ESPR Overview

The Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781) is the framework regulation that sets up the Digital Product Passport requirement across the European Union. It entered into force in 2024. No delegated act under Article 4 has yet been adopted for any product group, so ESPR itself obliges nobody to issue a passport today: the framework is in force, but the obligations that depend on it are not. The passport obligations that do have dates come from other acts: the Battery Regulation from 18 February 2027, the Detergents Regulation from 23 September 2029 and the Toy Safety Regulation from 1 August 2030. The Construction Products Regulation requires a passport too, but Art. 22(7) dates it 18 months after the Commission’s delegated act setting up the construction passport system (Art. 75(1)), and that act has not been adopted.

What ESPR requires

The regulation sets three main obligations.

The passport itself. Every regulated product must have a machine-readable Digital Product Passport, reachable through a data carrier (usually a QR code) on the product.
Access. Art. 11(b) requires that a long list of actors, from customers to recyclers to market-surveillance authorities, have access free of charge “based on their respective access rights set out in the applicable delegated act”. ESPR defines no tiers and assigns no actor to any data; that is left to each product group’s delegated act under Art. 9(2)(f), and ESPR prescribes no enforcement mechanism.
Retention. Art. 9(2)(i) requires the passport to stay available for “at least the expected lifetime of a specific product”, and sets no number of years. Where a number exists, it comes from the product regulation: ten years for toys, detergents and the construction operator’s own duty, and twenty-five years for the construction passport system.

What ESPR does not specify

ESPR does not prescribe a data format, an identity method, a cryptographic scheme or a resolution scheme. The delegated acts for each product group narrow these choices, and the standards bodies (GS1, IDTA, W3C, CEN/CENELEC JTC 24) supply the technical detail.

In practice, the software has to follow several standards as they develop, and update its schemas when the standards bodies publish.

How Odal maps to ESPR

Odal covers the articles of ESPR that matter technically for a passport implementation:

Articles 8, 9 and 12: what a delegated act must specify about the passport, and the identifiers behind it. Art. 9(2) sets the act’s content, including who may read and write which data and how long the passport stays available; Art. 12 and Annex III define the unique product, operator and facility identifiers. A scan resolves to the passport through GS1 Digital Link.

Articles 10 and 11: the passport’s requirements and its technical design. Art. 11(b) is the access provision: readers get access “based on their respective access rights set out in the applicable delegated act”, free of charge, with the question of which actor sees which data left to each product group under Art. 9(2)(f). ESPR sets no access tiers of its own, and no product-group act has been adopted yet.

Transfer of responsibility: when a product moves to another economic operator along the supply chain, Odal records the handover on the passport. The outgoing operator signs the transfer, and the hosting node (not the incoming operator) signs its acceptance, which gives a verifiable chain of custody. ESPR has no single article that sets out how a transfer works. The closest operative text is Art. 11(e) (passport continuity when an operator ceases activity), and who holds the obligations is ultimately what the EU registry records. Our handover record is an engineering choice, not something a specific article requires. See Handing over responsibility.

Article 13: the EU Central Registry, the directory of registered passports, which Art. 13(1) required the Commission to set up by 19 July 2026. The passport itself is served publicly by the resolver, which caches the public view so it stays fast under load.

Articles 24 & 25: the disclosure duty for discarded unsold consumer products (Art. 24) and the ban on destroying unsold apparel, clothing accessories and footwear (Art. 25, Annex VII, in force for large companies since 19 July 2026). Neither involves a passport: both apply to a company over a financial year. Odal records the disclosure line by line, in the format Implementing Regulation (EU) 2026/2 prescribes; see The unsold-goods disclosure.

Which product groups are covered

ESPR is a framework. The binding detail comes in delegated acts for each product group, spread over several years, and some groups get their passport from a separate act instead. Odal has a versioned schema, and for most groups a plugin, for each product group below, so covering more of the law is a matter of the regulation being adopted, not of rebuilding the software. The status column shows what the regulation requires today, not what the software can already read. Indicative years come from the Commission’s 2025–2030 working plan and are not passport dates.

Product group	Regulatory basis	Status today
Batteries	Regulation (EU) 2023/1542	Passport required from 18 Feb 2027 for EV, LMT and industrial batteries over 2 kWh; substance limits enforced now
Textiles	ESPR	No delegated act; indicative adoption 2027. Structural validation only
Iron and steel	ESPR	No delegated act; first in the working plan, indicative adoption 2026
Aluminium	ESPR	No delegated act; indicative adoption 2027. Carbon checks use reference values as warnings only
Tyres	ESPR; Tyre Labelling Regulation (EU) 2020/740	No delegated act; indicative adoption 2027. Label classes in force
Furniture · Mattresses	ESPR	No delegated act; indicative adoption 2028 and 2029
Phones and tablets	Regulations (EU) 2023/1670 and 2023/1669 (ecodesign and energy labelling, not ESPR)	In force since 20 Jun 2025; no passport, product information goes to EPREL
Toys	Regulation (EU) 2025/2509	Passport required from 1 Aug 2030, a date set by the Toy Safety Regulation itself
Detergents	Regulation (EU) 2026/405	Passport required from 23 Sep 2029, with a one-year transition for products meeting the old rules
Construction products	Regulation (EU) 2024/3110	Passport owed 18 months after the Commission’s delegated act setting up the construction passport system (Art. 22(7), Art. 75(1)), not yet adopted. Operator owes 10 years of availability, the passport system 25

Each linked group has its own page, Vehicle passport covers the separate regime for vehicles, and Acts and standards lists every act the code relies on.

What a compliance result claims

Within any product group, some obligations are in force while others wait on a delegated act, and Odal only certifies what the law supports. Every passport is checked for structural and cross-field validity, for every product group, whether or not its obligations are in force. A binding determination, a verdict of compliant or non-compliant, is issued only where the underlying obligation actually applies. Where it does not, the result is recorded as not assessed, and the passport says so.

When a delegated act takes effect, a maintainer switches on the determination for that product group. The switch reads a status recorded in the core library’s instrument catalog, so it changes when a new version of the software is released, not on the date the law changes. Passports already issued are not affected either way. This is why a battery’s banned-substance limits are enforced today, while its 2031 recycled-content minimums are only shown as advisory until they apply. The software reports not yet assessed rather than make a compliance claim the law does not yet support.