Design for longevity.
Prepare for what applies.

Build an applicability record containing the product description, destination, current legal measure and relevant dates. For energy-related products, retain the existing ecodesign assessment where applicable under transitional arrangements. For newly prioritised goods, identify which requirements have actually been adopted before creating a compliance claim.

• Label each tracked measure as applicable, future adopted or proposed.

Potential ecodesign requirements address durability, repairability, resource use and other lifecycle characteristics. Translate the applicable measure into design questions your engineers can answer. A repairability assessment may need disassembly and spare-part information, while material circularity requires a different evidence chain.

• Avoid presenting a sustainability rating as regulatory approval.

Create a controlled record for materials, manufacturing inputs, component identities and claimed performance. Record the origin and limitations of each data item. Supplier estimates, measured values and verified declarations should remain distinguishable so later reporting does not turn an assumption into an apparently established fact.

• Assign ownership for collecting and updating supplier evidence.

The digital product passport is part of ESPR’s information framework. The required data and implementation depend on the relevant measure. Start by mapping identifiers and data owners; do not buy or publish a passport on the assumption that a generic QR code alone demonstrates compliance.

• Keep public information separate from access-controlled business data.

ESPR also contains provisions concerning unsold consumer products, including disclosure and restrictions on destruction in defined circumstances. These require a separate review of business size, product scope, dates and exemptions. Inventory and returns teams may hold the relevant information rather than the design department.

• Maintain traceable records of unsold-product handling decisions.

Prioritise actions against the product’s actual legal timetable. Resolve current compliance gaps first, then prepare data and design changes for adopted future requirements. Keep speculative development options separate from release decisions so teams can invest in useful capabilities without claiming that unpublished rules already apply.

• Review the roadmap when a final measure or amendment is published.