EU circular economy regulations: ESPR, PPWR and Digital Product Passport— compliant from day one.

The Ecodesign for Sustainable Products Regulation (ESPR, Regulation 2024/1781) entered into force in July 2024, replacing and substantially expanding the 2009 Ecodesign Directive. The regulation establishes a working plan framework under which the European Commission adopts delegated acts setting ecodesign requirements for specific product categories. The first ESPR Working Plan (2024–2027) prioritises: textiles (beginning with garments and footwear — delegated act expected 2025/2026); furniture; iron and steel; aluminium; tyres; detergents and cleaning products; paints and varnishes; electronics and ICT (extending existing measures for televisions, computers, washing machines). For products in scope, ESPR requirements can cover energy efficiency, material efficiency, recycled content minimum percentages, design for disassembly requirements, availability of spare parts and repair information, prohibition of destruction of unsold goods, and Digital Product Passport obligations. Unlike the original Ecodesign Directive which focused solely on energy-related products, ESPR can address any product category sold in the EU. IgeraIndustria tracks ESPR delegated act status and timeline for each product category.

The Digital Product Passport (DPP) is a central innovation of the ESPR framework — a structured data carrier (QR code, RFID or data matrix) linked to a product-specific dataset in the EU DPP Registry managed by ECOS/ECHA. Mandatory DPP data fields vary by product category but the ESPR DPP framework establishes common requirements: unique product identifier (UPI), manufacturer/importer details, place of manufacture, general product information, materials and substances present (including SVHC concentrations above 0.1% w/w per REACH Article 33), recycled content percentage, carbon footprint, instructions for use and end-of-life. For batteries (EU Battery Regulation 2023/1542), DPP requirements apply from 18 February 2027 for industrial and EV batteries — mandatory data includes: battery chemistry, capacity, state of health, recycled content of cobalt/lithium/nickel/lead, carbon footprint per kWh by lifecycle stage, and due diligence on sourcing of raw materials. For textiles, the DPP is expected from 2026 under the ESPR delegated act — including fibre composition, country of manufacture, and recyclability instructions. For construction products under the Construction Products Regulation (CPR) revision, DPP requirements are expected from 2026 for a first set of product categories. IgeraIndustria maps current DPP data requirements by product category and publication timeline.

The Packaging and Packaging Waste Regulation (PPWR, Regulation 2025/40, replacing Directive 94/62/EC) entered into application progressively from 2025. For recycled content in plastic packaging, PPWR sets minimum mandatory recycled content targets that differentiate by packaging type and contact application. For plastic packaging in non-contact applications: 35% recycled content by 2030 and 65% by 2040. For plastic packaging in contact-sensitive applications (food contact, excluding PET beverage bottles): 10% by 2030 and 25% by 2040. For PET beverage bottles: 30% by 2030 (building on the SUP Directive requirement already in force) and 65% by 2040. For other plastic bottles: 30% by 2030 and 50% by 2040. PPWR also sets packaging minimisation requirements, prohibits certain formats (overly complex multi-material packaging where mono-material alternatives exist), and requires packaging to be recyclable by design from 2030 (i.e. sortable at scale and technically recyclable in existing EU recycling infrastructure). IgeraIndustria has PPWR requirements indexed for packaging designers, procurement and compliance teams.

Extended Producer Responsibility (EPR) for packaging has existed across EU member states since the 1994 Packaging Directive, but the implementation varies significantly: Germany operates a dual system (Gruner Punkt successors), France has CITEO, the UK (post-Brexit) reformed its PRN/PERN system, and Southern European member states have fragmented producer responsibility organisations (PROs). PPWR introduces minimum harmonisation requirements for EPR schemes across EU27: standardised EPR fee modulation based on recyclability of packaging (eco-modulation — lower fees for easily recyclable packaging, higher for non-recyclable); minimum requirements for PRO transparency and governance; mandatory reporting by producers on quantities placed on market by packaging type; harmonised definitions of packaging and packaging waste; and a minimum threshold of 1 tonne/year of packaging placed on the EU market before EPR registration obligation applies. PPWR does not eliminate national EPR schemes but requires member states to transpose the harmonised requirements by 2027. Multinational producers placing packaging on multiple EU markets must register in each member state where they supply — PPWR aims to reduce but not eliminate this multi-registration burden. IgeraIndustria tracks EPR registration requirements and fee modulation criteria by member state.

The Green Claims Directive (Directive 2024/825/EU, amending the Unfair Commercial Practices Directive 2005/29/EC) targets environmental claims made in business-to-consumer commercial communications. From the transposition deadline (July 2026 for member state law), explicit environmental claims must meet substantiation requirements before they can be made. Key requirements: (1) Claims must be based on a recognised scientific methodology that considers the full lifecycle of the product — partial lifecycle claims (e.g. “made from recycled materials” without addressing carbon footprint) are prohibited unless the scope limitation is clearly disclosed; (2) Claims that cannot be independently verified are prohibited; (3) Generic environmental claims (“eco-friendly”, “sustainable”, “green”, “climate neutral”) are prohibited unless supported by a recognised label scheme or specific substantiated evidence; (4) Future performance claims (“net zero by 2040”) must be based on a published, credible transition plan with verified milestones; (5) Carbon offset claims — stating a product is “carbon neutral” through offsetting — are effectively prohibited as a standalone claim. The Directive applies to all businesses selling to EU consumers regardless of where the business is established. IgeraIndustria indexes the Green Claims Directive and substantiation requirements for marketing and compliance teams.

Article 6 of the Waste Framework Directive (WFD, Directive 2008/98/EC as amended) provides the legal framework for materials to cease being classified as waste — achieving “End of Waste” (EoW) status. EoW criteria can be set at EU level through Commission Regulations (currently in force for iron, steel and aluminium scrap; copper scrap; and recycled aggregates) or at national level by member state competent authorities where no EU-level criteria exist. For EU-level EoW criteria, a material ceases to be waste when: it is commonly used for specific purposes; a market or demand exists; it meets technical requirements for those uses; and its use will not lead to overall adverse environmental or human health impacts. For national EoW assessments (where no EU criteria exist), companies must demonstrate these four criteria to the competent authority and obtain a case-by-case decision. In the UK, the Environment Agency (EA) Quality Protocol for specific waste streams (e.g. glass, aggregates, compost) provides the equivalent EoW mechanism post-Brexit. The ESPR and PPWR frameworks create additional pressure to achieve EoW status for secondary materials used as recycled content — because PPWR recycled content targets can only be met with materials that legally qualify as secondary raw materials, not waste. IgeraIndustria maps EU-level and member state EoW criteria for key material streams.