Navigating the ESPR: A Guide to the First Steps for Business Compliance

The Ecodesign for Sustainable Products Regulation (ESPR) is becoming increasingly familiar to businesses operating in the EU market. With growing media attention on the legislation's role in driving economic circularity and sustainability, largely through Digital Product Passports (DPPs), many businesses understand the reasons behind the regulation.

However, they may be unsure about the actionable steps needed to ensure compliance. The first crucial step is identifying and validating the necessary data to support this. This phase is often more complex than businesses anticipate, so taking early action can greatly ease the transition process.

The EU’s aim for economic circularity - The movement and its impact on businesses In recent months, awareness of the Ecodesign for Sustainable Products Regulation (ESPR) has grown, especially among businesses in the EU. For those new to the regulation, the ESPR is a key part of the EU’s Circular Economy Action Plan (CEAP), aimed at transforming product sustainability across the region. The regulation is designed to make "sustainable products the new norm" by focusing on product longevity, energy efficiency, ease of repair and recycling, reducing harmful substances, and incorporating recycled materials.

The ESPR will particularly affect industries with significant environmental impacts, such as textiles and ICT, and will apply to any business placing items within these product groups in the EU market - irrelevant of where they are based. A central feature of the regulation is the Digital Product Passport (DPP), a digital record that tracks a product’s life cycle, capturing event, transactional, and sustainability data. While the detailed guidelines for DPPs - covering information relating to exactly what data is required - are still yet to be released, businesses must begin by collecting and validating data on their products' environmental impact.

This initial step can be challenging, as data is often scattered across different systems within a company's value chain, making it difficult to source and validate. With this in mind, businesses should proactively map and organise their data in preparation for the regulation’s full implementation.

The following 6 steps provide a structured and clear pathway for assessing, gathering, and integrating essential environmental data across the supply chain:

1. Connect with key stakeholders to evaluate your current position and readiness

To start, businesses should actively collaborate with stakeholders throughout the supply chain, including suppliers, manufacturers, and logistics partners. This approach helps build a comprehensive view of available product life cycle data. Additionally, engaging in these

discussions can reveal previously unknown information and open conversations about improving data transparency and access across the chain.

2. Conduct a data gap analysis to pinpoint missing information

After identifying existing data, it's recommended to conduct a data gap analysis, focusing on the elements likely to be required in a DPP, even before specific guidelines are released. This might include data on waste generated during production or the carbon footprint of manufacturing. This analysis will help pinpoint gaps in the product life cycle within your business, allowing you to determine how best to address them. Solutions may involve implementing measurement tools or partnering with new stakeholders to support data collection and accuracy.

3. The need for a Life Cycle Assessment (LCA) audit to effectively fill data gaps

At this point, once data gaps are identified, conducting a life cycle assessment (LCA) should be prioritised to ensure all gaps are filled. This process measures the environmental impact of a product’s life cycle and can start from the point of raw material extraction to provide a complete view.

4. Assessing Digital Product Passport Solutions for a smooth implementation

After collecting and analysing the necessary data, evaluating DPP solutions is key to ensuring a seamless transition. Given the complexities involved, developing a DPP system in-house may not be feasible for most businesses. Instead, seeking partners who specialise in DPP development and deployment will allow businesses to address their unique requirements effectively.

Since DPPs are essential for ESPR compliance, it’s crucial to assess how data will be formatted, inputted, and stored within the systems. This includes ensuring the DPP solution can integrate with existing business systems and may be able to reflect real-time updates on a product's life cycle. By carefully choosing a DPP solution tailored to their needs, businesses can streamline data capture, storage, and accessibility throughout the product’s life cycle.

5. Validate data sources for accuracy and ease of mind

Throughout their data compliance journey, businesses need to validate data sources to build an accurate, verifiable picture of each product. This means assessing the credibility of third-party data suppliers, and ensuring processes are underpinned by the relevant standards.

6. Launching pilot programs for testing and evaluation

After completing the initial steps, the next logical phase is to pilot a DPP solution in a test environment. This allows businesses to test their strategy and gain a clearer view of the scale and timing needed for full deployment. Through piloting, companies can refine their approach, making them well-prepared for the final requirements once the delegated acts are released.

Effective compliance with the EU’s ESPR relies on a strategic, methodical approach to collecting, validating, and integrating environmental data across the supply chain.

The stepping stones to compliance

Although there are still unknowns as we await the release of the delegated acts, the path to ESPR compliance can be much less overwhelming if companies focus on practical, manageable steps they can take now. Developing a strong compliance strategy grounded in accurate data and reliable validation processes will not only support ESPR alignment but also promote greater sustainability and operational resilience.