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Ecodesign Directive vs ESPR: What Changed in 2024

Raahul Dutta9 November 20268 min read
Two men working in a cluttered electronics repair shop.
Photo by Michael Wu on Unsplash

The Ecodesign Directive is repealed. Parts of it still apply. Both of those sentences are true, and mixing them up is how companies end up checking the wrong law.

This page puts the old directive and its replacement side by side, then shows what carries over and until when. For the full introduction to the new law, start with what the ESPR is.

At a glance:

  • The Ecodesign Directive, 2009/125/EC, is repealed. Regulation (EU) 2024/1781, the ESPR, repealed it with effect from 18 July 2024.
  • The directive covered energy-related products. The ESPR covers almost all physical goods, including components and intermediate products.
  • A regulation applies directly. No national transposition is needed, unlike with a directive.
  • Some old rules run on. For named product groups until 31 December 2026, for technical fixes until 31 December 2030, and for existing implementing measures until they are repealed or declared obsolete.
  • New duties came with the ESPR. The digital product passport, a ban on destroying some unsold goods, and green public procurement.

Directive and ESPR side by side

Ecodesign Directive 2009/125/EC ESPR, Regulation (EU) 2024/1781
Legal form Directive, to be transposed by each member state Regulation, binding in its entirety and directly applicable
Scope Energy-related products Any physical goods placed on the market, with exclusions
How product rules are set Implementing measures Delegated acts (Article 4)
What rules can cover Ecodesign requirements for energy-related products Durability, reliability, repair, upgrading, recycling, substances, recycled content, footprints (Annex I)
Digital product passport None Yes, Chapter III
Unsold goods No rule Destruction ban for listed goods (Article 25)
Public procurement No rule Framework for mandatory green public procurement (Article 65)
Status Repealed from 18 July 2024, with exceptions In force

The title of the directive gives the first row away. It sets a framework for ecodesign requirements for energy-related products. The ESPR sets a framework for ecodesign requirements for sustainable products, and it adds the passport, the unsold goods rules and green procurement to that framework.

A directive tells member states what result to reach and leaves them to write national law. A regulation does not. The ESPR is binding in all its parts and directly applicable in every member state. One text applies everywhere, and the rules for each product group arrive as delegated acts at EU level.

For a manufacturer or importer that is simpler. You read one set of rules, not 27 national versions.

Who is in scope now?

The ESPR covers physical goods placed on the market or put into service, components and intermediate products included. It does not apply to:

  • food and feed,
  • medicinal products and veterinary medicinal products,
  • living plants, animals and micro-organisms,
  • products of human origin,
  • plant and animal products relating directly to their future reproduction,
  • vehicles, for the aspects that sector-specific vehicle laws already cover.

So a maker of furniture, textiles or steel, who was never touched by the directive, is now in the frame. Whether a rule reaches your product still depends on a delegated act for your product group. The first ESPR work plan names the groups to be taken first, and which products need a digital product passport shows where each stands.

Hands wiring electronics with tools and a laptop nearby.

Photo by Eric Stoynov on Unsplash

What still applies from the old directive?

Article 79 of the ESPR repeals the directive from 18 July 2024, with the exception of several articles. Those exceptions are the transition. They come in three layers.

Layer What continues Until
Listed product groups Parts of the directive, including its route for adopting implementing measures, continue instead of the matching ESPR articles. The list includes photovoltaic panels, space and water heaters, air conditioners, ventilation units, vacuum cleaners, cooking appliances, water pumps, external power supplies, computers, servers and data storage products, power transformers, professional refrigeration equipment and imaging equipment 31 December 2026
Existing implementing measures The same route stays open, but only to the extent amendments are needed to address technical issues 31 December 2030
Products already regulated by implementing measures Further directive rules, on matters such as conformity assessment and CE marking, continue instead of the matching ESPR articles Until the measures are repealed or declared obsolete

Two things follow. First, the first date is close: 31 December 2026 is just over seven weeks from this page. Second, the 2030 date is narrow. It covers technical amendments to existing measures, not a general extension.

Some ESPR rules also already reach products under the old measures. Article 79(2) applies the ESPR rules on free movement (Article 3), on preventing circumvention (Article 40) and on market surveillance and safeguards (Articles 66 to 71) to them.

The records duty that survives

One small rule matters for anyone who put products on the market under the directive. If you placed a product on the market in line with the directive before a delegated act applies to the same product, you must keep the conformity documents and the declaration of conformity. You must make an electronic copy available to market surveillance authorities or the Commission within 10 days of a request. The period runs for 10 years from the date the last of those products was manufactured (Article 79(4)).

Do not discard old technical files because the directive was repealed.

Key dates

Date What happens
21 October 2009 The Ecodesign Directive is adopted
18 July 2024 The ESPR applies and repeals the directive, with exceptions
16 April 2025 First ESPR work plan adopted
19 July 2026 Destruction ban on unsold apparel and footwear starts for large companies
20 July 2026 EU digital product passport registry goes live
31 December 2026 Transition for the listed product groups ends
18 February 2027 Battery passport applies (under the Batteries Regulation, not the ESPR)
31 December 2030 Transition for technical amendments ends

The iron and steel delegated act is the next ESPR product act. The Commission gives Q4 2026 as an indicative time and says timelines can change. For the latest, see digital product passport news.

What to do

  1. Find your legal basis. Is your product already regulated by an implementing measure under the directive? If so, those rules still apply.
  2. Check the transition list. If your product is on it, note 31 December 2026.
  3. Keep your old files. The 10-year duty in Article 79(4) is real.
  4. If you are new to ecodesign, check whether your product group is in the work plan and start collecting the data it will need.
  5. Read the delegated act when it lands, and read its date separately from its rules. An act cannot apply earlier than 18 months after entry into force, except in duly justified cases (Article 4(4)).

Where Bindu fits. Whatever product rule applies, the work starts with product data: what it is made of, who supplied it, and which papers prove it. Bindu collects and keeps that data so it is ready before an act fixes the format. See how the passport is built.

A man working on electronics at a cluttered desk.
Photo by Stacey Zinoveva on Unsplash

FAQ

Is the Ecodesign Directive still in force? No. The ESPR repealed Directive 2009/125/EC with effect from 18 July 2024, but certain articles continue to apply for named product groups and for existing implementing measures.

Source: EUR-Lex: Regulation (EU) 2024/1781, Article 79

What replaced the Ecodesign Directive? Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR). It sets a framework for ecodesign requirements for sustainable products and also creates the digital product passport.

Source: EUR-Lex: Regulation (EU) 2024/1781, Article 1

What is the difference between the Ecodesign Directive and the ESPR? The directive covered energy-related products and had to be transposed by each member state. The ESPR is a regulation, applies directly, covers almost all physical goods and adds a digital product passport, a destruction ban for some unsold goods and green public procurement.

Source: EUR-Lex: Regulation (EU) 2024/1781, Articles 1 and 25

Does the ESPR apply to products that are not energy-related? Yes. It applies to any physical goods placed on the market or put into service, including components and intermediate products. Food, feed, medicinal products and a few other categories are excluded.

Source: EUR-Lex: Regulation (EU) 2024/1781, Article 1(2)

What happens to existing ecodesign regulations? Implementing measures adopted under the directive stay in place. The directive's rules that go with them continue to apply until the measures are repealed or declared obsolete.

Source: EUR-Lex: Regulation (EU) 2024/1781, Article 79(1)(b)

When does the transition from the directive end? For the product groups listed in Article 79(1)(a)(i), on 31 December 2026. For technical amendments to existing implementing measures, on 31 December 2030.

Source: EUR-Lex: Regulation (EU) 2024/1781, Article 79(1)(a)


This article reflects the official position as of 9 November 2026. This is general information, not legal advice.