ESPR comes into force
The Ecodesign for Sustainable Products Regulation becomes law, creating the legal basis for ecodesign rules and the Digital Product Passport across almost all physical goods.
Clear, practical guidance on circularity, sustainability regulations, and the software powering the transition—for businesses.
Covering the regulations and frameworks shaping the future of products:
The regulatory landscape for products is shifting fast. ESPR, Digital Product Passports, and sector-specific rules are no longer future concepts—they are active compliance requirements with fixed deadlines. Circular Notes cuts through the complexity.
Plain-English breakdowns of ESPR, DPP, and sector-specific obligations.
Independent comparisons and buyer’s guides for DPP, LCA, and PLM platforms.
Checklists, templates, and frameworks you can use today.
Regulatory timeline
From the Digital Product Passport to packaging, batteries and deforestation, these are the dates that decide what you must have ready, and when.
The Ecodesign for Sustainable Products Regulation becomes law, creating the legal basis for ecodesign rules and the Digital Product Passport across almost all physical goods.
The Packaging and Packaging Waste Regulation enters into force, starting an 18-month countdown before its rules apply.
The 2025–2030 ESPR working plan sets the first priorities, including textiles, furniture, tyres, mattresses, steel and aluminium. Work on detailed passport requirements begins.
The Commission’s central registry, which will store the unique identifiers linked to every Digital Product Passport, is due to be in place.
Large companies can no longer destroy unsold apparel and footwear, and must disclose what they discard and why.
The general application date of the PPWR. Obligations then phase in over the following years.
The Empowering Consumers for the Green Transition Directive applies: vague environmental claims and offset-based “climate neutral” product claims are banned unless they can be proven.
Large and medium-sized operators, and traders, must show that covered products such as cattle, cocoa, coffee, palm oil, rubber, soy and wood are deforestation-free.
Every EV battery, light-means-of-transport battery and industrial battery above 2 kWh placed on the EU market needs a passport. It is the first mandatory product passport in EU law.
Micro and small operators are brought into scope for the remaining covered products.
Passports are expected for the first priority groups, such as textiles and clothing, furniture, steel and aluminium, as each delegated act is adopted. Timing is indicative.
Harmonised labels tell consumers how to sort each piece of packaging. The date can move later, depending on when the implementing acts are adopted.
Packaging must be “recycled at scale”: actually collected, sorted and recycled across the EU, not only recyclable in theory.
Grade C packaging is phased out. Only packaging rated A or B for recyclability can be placed on the market.
Minimum recycled content in plastic packaging rises again, to between 25% and 65% depending on the type, as circularity targets tighten.
Dates reflect adopted EU legislation as of September 2026. Some depend on delegated or implementing acts and may move. Read our analysis →
Our Expertise
Circular Notes focuses on four connected areas. We read the primary texts, follow them as they change, and turn them into guidance that product, compliance and sustainability teams can act on.
How we work
Ecodesign for Sustainable Products Regulation
We follow the regulation, its delegated acts and the consultation responses, and translate them into what changes for your products, and when.
Digital Product Passport
What a passport has to contain, who can see which data, and how to structure the information behind it so it holds up.
Supply chains you can prove
Mapping where materials and components come from, and collecting supplier data that can actually be verified.
The wider circular shift
Design for durability, repair and recovery, and environmental claims that stand up to the new consumer rules.
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Arden Hale
Independent writer & researcher
Circular Notes is an independent publication founded by Arden Hale, an independent writer and researcher focused on EU product regulation.
Our mission is simple: to help businesses across the UK, EU, and beyond navigate the complex shift toward circular, compliant, and transparent products.
We are not affiliated with any software vendor. Our analysis is independent, our guides are practical, and our focus is always on helping you take action.