Circular by design: what the Ecodesign rules ask of products

For most companies, circularity has lived in the sustainability report: a waste figure, a recycling rate, perhaps a take-back pilot. The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, moves it somewhere much harder to ignore: the conditions for selling a product in the EU.

A framework, filled in product by product

The ESPR itself sets the menu. The detailed rules arrive through product-specific delegated acts. The Commission's first working plan, published in 2025, prioritises steel, aluminium, textiles, furniture, tyres and mattresses, among others. For each group, the rules can cover:

• Durability and reliability: how long a product must last.
• Repairability and upgradability: availability of spare parts and repair information.
• Recycled content and recyclability.
• Substances of concern that make recycling harder.
• Carbon and environmental footprint.
• Information requirements, delivered through a Digital Product Passport.

The destruction ban

One rule applies directly. Since 19 July 2026, large companies may not destroy unsold apparel, clothing accessories and footwear, with limited exceptions. Medium-sized companies follow in 2030. Companies that discard unsold consumer products must also disclose how much, and why.

The Digital Product Passport

Each regulated product will carry a passport, usually via a QR code, with information on materials, origin, repair and end of life. For manufacturers, this means product-level data that most do not collect today. For buyers and recyclers, it means information they have never had.

What it means for strategy

• Design teams need sustainability input early. Most of a product's environmental impact is fixed at the design stage.
• Supplier data becomes product data. Material composition and recycled content have to be evidenced, not estimated.
• Business models may shift. Repair, resale and product-as-a-service become easier to justify when durability is required anyway.

Circularity used to be a choice some brands made to stand out. Under the ESPR, for more and more products, it becomes the baseline.

Educational content, not legal advice.