What is the Ecodesign Directive?
The European Ecodesign Directive (Directive 2009/125/EC) sets ecological standards for the design of certain product groups in the member states of the European Union. It is mentioned and worked on together with its “sister directive”, the Energy Labeling Regulation. It poses design requirements for the most energy and greenhouse-gas-intensive products, while its sister directive rules the energy labeling of such products – you might know them from your fridge and washing machine.
In 2021, these regulations lowered energy consumption of the regulated products by 10% and saved consumers 120 Billion euros of energy expenditure (!!) – the latter is estimated to have doubled in 2022.
The Ecodesign Directive is based on the sustainable design approach: Ecodesign. Ecodesign minimizes the life-cycle environmental impacts of a product through design solutions. Decisions are driven by environmental data, ideally measured with LCA.
What is the Ecodesign for Sustainable Products Regulation (ESPR)?
The “Ecodesign for Sustainable Products Regulation” (ESPR) was proposed in March 2022 and will replace the current EU Ecodesign Directive. It will introduce more extensive Ecodesign requirements, for many more product groups. This will result in consequences for a wider range of companies. And, by 2030, potentially lead to energy savings equivalent in size to the EU’s imports of Russian gas.
In this article, you learn:
- How the ESPR relates to the EU Green Deal policy framework (+ a nice infographic)
- The process and outcomes of ESPR implementation so far;
- Which confusing concepts have nothing to do with Ecodesign Directive/ESPRS;
- How companies can prepare for the ESPR.
How the ESPR relates to the EU Green Deal
The Ecodesign directive and ESPR sit in a jungle of regulations and plans – all part of the European Green Deal.
Let’s go through all the layers. This first section of terms deals with the outer layers – covering the green part in Image 1.
1. EU’s Green Deal – The big idea
The EU Green Deal is a policy package to make the EU carbon neutral by 2050. Immense funds of about 1 trillion euros are available for it. Its promises range from decoupling economic growth from resource use, over nature restoration, to improved public health and well-being.
2. The circular economy – A plan for action
One policy in the EU Green Deal is the Circular Economy Action Plan. The circular economy action plan in turn has different policies, e.g. on empowering consumers in sustainable choices, reducing waste, and: the “sustainable products initiative”.
3. Sustainable Products Initiative – Getting down to business
The Sustainable Products Initiative’s goal is to “make sustainable products the norm”. The ESPR is the main policy instrument here. The ESPR will be a regulation, thus: binding for EU member states. We’ll get to know it deeply in the next section.
The Sustainable Products Initiative is implemented further through the “EU Strategy for Sustainable and Circular Textiles” and the revision of the Construction Products Regulation (Image 1). They cover more product-specific rules, while the ESPR covers environmental aspects.
Image 1. Green Deal policy framework around ESPR (green) and the ESPR’s relationship to the Ecodesign directive (blue).
The Ecodesign for Sustainable Products Regulation (ESPR)
Now let’s zoom in on the ESPR: It is placed in the inner layers of the European Green Deal. The blue parts in Image 1.
4. ESPR will replace Ecodesign Directive
At the current time of writing (12/2022) the Ecodesign Directive regulates 29 product categories (see below), posing mainly energy-related criteria. However, the new ESPR wants to cover the “broadest possible range of products” with more diverse Ecodesign criteria. These criteria are aligned to the “Right to Repair”, and boost circularity, durability, reusability, upgradability, and repairability.
Next to Ecodesign criteria, the ESPR will introduce a digital product passport for all regulated products. This will be an easily accessible tag on the products that makes sustainability information instantly available to supply chain actors, regulators, and consumers alike.
To address the practice of destroying unsold consumer products, the ESPR will mandate companies to adopt measures to prevent this practice and disclose unsold product disposal data. A direct ban on unsold textile and footwear destruction applies to large companies, while smaller businesses have exemptions and medium-sized companies have a transitional period. Some other ESPRS sub-goals are visible in the blue core in Image 2 below.
The 29 product groups with Ecodesign criteria in 2024 are:
- Solid fuel local space heaters
- Space and water heaters
- Solid fuel boilers
- Air heating and cooling products
- Fridges and freezers
- Professional refrigerators
- Refrigerators with a direct sales function
- Vacuum cleaners
- Washing machines
- Tumble driers
- Air conditioners and comfort fans
- Industrial fans
- Ventilation units
- Air heating and cooling products
- Set-top boxes
- Cooking appliances
- Water pumps
- Power transformers
- External power supplies
- Computers and small servers
- Servers and data storage products
- Mobile phones, cordless phones, and tablets
- Electric motors
- Off mode, standby, and networked standby
- Welding equipment
5. Implementing acts to the ESPR
Each regulated product group in the Ecodesign Directive has it’s own “implementing act”. This is a piece of law, that makes the Ecodesign criteria mandatory. Currently, the EU is developing the implementation of acts for new product groups and revising old ones. The new acts still enter into force under the current Ecodesign directive. Once the ESPR enters into force, it will take over these acts and replace the current Ecodesign directive.
For example, the newest implementing act on mobile phones and tablets, adopted in June 2023 and applied from June 2025, requires durable design, longer-lasting batteries, and (prolonged) availability of software updates and spare parts. Compared to previous energy-focused acts, this act demonstrates how the EU is implementing the Right-to-Repair in the ESPR.
6. Energy Labels
The Ecodesign Directive and the Energy Labelling Regulation are “sister directives”. They are often mentioned and worked on together.
Product groups with energy labeling requirements also have an Ecodesign ruling (except tires). But not every product group with Ecodesign ruling needs/ is suitable for energy labeling.
This is how the EU puts it:
- “The Ecodesign Directive (2009/125/EC) – the tool for making products more energy efficient.
- The Energy Labelling Regulation (EU) 2017/1369) – the tool through which the consumer can recognize the best-performing products”
As of December 2023, energy labeling applied to 14 of the earlier-mentioned product groups, and to tires (which do not have Ecodesign criteria).
Image 2: The ESPR and its goals in the circular economy package. Source: European Commission
Current plans for the ESPR
On December 4, 2023, the EU parliament and council reached a “provisional agreement”, pushing the ESPR proposal from March 2022 one step further in the legislative process. Once the regulation is formally adopted, its general measures such as the ban on the destruction of unsold products will take effect, and new implementing acts will be implemented directly under the ESPR.
Also, the newest Ecodesign and Energy Labeling Work Plan will be adopted. The provisional agreement from December 4, 2023, established iron, steel, aluminum, textiles (notably garments and footwear), furniture, tires, detergents, paints, lubricants, and chemicals as priority products for the 2024-2027 working plan.
The highlights of the working plan 2022-24 were:
- Implementing act on computers and computer servers, planned for the end of 2025.
- 31 product categories to be assessed next -first those* with the highest energy or material efficiency potentials. Regulations might arrive by 2030.
- More focus on non-energy related Ecodesign criteria such as durability, reparability, recyclability, ease of end-of-life disassembly and reuse, recycled content, etc.
- Progress made on requirements for Solar PV-related products.
- A repair score was developed, and adding this to energy labels of “relevant products” (e.g. consumer electronics) is considered.
- Priority: rescaling Energy Labels and adding onto them the European Product Registry for Energy Labelling (EPREL) as a QR code.
*Priority products in working plan 2022-2024, section 4.4: low-temperature emitters, professional laundry machines, and dishwashers, universal external power supplies, and electric vehicle chargers.
How to prepare for the ESPR
The ESPR will pose Ecodesign criteria for as many products as possible. However, in the next few years, it will be implemented for only a limited range of energy-intense products. Our tip: find out if your products are among them!
Conduct LCAs of your products
The environmental impact of the whole life product cycle is a prominent theme in the EU’s environmental regulations. The talk is of a “whole life cycle approach to product regulation” in the ESPR proposal. LCA is currently only prescribed in the EU’s Product Environmental Footprint (PEF) method – which falls outside of the ESPR. The Commission mentions that most stakeholders support the implementation of LCA for impact assessment within the ESPR, although its own LCA methodology, the PEF, is currently not fit for the purpose.
As we know, Ecodesign is all about reducing LCA impacts. Therefore, it’s incredibly likely that the environmental data required by the ESPR will be LCA data. Prepare and already take steps towards Ecodesign (rules) with your product. Measure the environmental footprint of your product with LCA.
Ecochain Mobius is an easy LCA tool, specifically created for Ecodesign. Have a look at Mobius here.
EU communication on making sustainable products the norm
Ecodesign and Energy Labelling Working Plan 2022-2024
Q&A: ESPR under the Sustainable products initiative
EU Green Deal’s policy framework – on Circular Economy and Ecodesign
Rescaling of energy labels
Ecodesign and energy labeling rules for product groups- overview
Ecodesign and energy labeling harmonized standards (only some product groups)
Ecodesign – Overview for 2023 – Ecochain