ESPR Article 5 Ecodesign Requirement Parameters (Durability, Reparability, Recycled Content, and Others) and the Distinction Between Performance and Information Requirements
ENFORCEMENT TIMELINE
In force since July 18, 2024 (specific numerical requirement levels are determined in stages via product-category-specific delegated acts)
Overview
This card focuses on the specific operational practice for the "core ecodesign requirement parameters" enumerated in Article 5 of the ESPR, and the operational distinction between the two categories of requirements the European Commission sets for each product category: "performance requirements" and "information requirements."
The parameters set out in Article 5 span a wide range: durability, reliability, reusability, upgradability, reparability, the possibility of maintenance and refurbishment, the presence of substances of concern, energy use and efficiency, water use and efficiency, resource use and efficiency, recycled content, the possibility of remanufacturing, the possibility of recycling, the possibility of material recovery, environmental impacts (including carbon and environmental footprint), and expected waste generation. For each product category's delegated act, the European Commission individually decides which of these parameters to set as "performance requirements" (minimum performance thresholds the product must meet) and which to set as "information requirements" (data items that must be disclosed, such as via the Digital Product Passport).
Enforcement Timeline
July 18, 2024: The ESPR (Regulation (EU) 2024/1781) enters into force, legally establishing the Article 5 parameter list.
April 16, 2025: The European Commission adopts its first Ecodesign and Energy Labelling Working Plan (2025–2030), identifying priority product categories including textiles, furniture, iron and steel, aluminium, tyres, and ICT products.
Going forward: Delegated acts setting specific numerical thresholds and data items for performance and information requirements are expected to be adopted in turn for each priority product category (each delegated act generally includes a minimum transition period of 18 months).
Related Regulations / Topics
ESPR Delegated Act on Ecodesign for Textiles (Pending)
The ecodesign delegated act for textiles and apparel is planned under the ESPR (Regulation (EU) 2024/1781). In the Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025–2030 (16 April 2025), textiles/apparel is a priority product, and the indicative timeline for adoption is 2027. ESPR requirements may cover product performance (such as durability, availability of spare parts and minimum recycled content) and product information (such as carbon or environmental footprint, mainly provided through the Digital Product Passport (DPP)). The specific requirements for textiles are not settled until the delegated act is adopted. Footwear is not included in the working plan; a study on applying the ESPR to footwear is to be completed by the end of 2027.
EU ESPR: Application to Electronics and ICT Products (Horizontal Requirements)
The first ESPR Working Plan (published April 2025) does not set a dedicated delegated act for electronics and ICT products. Instead, they are to be covered in stages through two horizontal requirements that cut across product groups: (1) a reparability scoring framework and (2) recycled content and recyclability requirements for electrical and electronic equipment. Smartphones and tablets are handled separately under the energy-related products track.
Business Impact
Product manufacturers need to distinguish and understand whether the delegated act applicable to their product category falls under performance requirements (products failing to meet the minimum performance threshold are excluded from the EU market) or information requirements (the product meets the standard but only disclosure is required). Where a product becomes subject to performance requirements in particular, a fundamental review of product design and preparation of conformity assessment documentation become essential.
Because the Article 5 parameters serve as an evaluation framework common across product categories, companies with multiple product lines benefit from preparing a generalised design and procurement policy for items such as durability, reparability, and recycled content in advance — one capable of responding to any future delegated act — rather than reacting to each category's delegated act on an ad hoc basis as it takes effect.