{
"id": "espr",
"title": "Ecodesign for Sustainable Products Regulation (EU) 2024/1781",
"celex": "32024R1781",
"kind": "framework",
"status": "adopted",
"currency": { "state": "consolidated", "asOf": "02024R1781-20240628", "checkedOn": "2026-09-11" },
"passport": { "obligation": "required" },
"retentionYears": 10,
"retentionYearsBasis": "assumed",
"customerPersonalData": { "storage": "explicitConsentOnly", "provision": "Regulation (EU) 2024/1781 Art. 10(1)(e)" },
"productGroups": [
{
"productGroup": "textile",
"status": "provisional",
"legalBasis": ["Regulation (EU) 2024/1781 Art. 18"],
"notes": "Art. 18 statutory priority list ('textiles, in particular garments and footwear'); selected as a final product in the 2025-2030 working plan with an indicative delegated-act adoption year of 2027. No delegated act exists, so nothing is determinable and no CN range is knowable."
},
{
"productGroup": "furniture",
"status": "provisional",
"legalBasis": ["Regulation (EU) 2024/1781 Art. 18"],
"notes": "Art. 18 lists 'furniture, including mattresses'; the working plan then selects Furniture and Mattresses separately, with different rankings and indicative adoption years of 2028 and 2029 respectively. Mattresses is bound separately below and must not be carried as a category here."
},
{
"productGroup": "mattress",
"status": "provisional",
"legalBasis": ["Regulation (EU) 2024/1781 Art. 18"],
"notes": "Selected in the 2025-2030 working plan as a final product distinct from Furniture, ranked fourth among final products, indicative adoption 2029. The Regulation groups it under furniture and the working plan splits it out — which is why product group cannot be a fixed taxonomy: the grouping changed between the framework and its own working plan."
},
{
"productGroup": "tyre",
"status": "provisional",
"legalBasis": ["Regulation (EU) 2024/1781 Art. 18"],
"notes": "Art. 18 priority list; working plan final product, indicative adoption 2027. Already regulated in part by the Tyre Labelling Regulation (EU) 2020/740, which is a labelling instrument and not a passport one."
},
{
"productGroup": "steel",
"status": "provisional",
"legalBasis": ["Regulation (EU) 2024/1781 Art. 18"],
"notes": "Art. 18 'iron and steel'; working plan intermediate product, ranked first, indicative adoption 2026. The JRC priorities study indicates a scope of CN chapters 72 and 73 — an indication from a preparatory study, not a legal scope: ESPR Art. 8(a) puts the commodity codes in the delegated act, and none exists."
},
{
"productGroup": "aluminium",
"status": "provisional",
"legalBasis": ["Regulation (EU) 2024/1781 Art. 18"],
"notes": "Art. 18 priority list; working plan intermediate product, indicative adoption 2027. Intermediate products may have their delegated acts reach final products containing them, which is one of the ways one product accumulates several instruments."
},
{
"productGroup": "unsold-goods",
"status": "in_force",
"legalBasis": [
"Regulation (EU) 2024/1781 Art. 24",
"Regulation (EU) 2024/1781 Art. 25",
"Regulation (EU) 2024/1781 Annex VII"
],
"passport": { "obligation": "notRequired" },
"notes": "Binding today and determinable: the Art. 25(1) destruction prohibition for Annex VII goods has applied since 2026-07-19, and the Art. 24 disclosure duty is live for large operators, with medium-sized operators brought in from 2030-07-19 and micro and small enterprises exempt. There is no passport anywhere in Arts. 24-25 — the subject is an operator over a financial year, disclosed on its own website, not a product placed on the market. This is why the obligation binds while requiring no passport: the two questions are separate and this binding answers them differently. The 2026-07-19 date is the destruction ban's, and it must never be recorded as a passport date."
}
],
"notes": "The framework itself. Art. 9(1) requires 'a digital product passport ... in accordance with the applicable delegated acts' — singular passport, plural acts — so the obligation is real but undated until a delegated act fixes it. Art. 5(7) lets one act cover many product groups and lets a group-specific act supplement a horizontal one, and no precedence rule exists anywhere in the Regulation: overlapping acts accumulate. retentionYears is assumed, not sourced, and applies to every group below: Art. 9(2)(i) sets no figure — it requires availability for at least the expected lifetime of the product, delegated per product group, and no delegated act has been adopted for any of them. As of 2026-08-24 that is true of every ESPR product group without exception."
}