Ecodesign for Sustainable Products Regulation (ESPR), EU Energy Labelling Regulation and EU Eco-label Frameworks

This article is provided by BRC Associate Member, UL Solutions.

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Ecodesign for Sustainable Products Regulation (ESPR)

On June 13, 2024, Regulation (EU) 2024/1781 on Ecodesign Requirements for Sustainable Products was published, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542, and repealing Directive 2009/125/EC.

The Ecodesign for Sustainable Products Regulation (ESPR) is the cornerstone of the European Commission’s approach to advancing more environmentally sustainable and circular products.

It establishes a framework for setting ecodesign requirements for various product groups to help enhance environmental sustainability, reduce carbon and environmental footprint throughout the product life cycle, and enable free movement of products within the European Union (EU).

ESPR applies to any physical product placed on the EU market or put into service, including components and intermediate products. It does not apply to food, animal feed, medicinal or veterinary products, living plants, animals, microorganisms, products of human origin, products of plants and animals related to reproduction, or vehicles.

ESPR partially repealed the Energy-Related Products Directive 2009/125/EC (also known as the EU Ecodesign Directive) as of July 18, 2024. However, some transitional provisions remain in effect for energy-related products under various timelines.

ESPR empowers the European Commission to adopt delegated acts for different product groups, supplementing the regulation with mandatory ecodesign and performance requirements. These delegated acts will define specific requirements, such as:

• Durability, reliability, reusability, upgradability, repairability, maintenance and refurbishment
• Substances of concern
• Energy, water, and resource use and efficiency
• Recycled content, remanufacturing, recyclability and material recovery
• Environmental impacts
• Waste reduction

Delegated acts will not apply earlier than 18 months after their entry into force, except in justified cases.

On April 16, 2025, the European Commission adopted the first working plan for ESPR and Energy Labelling Regulation for 2025-2030. The plan prioritises the following products and intermediate products (with the implementing act adoption year indicated below):

• Iron and steel (2026)
• Textile and apparel (2027)
• Tires (2027)
• Aluminium (2027)
• Furniture (2028)
• Mattresses (2029)

The plan also includes two legal acts setting horizontal requirements:

• Repairability, including scoring (2027)
• Recycled content and recyclability of electrical and electronic equipment (2029)

The previous Ecodesign and Energy Labelling working plan for 2022-2024 covered 35 products. For 19 of these products, ESPR sets a transition period of Dec. 31, 2026; during this time, the measures continue to be covered by the Ecodesign Directive. For the remaining 16 products, the European Commission considers the analysis of potential improvements still valid.

Additional requirements introduced by the ESPR also include CE marking, EU Declaration of Conformity, technical documentation, digital product passport and dispositions on unsold products. The prevention of destruction and related derogations and transparency obligations will also apply to different requirements and, in some cases, will need implementing acts. Delegated acts will specify conformity assessment procedures, which may require third-party certification.

Energy Labelling Framework Regulation (ELFR)

Energy labelling helps buyers make informed choices and encourages manufacturers to innovate. In 2017, Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 was published, setting a framework for energy labelling and repealing Directive 2010/30/EU. This regulation — also called the EU Energy Labelling Framework Regulation, or ELFR — applies to energy-related products placed on the market or put into service. It requires labelling and standardised product information on energy efficiency, energy consumption and other resource consumption during use, as well as supplementary information. ELFR does not apply to second-hand products (unless imported from outside the EU) or means of transport.

Recent energy-related product display labels provide an updated, clearer scale ranging from Class A (dark green, most efficient) to Class G (red, least efficient). Requirements also include a product information sheet and supplier registration in the European Product Registry for Energy Labelling (EPREL). Delegated acts of ELFR shall be published to define detailed requirements for specific product groups.

Current and upcoming ecodesign and energy label requirements for domestic ovens, refrigerating appliances and vacuum cleaners

The following table provides an overview of the regulatory landscape for three key household product categories: the domestic ovens, refrigerating appliances and vacuum cleaners. It summarises the current ecodesign and energy labelling requirements under existing EU legislation and highlights the upcoming changes expected under the Ecodesign for Sustainable Products Regulation (ESPR) and the Energy Labelling Framework Regulation (ELFR).

Product category	Type of requirement	Current implementing acts	Upcoming acts under ESPR/ELFR
Domestic electric and gas ovens and domestic electric range hoods	Ecodesign	Commission Regulation (EU) No 66/2014 (adopted under the old EU Ecodesign Directive)	Public consultations were launched in 2023; adoption of the acts expected in the third quarter of 2026
	Energy labelling	Commission Delegated Regulation (EU) No 65/2014 (adopted under the old Energy Labelling Directive (2010/30/EU))
Electric mains-operated refrigerating appliances with a volume of more than 10 litres and of less than or equal to 1,500 litres for domestic use	Ecodesign	Commission Regulation (EU) 2019/2019 (adopted under the old Ecodesign Directive)	Public consultation launched in May 2025; adoption expected between the first quarter of 2026 and the third quarter of 2028
	Energy labelling	Commission Delegated Regulation (EU) 2019/2016 (adopted under the newer regulation ELFR)
Electric mains-operated vacuum cleaners for domestic indoor use	Ecodesign	Commission Regulation (EU) No 666/2013 (adopted under the old Energy Labelling Directive)	Public consultations were launched in 2023; adoption of the acts expected in the first quarter of 2026
	Energy labelling	None; no specific act currently applies (a previous act was annulled)