ESPR Overview

The Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781) is the framework regulation that establishes the Digital Product Passport requirement across the European Union. It entered into force in 2024, and the first product-group delegated acts started landing immediately. By 2027, every product placed on the EU market that falls under a delegated act needs a machine-readable DPP.

What ESPR requires

The regulation establishes three core obligations that shape every implementation. The first is the passport itself — every regulated product must have a machine-readable Digital Product Passport accessible via a data carrier (typically a QR code) on the product. The second is regulatory access control — the passport must distinguish between public information, information available to authorised actors, and private information, with cryptographic enforcement of the boundaries. The third is retention — the passport must remain accessible for the lifetime of the product plus a regulator-defined retention horizon (10 to 20 years depending on sector).

What ESPR does not specify

The regulation is deliberately technology-neutral in important places. It does not mandate a specific data format, a specific identity method, a specific cryptographic scheme, or a specific resolution scheme. The delegated acts (per product group) tighten these decisions, and the standards bodies (GS1, IDTA, W3C, CEN/CENELEC JTC 24) fill in the technical detail.

The implications for the implementation are that the platform has to track several converging standards simultaneously and update its schemas as the standards bodies publish.

How Odal maps to ESPR

Odal covers the articles of ESPR that are technically substantive for a passport implementation:

Articles 8 and 9 — the format of the passport and its data carrier: the passport itself is the format, and GS1 Digital Link is how a scan resolves to it.

Article 10 — the three-tier access control. Odal carries the tier boundaries and the resolver enforces them on every request.

Article 12 — the transfer of responsibility from one economic operator to another along the supply chain, implemented as a dual-signature chain: both transferor and transferee sign, creating a verifiable chain of custody.

Article 13 — public access to passports. The resolver serves the public view, cached to stay fast under load.

Article 22 — the ban on destroying unsold consumer products, with the reporting obligations that flow through the passport. Odal carries a dedicated unsold-goods passport variant that records the disposal pathway as a verifiable record.

Which sectors are covered

ESPR is a framework; the binding detail arrives through per-product-group delegated acts, staggered across years. Odal carries a seam — a versioned schema and a sector plugin — for each sector below, so widening coverage is a matter of the regulation maturing, not of re-engineering. The status reflects what the regulation requires today, not what the software can already parse.

Sector	Regulatory basis	Status today
Battery	EU 2023/1542	In force — passport mandatory 18 Feb 2027; substance limits enforced now
Textile	ESPR delegated act (in drafting)	Structural validation now; unsold-goods ban (Art. 22) applies from 2026
Electronics	ESPR delegated act (adopted Mar 2026)	Phasing in — high-end from Apr 2026, the rest from Jan 2027
Steel · Aluminium	CBAM 2023/956 / ESPR	Reference benchmarks only; no DPP mandate yet (aluminium expected ~2030)
Construction	CPR 2024/3110	Awaiting delegated acts (2028–2032)
Toys	EU 2025/2509	Awaiting delegated act (~2030)
Furniture · Detergent · Tyre	ESPR	Seams in place; awaiting delegated acts

Battery, textile, and electronics have dedicated pages below; the rest run on the same mechanism, waiting on their regulation.

What a compliance result actually claims

Within any sector, some obligations are in force while others wait on a delegated act, and Odal is deliberate about not overstating what it can certify. Every passport is checked for structural and cross-field validity — that runs for every sector, in force or not. But a binding determination — a verdict of compliant or non-compliant — is issued only where the underlying obligation actually binds. Where it does not, the result is recorded as not assessed rather than guessed, and the passport carries that honestly.

As each delegated act takes effect, the matching sector’s determination switches on, with no change to passports already issued. This is why a battery’s banned-substance limits are enforced today while its 2031 recycled-content minima are surfaced only as advisory until they bind. The system would rather say not yet assessed than assert a compliance claim the law does not yet support.