Imagine buying a jacket. On the jacket there is a QR code. Scanning it, you can see where the fibre comes from, whether the product is repairable, whether it contains hazardous substances, how much carbon its production generated, and how to dispose of it at end of life. This is not science fiction: it is the objective of the Digital Product Passport, one of the central instruments of Regulation (EU) 2024/1781, known as the ESPR (Ecodesign for Sustainable Products Regulation).
The ESPR has been in force since 18 July 2024 and applies to almost all physical goods placed on the European market, from appliances to textiles, from furniture to paints. Its stated objective is to make products more durable, more repairable, more recyclable and more transparent about their environmental impact. The logic is not new, but the scale is unprecedented: this time it does not concern only energy-related products, as the previous Ecodesign Directive did, but practically everything produced and sold in Europe.
For those who design, manufacture or sell physical goods, this means that environmental compliance will no longer be a communication option but a condition of market access. And preparing takes time, because the real work is not normative: it is on data.
What changes compared to the previous framework
The 2009 Ecodesign Directive focused on energy efficiency: it mainly covered electrical and electronic equipment, introducing requirements on energy performance. It worked, but within a narrow scope and an almost exclusively energy-focused perspective.
The ESPR expands the scope on two dimensions. The first is the products covered: almost all physical goods, with few exceptions (food, medicines, plants, animals, vehicles already covered by dedicated regulations). The second is the aspects assessed: not just energy efficiency, but the entire life cycle. Durability, repairability, reusability, recycled material content, presence of substances of concern, disassembly options, availability of spare parts, end-of-life recyclability, carbon footprint.
There is one structural characteristic of the ESPR worth understanding clearly: the Regulation does not set operationally applicable requirements immediately. It defines a common framework and the instruments. Specific requirements for each product category will arrive progressively through delegated acts of the European Commission. This means that those producing steel will see requirements in 2026, textile and clothing manufacturers in 2027, furniture makers in 2028. There is no single deadline for everyone: it is a calendar worth monitoring closely.
Source: ESPR Work Plan 2025-2030, European Commission
The Digital Product Passport: not just transparency, but data architecture
The Digital Product Passport is the most concrete and most operationally demanding element of the ESPR. Every product subject to the regulation will need to be accompanied by an accessible data carrier, typically a QR code or equivalent technology, allowing anyone in the supply chain to retrieve certified information about the product.
The specific information to be included in the DPP will vary by product category and will be defined through delegated acts. As a general framework, the passport may carry data on: technical product performance, materials used and their geographic origin, presence of substances of concern, repairability and spare parts availability, recycled content percentage, recyclability options and end-of-life pathways, carbon footprint across the life cycle.
The Digital Product Passport is not a document to attach. It is a product data management system that must function in real time throughout the commercial life of the good.
This is the point that many companies underestimate. The DPP does not require writing a document: it requires having data that is reliable, updatable and shareable. And this data does not reside in a single department. It is distributed across the technical office that knows the materials, procurement that knows the suppliers, production that knows the consumption figures, quality that holds the certifications. Aggregating these coherently and in a structured way requires an internal organisational effort that cannot be improvised in a few weeks.
There is a further complexity: some data does not sit inside the company at all. Many supply chain details, such as the origin of raw materials, supplier process certifications, or the recycled content of a component, reside with suppliers or sub-suppliers who may never have formalised them. Engaging the supply chain becomes part of DPP preparation, not a separate activity.
Want to understand which of your products may be in scope and where it makes sense to start the data mapping?
The ban on unsold goods destruction: a change already under way
Among the ESPR measures already in force or expected shortly, one of the most concrete concerns the fashion sector. From 19 July 2026, large companies will no longer be allowed to destroy unsold products such as clothing, clothing accessories and footwear. For medium-sized companies, the same ban is expected to apply from 2030.
4-9%
of unsold textile products in Europe is destroyed before being worn
5.6m tonnes
of CO₂ emitted annually from the destruction of unsold textiles in Europe
Source: European Commission, ESPR measures on the destruction of unsold textile products, February 2026
Alongside the ban, large companies are already subject to the obligation to disclose the volumes of unsold products discarded as waste, indicating quantities, weight, reasons for disposal, destination of the products and measures adopted to prevent their destruction. For medium-sized companies, the obligation will apply from 2030.
Two obligations that hold together: the ban on destruction pushes companies to develop alternative channels (secondary market resale, donation, repair, reuse, material recycling), while the disclosure obligation ensures the numbers are verifiable.
For SMEs in the textile sector, even those currently outside the size thresholds, the signal is clear: unsold inventory management is becoming a compliance variable, not just an operational efficiency issue. Companies without a system to track stock, returns and the destination of unsold products will need to build that capacity before it becomes mandatory.
Ecodesign as a design criterion, not a label
The heart of the ESPR is not the DPP and not the unsold goods measures. It is the shift in perspective on the act of designing a product.
Today, in most companies, sustainability enters the design process as a final check: the product is designed, then assessed against certain environmental standards. The ESPR pushes in the opposite direction: criteria such as durability, ease of disassembly, compatibility with repair and recycling systems should inform upstream design choices, not be verified downstream.
This has concrete implications. A product designed with glued joints cannot be disassembled for repair. A non-standardised component makes partial replacement impossible. A composite material that is difficult to recycle closes off end-of-life options. These are not philosophical considerations: they are criteria that future ESPR delegated acts will translate into measurable metrics and verifiable requirements.
For companies redesigning a product line or launching a new item, integrating these criteria now, before the obligation exists, is far less costly than adapting when the requirement is already in force and the window for design revision has closed.
The real issue is data, and understanding why matters
There is a consequence of the ESPR that emerges clearly as companies start preparing: the Regulation does not require complex technological investments. It requires, first of all, that product data exists, is reliable, and is organised.
In practice, the information needed for the DPP is distributed across very different locations: the technical office holds material specifications, procurement holds supplier contracts, production tracks consumption, quality manages certifications. None of these sources is designed to produce comparable or automatically aggregable data. Before any digital system, there is a mapping and normalisation task that takes time and requires clarity on responsibilities.
60-80%
of the information needed for the DPP is already present in the company, but distributed across separate silos
Source: sector analysis estimate (McKinsey, Accenture, 2025)
The gap is not one of knowledge, but of organisation
A common mistake is to look for the technological solution first. DPP platforms, life cycle management software, traceability systems: all useful tools, but ones that deliver value only if the data feeding them is clean, verified and up to date. Selecting software before resolving the quality of core data leads to expensive, unreliable systems.
The first step is not technological. It is understanding which products are potentially in scope, what data is already available, where the gaps are, and what information needs to be requested from suppliers. Everything else is built on that map.
At Kyklos Carbon we work with companies on exactly this preparatory phase: product mapping against the ESPR work plan, data inventory, gap identification and support in engaging the supply chain to collect information that is not available internally. We do not sell software solutions: we help build the data foundation that any DPP system will need to draw on.
If you are starting to work on ESPR and want to think through where it makes sense to begin for your company, we are happy to talk.
A medium-term perspective
The ESPR is not a regulation to address through a one-off project. It is a framework that will progressively change the conditions for accessing the European market, sector by sector, requirement by requirement. Those who follow the delegated acts calendar and build their data structure in advance arrive at each individual deadline with the work already done. Those who wait for the specific obligation for their sector find themselves moving quickly on something that would have required months.
There is also a dimension that goes beyond compliance. The information the DPP requires collecting, from materials to consumption to supply chain processes, is the same information that allows companies to identify where a product is inefficient, where end-of-life costs are too high, where a supplier represents a risk. Whoever builds this data foundation to comply with the ESPR ends up with a product analysis tool they did not have before.
A well-built DPP is not just a regulatory requirement. It is the technical documentation of a product that every department wishes it had and that almost no one has ever assembled in a single unified format.
Sources
Regolamento (UE) 2024/1781 — Ecodesign for Sustainable Products Regulation (ESPR)
Regulation (EU) 2024/1781 — Ecodesign for Sustainable Products Regulation (ESPR)
ESPR Work Plan 2025-2030 — Italian Ministry of Environment and Energy Security (MASE)
European Commission — Ecodesign for Sustainable Products Regulation (official page)
European Commission — New EU rules to stop destruction of unsold clothes and shoes, February 2026
A product sold in Europe will soon need a digital identity card. Here is what changes, and why preparing now makes sense.