What is happening in the EU product policy landscape?

The EU product policy landscape is changing rapidly as sustainability requirements move from voluntary commitments to legal obligations. The Ecodesign for Sustainable Products Regulation (ESPR) will change how products are designed, documented and sold in Europe over the next decade.

ESPR will set mandatory sustainability standards (‘performance requirements’) for almost all physical products sold on the EU market. These new rules will ensure products sold in the EU are more durable, repairable, recyclable, and transparent in their environmental impact. Manufacturers will need to demonstrate compliance. If products do not meet performance thresholds, they will need to be removed from the EU market or re-designed to avoid penalties. Rather than a single set of requirements, ESPR is a framework for product-specific rules that will be introduced gradually across multiple sectors.

Why ESPR Matters for Sustainability and Compliance in the EU?

For brands and manufacturers, ESPR will shape product design, data management, compliance and market access. Any business which manufactures a product will have responsibilities, as well as the downstream value chain—importers, distributors, online marketplaces and dealers.

One of the biggest changes is the introduction of Digital Product Passports (DPP)—think QR codes showing the environmental impact of products e.g., material composition, environmental footprint and repair instructions. For manufacturers, this means gathering and managing data they may not already hold, and sharing product data across the supply chain. Beyond just holding information, DPPs could be an opportunity for companies to engage with their customers.

Why is ESPR Complicated? Unpacking the Ecodesign for Sustainable Products Regulation's Key Challenges

Manufacturers will need traceable, product-level sustainability data that can be shared with regulators, customers and their value-chain. This will involve identifying data already held in existing systems, as well as generating new data not previously collected. As a result, companies will need robust and agile product data management systems.

Depending on the product, data may also require further processing, e.g., for a Life Cycle Assessment, where inventory data is converted into outputs like greenhouse-gas emissions. Managing compliance across large product portfolios will add complexity, as manufacturers must ensure that each product meets the necessary information and performance criteria and that data is uploaded to a DPP.

What can you prepare now to comply with ESPR?

The exact roll-out of ESPR is currently uncertain, as Delegated Acts are yet to be adopted. First product requirements will apply 2027-2028, with broader rollout in 2030, but companies are starting to prepare now, especially around product data, lifecycle information and DPP readiness. This is particularly important for priority sectors: iron and steel, textiles/apparel, tyres, aluminium, furniture and mattresses.

How can SAP help you to get ready for ESPR?

With around 70% of the data required for Digital Product Passports already held in, or easily brought into, the core SAP system of record, SAP’s DPP strategy begins with ensuring robust regulatory compliance and then extends into a product operating system that governs how identity, materials, suppliers, claims, and lifecycle decisions are controlled across design, sourcing, manufacturing, retail, and reuse.

By unifying traceability, regulatory signals, sustainability impacts, and AI-generated insights into a single control plane—supported by PLM systems, business network, SAP Sustainability Footprint Management, and SAP Product Compliance—SAP enables organisations to create trusted product identities, enforce evidence-backed claims, and embed decision gates that ensure products are regulator-ready, defensible, and fit for future market access. With this foundation, companies can move just defensive compliance to business benefits - reducing operational and regulatory risk, driving down material and energy use, lowering costs and indirect taxes, and strengthen supply chain resilience.

To learn more about SAP DPP's strategy, please contact us or request a demo with an SAP expert.

Note: This article is a collaboration between SAP and Eunomia Environmental Research & Consulting sustainability experts. Check out the latest whitepaper: ‘Ready, Set, Comply: Preparing your business for the PPWR’