields, website publication evidence, destruction-ban status, owners, and unresolved source gaps. - [ESPR vs Batteries Regulation Comparison](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-batteries-regulation.md): Compare ESPR delegated-act planning with the Batteries Regulation product-specific regime, including DPP overlap, battery passport evidence, timing limits, and source boundaries. - [ESPR vs Ecodesign Directive](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-ecodesign-directive.md): Compare ESPR with the earlier Ecodesign Directive across scope, legal form, delegated acts, DPP requirements, unsold goods, transition rules, and evidence. - [ESPR vs GPSR: Sustainability vs Product Safety](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-gpsr.md): A source-limited comparison of ESPR sustainability and product-information requirements against GPSR product-safety context, with evidence and DPP reuse limits. - [ESPR vs PPWR Comparison](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-ppwr.md): Compare ESPR product ecodesign and Digital Product Passport work with the separate PPWR packaging regime, using only source-linked ESPR and packaging-boundary claims. - [ESPR vs REACH and RoHS Comparison](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-reach-and-rohs.md): Compare ESPR ecodesign, sustainability, information, and digital product passport requirements with source-limited REACH and RoHS substance-control context. - [EU ESPR DPP obligations FAQ](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/dpp-obligations.md): Standalone FAQ on Digital Product Passport obligations under ESPR, covering delegated acts, identifiers, carriers, access rights, data governance, and supplier evidence limits. - [Timeline for ESPR: practical implementation guide](/artifacts/eu/ecodesign-for-sustainable-products-regulation/timeline.md): Practical ESPR guidance for Timeline, with source-linked decisions, owners, evidence records, and implementation steps. - [What ESPR is and why it matters](/artifacts/eu/ecodesign-for-sustainable-products-regulation/what-is-espr-and-why-it-matters.md): A grounded explainer of the EU Ecodesign for Sustainable Products Regulation, including scope, delegated acts, DPPs, unsold goods, and enforcement limits. *Recommended next step* *Placement: after evidence section* ## Map ESPR scope to product-group monitoring Use this ESPR FAQ to separate broad framework scope from delegated-act requirements, DPP readiness, and working-plan monitoring. - [Open Research Copilot](/solutions/research-copilot.md): Answer ESPR scope and DPP questions with cited source material. - [Discuss ESPR implementation](/contact.md): Review product scope, delegated-act monitoring, and source evidence with Sorena. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). All rights reserved. Source: https://www.sorena.io/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/products-in-scope