If you sell physical products into the European Union, one piece of legislation is about to reshape what you have to know — and prove — about everything you make. It's called the Ecodesign for Sustainable Products Regulation, or ESPR, and it is the engine behind the Digital Product Passport.

It is not a distant proposal. ESPR entered into force in July 2024, and the first product-specific rules are already being drafted. Here is what it is and why it matters now.

What ESPR actually is

ESPR is a framework regulation. Rather than setting every rule itself, it gives the European Commission the power to introduce requirements category by category, through what are called delegated acts. Each delegated act sets the ecodesign and information requirements for a specific group of products — textiles, furniture, electronics, and so on.

The goal is to make products sold in the EU more durable, repairable, recyclable and resource-efficient, and to make that information transparent to everyone in the chain — from the buyer to the recycler to the regulator.

The Digital Product Passport

The most visible part of ESPR for most companies is the Digital Product Passport (DPP): a structured, machine-readable record of a product's key sustainability and supply-chain data, reachable from a QR code or similar data carrier on the product itself.

In practice, if a product group is covered and your product doesn't have a compliant passport, it cannot legally be placed on the EU market.

The passport has to be available at the point of sale and kept current. That sounds simple until you consider how much of the required data — emissions, water use, recycled content — most companies have never measured.

Who it applies to

ESPR is deliberately broad. It is designed to eventually cover nearly all physical products sold in the EU, with a small number of exceptions such as food and medicines. It applies whether you manufacture in the EU or import into it, which means companies well outside Europe are caught by it too.

Crucially, there is no carve-out for small businesses on the core obligation. A textile SME with fifty products faces the same passport requirement as a multinational — but with far fewer resources to meet it.

The deadlines that matter

Requirements arrive group by group. Indicative timing from the Commission's 2025–2030 working plan and related laws looks like this:

  • 2026 — iron and steel; construction products (under their own regulation)
  • 2027 — textiles and apparel, tyres, aluminium; batteries (under the EU Battery Regulation)
  • 2028 — furniture; electronics on a parallel track
  • 2029 and beyond — mattresses, then a widening list including toys, detergents and more

Dates will move as delegated acts are finalised, but the direction is fixed and the lead times are short.

What it means in practice

For most companies the hard part is not the QR code — it's the data behind it. Compliance means assembling verified information about materials, origin, environmental impact and certifications for every product, and keeping it up to date as your catalogue changes.

That's the problem we built Luxima to remove. Instead of asking you to gather and maintain all of this by hand, it connects to the systems and spreadsheets you already use, fills the gaps you can't measure, and generates compliant passports automatically. The regulation is coming either way — the question is how much work it costs you.