ESPR Compliance Checklist for Businesses

The Digital Product Passport requirements, deadlines, and evidence fashion and textiles businesses need to prepare for, in one practical checklist.

The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) entered into force in July 2024 and is reshaping what businesses must be able to prove about their products. It establishes the framework for binding ecodesign requirements across almost every product placed on the EU market, mandates the Digital Product Passport, and bans the destruction of unsold apparel and footwear. This checklist sets out the practical steps businesses should be taking now. It is one of 50 regulations we have mapped that fashion brands need to be aware of and tracking against, but as the regulation mandating Digital Product Passports in the EU, it is the one that matters most right now.

Section 01

Confirm your scope and exposure

Identify which of your product categories fall under ESPR and where they sit in the Commission's 2025–2030 Working Plan (textiles and footwear are named priorities).
Map which legal entity acts as the economic operator placing products on the EU market, including for imports and online sales.
Determine your company size classification: the unsold goods destruction ban applies to large companies (meeting two of: 250+ employees, €50m+ turnover, €25m+ total assets) from 19 July 2026, and to medium-sized companies from 2030.
Confirm which adjacent regulations also apply to your products, from EPR schemes to labelling and chemicals rules.

Section 02

Act on the unsold goods rules now

The ban on destroying unsold apparel, clothing accessories, and footwear applies to large companies from 19 July 2026.
Review how unsold inventory is handled across your operations, including returns, seasonal surplus, and third parties disposing on your behalf.
Map the permitted derogations under the February 2026 delegated act and the documentation each requires.
Put record-keeping in place: evidence supporting any derogation must be retained for five years and made available electronically to authorities within 30 days of request.
Prepare for disclosure: businesses discarding unsold consumer products must report them, with the standardised reporting format applying from 2027.

Section 03

Prepare for the Digital Product Passport

Understand what the DPP requires: structured, machine-readable product-level information on identity, materials, environmental performance, durability, repairability, and end-of-life handling, accessible via a data carrier on the product.
Define your DPP data model by product category and identify which required data you already hold, and where the gaps are.
Assign unique product identifiers and plan how data carriers will be applied across your range.
Track the EU DPP Registry and the delegated acts that will set the exact data requirements for your product groups; the textiles delegated act is expected from 2027.

Section 04

Build the product data foundation

Establish traceability of materials and suppliers to the level of evidence the DPP will require.
Consolidate product data currently spread across PLM, ERP, spreadsheets, and supplier systems into a governed source of truth.
Identify substances of concern in your products and prepare to disclose them.
Verify data quality: DPP information must be accurate and consistent, and wrong data is a compliance risk, not just a data problem.

Section 05

Put governance and evidence in place

Assign clear internal ownership for ESPR compliance across regulatory, product, data, and sustainability functions.
Build an audit trail: every claim in a DPP should be traceable to evidence that stands up to scrutiny.
Set up regulatory monitoring for new delegated acts, as ESPR requirements will continue to roll out product group by product group through 2030.
Brief your board: ESPR is a market access condition and a financial exposure, not a sustainability side project.

Where to start

ESPR readiness is a systems challenge: data, traceability, governance, and evidence, built in the right order. Our START framework takes businesses from regulatory gap analysis through to Digital Product Passport strategy, auditable measurement, and adoption. Use the single free assessment to answer ten questions and see your readiness score on screen straight away.

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This checklist is for general guidance and does not constitute legal advice. Requirements depend on your products, entities, and markets.