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ErP Energy & Ecodesign 12 min Changing in the next 12 months

ErP: Ecodesign Directive (Directive 2009/125/EC), explained

The Ecodesign Directive is the framework for implementing regulations that set mandatory ecodesign requirements energy-related products must meet before manufacturers, authorised representatives or importers place them on the EU market. It has applied since 20 November 2010; Regulation (EU) 2024/1781 repealed it with effect from 18 July 2024, but its implementing regulations still apply.

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Reviewed 24 September 2026 by Conphora compliance team · Next review 12 March 2027 · Not legal advice

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Who it applies to

Covered by the act

  • Energy-related products: any good that has an impact on energy consumption during use and is placed on the market or put into service in the EU, including parts sold to end users as individual parts whose environmental performance can be assessed independently
  • Only products covered by an implementing measure carry concrete requirements: household appliances, lighting, electronic displays, phones and tablets, external power supplies, electric motors, fans, pumps, heaters and water heaters, ventilation units, servers, welding equipment and the standby and off-mode consumption of household and office equipment, among others
  • Manufacturers, their authorised representatives and, where the manufacturer is outside the EU without a representative, importers; the Danish transposing act and the ESPR add duties for distributors, dealers and fulfilment service providers
  • Products sold online to EU end users, which are placed on the market irrespective of the selling technique
  • From 18 July 2024, the ESPR's own scope of any physical goods, with the Ecodesign Directive's implementing regulations continuing to apply until each is repealed or replaced by an ESPR delegated act

Derived and downstream products

  • The directive is a framework: it sets no limit values itself, and a product without an implementing measure has no ecodesign requirement until one is adopted (Art. 1(2), Art. 3(1) and Art. 15)
  • Implementing measures may require manufacturers of components and sub-assemblies to give the product manufacturer information on material composition and the consumption of energy, materials and resources (Art. 11)
  • Where there is neither a manufacturer nor an importer as defined, any person who places the product on the market or puts it into service is treated as the manufacturer (Art. 2, point 6)
  • Conformity assessment is self-assessment: internal design control (Annex IV) or the management system (Annex V), with a registered EMAS or harmonised-standard management system presumed to comply with Annex V (Art. 8(2))
  • Products bearing the CE marking, made to harmonised standards published in the Official Journal or awarded the EU Ecolabel are presumed to conform to the corresponding requirements (Art. 9)
  • From 19 July 2026 the ESPR prohibits large enterprises (medium-sized from 19 July 2030) from destroying unsold apparel, clothing accessories and footwear, and economic operators that discard unsold consumer products must already disclose the number, weight, reasons, treatment route and prevention measures annually, the first disclosure covering the first full financial year during which the ESPR is in force; Implementing Regulation (EU) 2026/2 adds the binding details and format for products discarded in financial years from the first full financial year after 2 March 2027 (Regulation (EU) 2024/1781, Art. 24(1) and Art. 25(1); Regulation (EU) 2026/2, Art. 1)

Roles under the act

Manufacturer (including brand owners)

The natural or legal person who manufactures products covered by the directive and is responsible for their conformity in view of their being placed on the market or put into service under the manufacturer's own name or trademark or for the manufacturer's own use; where there is no such manufacturer and no importer, any person who places the product on the market or puts it into service is considered the manufacturer.

Source · Art. 2, point 6
Authorised representative

Any natural or legal person established in the EU who has received a written mandate from the manufacturer to perform on the manufacturer's behalf all or part of the obligations and formalities connected with the directive, including affixing the CE marking, issuing the EC declaration of conformity and keeping the conformity documents.

Source · Art. 2, point 7, Art. 5(1) and Art. 8(3)
Importer

Any natural or legal person established in the EU who places a product from a third country on the EU market in the course of business; where the manufacturer is not established in the EU and there is no authorised representative, the importer must ensure the product complies and keep and make available the EC declaration of conformity and the technical documentation.

Source · Art. 2, point 8, and Art. 4
Distributor (wholesaler, retailer or dealer)

Any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a product available on the market; the directive itself imposes no separate distributor duties, but the Danish ecodesignloven binds any economic operator who has made an energy-related product available, and for products under ESPR delegated acts Article 30 of Regulation (EU) 2024/1781 sets the distributor's verification duties, with dealers also bound by Article 31.

Source · Art. 2, points 45 and 55, Art. 30 and Art. 31Source · § 2, nr. 3 og 4, § 7 a og § 11

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Does ErP apply to your product?

Three questions, a first answer from the regulation’s own scope rules. No account needed.

The rules behind this check
  1. Means of transport for persons or goods · any · any Not in scope The directive does not apply to means of transport for persons or goods; the ESPR likewise excludes vehicles under Regulations (EU) No 167/2013, (EU) No 168/2013 and (EU) 2018/858 for the aspects regulated by vehicle legislation. Source · Art. 1(3)Source · Art. 1(2), point (h)
  2. Energy-related product in a group with no implementing regulation yet · any · any Not in scope Only products covered by an implementing measure must comply and bear the CE marking under the directive; a product group without a measure carries no ecodesign requirement until the Commission adopts one, now as an ESPR delegated act that applies no earlier than 18 months after its entry into force, except in justified cases. Source · Art. 1(2), Art. 3(1) and Art. 15(1)Source · Art. 4(4)
  3. Product in a group with an ecodesign implementing regulation (appliances, lighting, displays, phones and tablets, motors, fans, heaters, water heaters, ventilation, external power supplies, servers, welding equipment, standby of household and office equipment) · Manufacturer (including brand owners), Authorised representative, Importer · any In scope Products covered by an implementing measure may be placed on the market or put into service only if they comply with it and bear the CE marking; the manufacturer or authorised representative runs the conformity assessment, issues the EC declaration of conformity and keeps the documents for 10 years, and the importer takes over those duties where the manufacturer is outside the EU without a representative. There is no company-size threshold. Source · Art. 3(1), Art. 4, Art. 5(1) and Art. 8
  4. Product in a group with an ecodesign implementing regulation (appliances, lighting, displays, phones and tablets, motors, fans, heaters, water heaters, ventilation, external power supplies, servers, welding equipment, standby of household and office equipment) · Distributor (wholesaler, retailer or dealer) · any In scope A distributor who has made an energy-related product available on the Danish market must notify the control authority and the responsible operator of a product it believes presents a risk, identify who is responsible for the product on request and comply with orders addressed to anyone in the sales chain; for products under an ESPR delegated act, distributors must verify CE marking, digital product passport and instructions before making the product available. Source · § 7 a, § 10, stk. 4, og § 11Source · Art. 30
  5. Component or sub-assembly built into another product and not sold as a separate part to end users · Manufacturer (including brand owners), Authorised representative · any It depends Components and sub-assemblies that are not sold to end users as individual parts, or whose environmental performance cannot be assessed independently, are not products in their own right; an implementing measure may nevertheless require their manufacturer or authorised representative to give the product manufacturer information on material composition and the consumption of energy, materials and resources. Source · Art. 2, points 1 and 2, and Art. 11
  6. Unsold consumer stock of apparel, clothing accessories or footwear · any · Large In scope From 19 July 2026 the ESPR prohibits the destruction of unsold apparel, clothing accessories and footwear listed in Annex VII, unless a derogation of Delegated Regulation (EU) 2026/296 applies and is documented; discarded unsold consumer products must be disclosed annually under Article 24(1), the first disclosure covering the first full financial year during which the ESPR is in force, with the format of Implementing Regulation (EU) 2026/2 binding for financial years from the first full financial year after 2 March 2027. Source · Art. 24(1), Art. 25(1) and Annex VIISource · Art. 2 and Art. 3Source · Art. 1
  7. Unsold consumer stock of apparel, clothing accessories or footwear · any · Small or medium (SME) It depends The destruction ban and the disclosure duty apply to medium-sized enterprises only from 19 July 2030 and do not apply to micro and small enterprises, but no operator may destroy unsold products supplied to it in order to circumvent the ban. Source · Art. 24(1), Art. 25(1) and Art. 25(2)
  8. Unsold consumer stock of apparel, clothing accessories or footwear · any · Micro Not in scope The destruction ban and the disclosure duty do not apply to micro and small enterprises; they may still not destroy unsold products supplied to them for the purpose of circumventing the ban. Source · Art. 24(1), Art. 25(1) and Art. 25(2)
  9. Non-energy product in an ESPR priority group (textiles and apparel, furniture, mattresses, tyres, iron and steel, aluminium) · any · any It depends Non-energy products fall under the ESPR, not the directive, and carry ecodesign requirements only once a delegated act for their product group applies; the 2025-2030 working plan lists textiles and apparel, furniture, mattresses, tyres, iron and steel and aluminium as the first priorities. Source · Art. 1(2), Art. 3(1), Art. 4(1) and Art. 18(5)Source · section 2
  10. Second-hand product already put into service in the EU · any · any It depends The requirements attach to placing on the market, the first making available in the EU, and to putting into service, the first use by an end user; a product already put into service in the EU is not covered again on resale, and the Danish act excludes units already in use, but a used product imported from a third country is placed on the EU market for the first time. Source · Art. 2, points 4 and 5, and Art. 3(1)Source · § 1, stk. 3
  11. any · any · any It depends Whether ecodesign requirements apply turns on whether the product has an impact on energy consumption during use, whether an implementing regulation or an ESPR delegated act covers its product group, and which role the operator holds in the supply chain. Source · Art. 1, Art. 2 and Art. 15Source · Art. 1 and Art. 79

Key dates

  1. Directive 2009/125/EC adopted by the European Parliament and the Council, recasting Directive 2005/32/EC on energy-using products to cover all energy-related products Source · title, Art. 24 and Annex IX
  2. Entry into force, the twentieth day after publication in OJ L 285 of 31 October 2009 Source · Art. 25
  3. Deadline for Member States to transpose Articles 1 to 9, 11, 14, 15 and 20 and Annexes I to V, VII and VIII and to notify their penalty rules to the Commission Source · Art. 20 and Art. 23(1)
  4. Deadline for the Commission's first ecodesign working plan listing priority product groups for the following three years Source · Art. 16(1)
  5. Directive 2012/27/EU on energy efficiency in force: Article 6(1) now states that free movement is without prejudice to national energy performance and system requirements for buildings under Directive 2010/31/EU Source · Art. 27(3) and Art. 29Source · Art. 6(1) (M1)
  6. First efficiency tier for space heaters, combination heaters, water heaters and hot water storage tanks under Regulations (EU) No 813/2013 and No 814/2013 Source · Art. 1 and Art. 3Source · Art. 1 and Art. 3
  7. Ecodesign and information requirements for residential and non-residential ventilation units apply under Regulation (EU) No 1253/2014 Source · Art. 1, Art. 3 and Art. 4
  8. Ecodesign requirements for servers and online data storage products apply under Regulation (EU) 2019/424 Source · Art. 1 and Art. 3
  9. Regulation (EU) 2019/1782 on external power supplies applies and repeals Regulation (EC) No 278/2009 Source · Art. 1, Art. 9 and Art. 10
  10. Regulation (EU) 2019/1784 on welding equipment applies Source · Art. 1 and Art. 11
  11. The 2019 ecodesign package applies: refrigerating appliances (2019/2019), electronic displays (2019/2021), household dishwashers (2019/2022), household washing machines and washer-dryers (2019/2023) and refrigerating appliances with a direct sales function (2019/2024), with repairability and spare-parts duties Source · Art. 1 and Art. 12Source · Art. 1 and Art. 12Source · Art. 1 and Art. 13Source · Art. 1 and Art. 13Source · Art. 1 and Art. 11
  12. Regulation (EU) 2019/1781 on electric motors and variable speed drives applies and repeals Regulation (EC) No 640/2009 Source · Art. 1, Art. 10 and Art. 11
  13. Regulation (EU) 2019/1020 on market surveillance applies; Directive 2009/125/EC is listed in its Annex I (point 32) and Articles 15 to 29 of Regulation (EC) No 765/2008 are deleted, and Article 4 of Regulation (EU) 2019/1020 starts to apply to the directive's products, so an ecodesign product may be placed on the market only if an economic operator established in the Union is responsible for the tasks of Article 4(3) Source · Art. 39(1), point (4), Art. 44 and Annex I, point 32
  14. Regulation (EU) 2019/2020 on light sources and separate control gears applies and repeals Regulations (EC) No 244/2009, (EC) No 245/2009 and (EU) No 1194/2012 Source · Art. 1, Art. 11 and Art. 12
  15. Regulation (EU) 2024/1781 (ESPR) in force: Directive 2009/125/EC repealed with effect from this date, except the articles and annexes that continue to apply to products covered by its implementing measures until those are repealed or declared obsolete; references to the directive are read as references to the ESPR Source · Art. 79(1), Art. 79(3) and Art. 80
  16. First ESPR and energy labelling working plan 2025-2030 adopted by the Commission (deadline 19 April 2025), prioritising textiles and apparel, furniture, mattresses, tyres, iron and steel, aluminium and the energy-related products carried over from the 2022-2024 plan Source · sections 2.1 and 2.2Source · Art. 18(5)
  17. Regulation (EU) 2023/826 on off mode, standby and networked standby of household and office equipment applies; Regulations (EC) No 1275/2008 and (EC) No 107/2009 repealed Source · Art. 1, Art. 10 and Art. 11
  18. Regulation (EU) 2023/1670 on smartphones, mobile phones, cordless phones and slate tablets applies, as corrected and amended by Regulation (EU) 2025/2006 with the same application date Source · Art. 1 and Art. 12Source · Art. 2
  19. Regulation (EU) 2023/2533 on household tumble dryers and Regulation (EU) 2024/1103 on local space heaters apply; in Denmark the ecodesignproduktloven supplementing the ESPR enters into force Source · Art. 1 and Art. 12Source · Art. 1 and Art. 12Source · § 22
  20. Earliest date on which the first ESPR delegated act setting ecodesign requirements may enter into force; deadline for the first delegated act on derogations from the destruction ban and for the implementing act on disclosure of discarded unsold products Source · Art. 4(7), Art. 24(3) and Art. 25(5)
  21. Sikkerhedsstyrelsen becomes the Markedsovervågning department of Erhvervsstyrelsen with the same tasks, including ecodesign market surveillance Source
  22. ESPR destruction ban applies: large and medium-sized enterprises (medium-sized only from 19 July 2030) may no longer destroy unsold apparel, clothing accessories and footwear listed in Annex VII, subject to the derogations of Delegated Regulation (EU) 2026/296; deadline for the Commission's digital product passport registry Source · Art. 13(1), Art. 25(1) and Annex VIISource · Art. 2 and Art. 6
  23. Regulation (EU) 2024/1834 on fans between 125 W and 500 kW applies, as amended by Regulation (EU) 2025/2481; Regulation (EU) No 327/2011 repealed with transitional application to integrated and spare-part fans Source · Art. 1, Art. 11 and Art. 12Source · Art. 1
  24. Implementing Regulation (EU) 2026/1778 on the digital product passport registry in force (published 17 July 2026) Source · Art. 1 and final article
  25. End of the period in which the Commission may still adopt measures under Article 15 of the directive for photovoltaic panels, heaters, water heaters, air conditioners, boilers, ventilation units, vacuum cleaners, cooking appliances, pumps, industrial fans, circulators, external power supplies, computers, servers, transformers, professional refrigeration and imaging equipment Source · Art. 79(1), point (a)(i)
  26. Implementing Regulation (EU) 2026/2 on the format for disclosing discarded unsold consumer products applies to the first full financial year after that date Source · Art. 1 and Art. 4
  27. Regulation (EU) 2025/2052 on external power supplies, wireless chargers, battery chargers and USB Type-C cables applies and repeals Regulation (EU) 2019/1782 Source · Art. 1, Art. 10 and Art. 11
  28. ESPR destruction ban and annual disclosure of discarded unsold consumer products apply to medium-sized enterprises Source · Art. 24(1) and Art. 25(1)
  29. End of the period in which the Commission may amend existing ecodesign implementing measures under Article 15 of the directive to address technical issues Source · Art. 79(1), point (a)(ii)

What you must do

Obligations by role

Manufacturer (including brand owners)13
  • Identify the implementing regulation that covers your product group and design the product to its specific requirements, staged tiers and information requirements; a product covered by a measure may be placed on the market or put into service only if it complies and bears the CE marking. Art. 3(1), Art. 15(6) and (8) and Annex VII
  • Before placing the product on the market, carry out the conformity assessment yourself using the Annex IV internal design control or the Annex V management system, or another module if the implementing regulation prescribes it; a design function inside an EMAS registration or a harmonised-standard management system is presumed to meet Annex V. Art. 8(1) and Art. 8(2)
  • Compile the technical documentation: a description of the product and its intended use, the environmental assessment studies used, the ecological profile where required, the design specification elements on environmental aspects, the standards applied and the solutions adopted where they were not, a copy of the Annex I Part 2 information, and the measurement results against the ecodesign requirements. Annex IV, point 2, and Annex V, point 3.3.2
  • Draw up the EC declaration of conformity with your name and address, an unambiguous model description, the harmonised and other standards applied, any other CE legislation applied and the signature of the person empowered to bind you, referring to the implementing measure. Art. 5(1), Art. 5(3) and Annex VI
  • Affix the CE marking, at least 5 mm high, to the product or, where that is not possible, to the packaging and accompanying documents, and do not affix markings likely to mislead users about the meaning or form of the CE marking. Art. 5(1), Art. 5(2), Art. 5(4) and Annex III
  • Keep the conformity assessment documents and declarations available for inspection for 10 years after the last unit was manufactured, produce them within 10 days of a request from a national authority, and draw them up in an official EU language; for products placed on the market under the directive before an ESPR delegated act applies, make an electronic version available within 10 days. Art. 8(3) and Art. 8(4)Art. 79(4)
  • Supply the consumer information the implementing measure requires, in the form you consider appropriate, on the role consumers can play in the sustainable use of the product and, where required, the ecological profile and the benefits of ecodesign, in the official language the Member State requires when the product reaches the end user. Art. 5(5), Art. 14 and Annex I, Part 2
  • Ensure the manufacturing process keeps series production in conformity with the design specification and the implementing measure. Annex IV, point 3
  • When a Member State finds a CE-marked product non-compliant, make it comply and end the infringement under the conditions imposed, or face restriction, prohibition or withdrawal of the product from the market. Art. 7(1)
  • In Denmark, notify the control authority immediately if you have reason to believe a product you placed on the market presents a risk. § 7 a
  • In Denmark, mark your name, trade name or trade mark and contact details on the product, its packaging or an accompanying document. § 8, stk. 2
  • Do not design products to alter their behaviour under test, to worsen their performance shortly after being put into service or through software updates beyond the margins the delegated acts allow; these ESPR anti-circumvention rules apply to products covered by the directive's implementing measures since 18 July 2024. Art. 40 and Art. 79(2)
  • When you place components and sub-assemblies on the market, provide the manufacturers of the products that incorporate them with the information on material composition and on energy, material and resource consumption that the implementing measure requires. Art. 11
Authorised representative7
  • Act under a written mandate from the manufacturer covering all or part of the obligations and formalities of the directive; under the ESPR, the mandate may not cover the manufacturer's design and information duties or the drawing up of the technical documentation. Art. 2, point 7Art. 28(1)
  • Where mandated, ensure the conformity assessment is carried out before the product is placed on the market. Art. 8(1)
  • Where mandated, affix the CE marking to the product before it is placed on the market. Art. 5(1)
  • Where mandated, issue the EC declaration of conformity declaring compliance with all relevant provisions of the implementing measure. Art. 5(1)
  • Keep the conformity assessment documents and declarations available for inspection for 10 years after the last unit was manufactured and produce them within 10 days of a request from the national authority. Art. 8(3)
  • When a Member State finds a CE-marked product non-compliant, bring it into conformity and end the infringement under the conditions imposed, and recall non-compliant products from the market when the market surveillance authority orders it. Art. 3(2), point (a), and Art. 7(1)
  • Where required, the Danish manufacturer must give you the necessary powers and means to perform the task, and you must cooperate with the control authority and provide the information it requests in a language it easily understands. § 8, stk. 3, og § 10, stk. 3Art. 28(2)
Importer12
  • Where the manufacturer is not established in the EU and has appointed no authorised representative, ensure that the product you place on the market or put into service complies with the directive and the applicable implementing measure. Art. 4, point (a)
  • In that case, keep and make available the EC declaration of conformity and the technical documentation; in Denmark the importer then carries the manufacturer's responsibility for conformity under section 4 of ecodesignloven and must keep the documentation for at least 10 years after the last unit was manufactured and produce it within 10 days. Art. 4, point (b)§ 4, stk. 2, og § 8, stk. 1
  • Check before placing the product on the market that it bears the CE marking, that the EC declaration of conformity refers to the implementing measure and that the required consumer information accompanies the product in the language the Member State requires. Art. 3(1), Art. 5(1), Art. 5(3) and Art. 5(5)
  • As the economic operator established in the Union responsible under Article 4 of Regulation (EU) 2019/1020, verify that the EC declaration of conformity and the technical documentation have been drawn up, and keep the declaration at the disposal of the market surveillance authorities. Art. 4(3)(a)
  • Provide the market surveillance authorities with the information and documentation they request on a reasoned request, and cooperate with them on any corrective action. Art. 4(3)(b) and (d)
  • Inform the market surveillance authority immediately if you have reason to believe a product you placed on the market presents a risk; in Denmark notify the control authority. Art. 4(3)(c)§ 7 a
  • Indicate your name, registered trade name or registered trade mark and contact details including a postal address on the product, its packaging, the parcel or an accompanying document; in Denmark the same duty follows from section 8(2) of ecodesignloven. Art. 4(4)§ 8, stk. 2
  • Provide the market surveillance authority on request with all information needed for its checks, including technical documents, conformity data, access to embedded software, supply-chain details, quantities placed on the market and product models with the same technical characteristics, and give access to your premises for sampling. § 10, stk. 3, og § 10 bArt. 3(2), points (b) and (c)
  • For products covered by an ESPR delegated act, place only compliant products on the market, and first verify that the manufacturer has run the conformity assessment and drawn up the technical documentation and that the digital product passport and digital instructions are available. Art. 29(1) and Art. 29(2)
  • For products covered by an ESPR delegated act, indicate your name, registered trade name or trade mark and contact details on the product, its packaging or an accompanying document and in the public part of the digital product passport. Art. 29(3)
  • For products covered by an ESPR delegated act, take corrective action, withdraw or recall a non-conforming product you placed on the market, and immediately inform the market surveillance authorities of the Member States where you made it available. Art. 29(6)
  • For products covered by an ESPR delegated act, keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities for 10 years. Art. 29(7)
Distributor (wholesaler, retailer or dealer)8
  • Do not make available a product covered by an implementing measure unless it complies with that measure and bears the CE marking; orders to bring the product into conformity, stop misleading marketing, withdraw, recall or destroy it can be addressed to anyone who has been part of the sales chain. Art. 3(1)§ 11, stk. 1
  • If you have reason to believe an energy-related product you made available presents a risk, immediately notify the control authority and the responsible manufacturer or importer, cooperate with the authority and give details of the non-conformity and the measures taken. § 7 a
  • On request, provide all information needed to determine who is responsible for the product, including documents, technical specifications, conformity information, supply-chain and distribution details and quantities on the market, and allow the control authority access to your business premises and transport to take samples. § 10, stk. 4, og § 10 b
  • For products covered by an ESPR delegated act, verify before making them available that they bear the CE or alternative conformity marking, carry the required label or digital product passport, come with the required documents and digital instructions in the language of the Member State, and carry the identification and contact details of the manufacturer and importer. Art. 30(2)
  • For products covered by an ESPR delegated act, hold back a non-conforming product until it conforms, and for one you already made available ensure corrective action, withdrawal or recall and inform the market surveillance authorities. Art. 30(3) and Art. 30(4)
  • As a dealer, give customers access to the information accompanying the product and to the digital product passport, including in distance selling, display the required labels and do not display marks or inscriptions likely to mislead about them; in distance selling the offer must name the manufacturer, the EU responsible operator and identify the product. Art. 31 and Art. 36(1)
  • If you sell a product covered by an ESPR delegated act under your own name or trade mark, or modify it in a way that affects compliance, you take on the manufacturer's obligations. Art. 34
  • Keep records of your suppliers and customers of products covered by an ESPR delegated act for 10 years and provide them within 15 days of a request. Art. 36(2)

ErP in plain terms

Directive 2009/125/EC, the Ecodesign Directive or “ErP”, is the framework under which the EU sets mandatory design requirements for energy-related products. It sets no numbers itself: Article 15 empowers the Commission to adopt product-specific implementing measures for product groups that sell more than about 200 000 units a year, have a significant environmental impact and offer significant improvement potential, and those regulations carry the concrete requirements: minimum energy efficiency, standby and off-mode limits, resource efficiency, durability, repairability, spare-parts availability and information duties (Art. 15(2), Art. 15(6) and (8), Annexes I, II and VII).

A product covered by an implementing measure may be placed on the market or put into service only if it complies with the measure and bears the CE marking (Art. 3(1)). Conformity is self-assessed by the manufacturer under Annex IV or Annex V, documented in a technical file and declared in an EC declaration of conformity (Art. 5 and Art. 8). Products without an implementing measure carry no ecodesign requirement.

The directive entered into force on 20 November 2009, replacing Directive 2005/32/EC, and Member States had to apply it from 20 November 2010 (Art. 23 to 25). Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR), repealed it with effect from 18 July 2024, but its implementing regulations and the articles those regulations rest on continue to apply to the products they cover until each measure is repealed or replaced (ESPR Art. 79).

Scope

The directive applies to energy-related products: any good that has an impact on energy consumption during use and is placed on the market or put into service, including parts sold separately to end users whose environmental performance can be assessed independently (Art. 2, point 1). Means of transport for persons or goods are excluded (Art. 1(3)), and the directive is without prejudice to EU waste and chemicals legislation (Art. 1(4)).

The obligations fall on the manufacturer, meaning whoever manufactures the product and markets it under its own name or trade mark, its authorised representative established in the EU, and, where the manufacturer is outside the EU without a representative, the importer (Art. 2, points 6 to 8, and Art. 4). Components and sub-assemblies not sold separately are not products in their own right, but an implementing measure may require their manufacturer to supply information on material composition and consumption of energy, materials and resources to the product manufacturer (Art. 2, point 2, and Art. 11). The Danish transposing act, ecodesignloven, additionally binds distributors and other economic operators in the supply chain (§ 2, § 7 a, § 10 and § 11).

The implementing regulations that businesses apply today include refrigerating appliances (2019/2019), light sources (2019/2020), electronic displays (2019/2021), household dishwashers (2019/2022), washing machines and washer-dryers (2019/2023), refrigerating appliances with a direct sales function (2019/2024), electric motors and variable speed drives (2019/1781), external power supplies (2019/1782, replaced by 2025/2052 from 14 December 2028), welding equipment (2019/1784), servers and data storage products (2019/424), space heaters and combination heaters (813/2013), water heaters (814/2013), ventilation units (1253/2014), standby and off mode of household and office equipment (2023/826), smartphones and tablets (2023/1670), household tumble dryers (2023/2533), local space heaters (2024/1103) and fans (2024/1834). Each regulation defines its own scope and exclusions in Article 1 and its tiers in the annexes.

What you must do

Find the measure and design to it. Identify the implementing regulation covering your product group, read its Article 1 scope and exclusions and design the product to the specific requirements, tiers and information requirements it lays down (Art. 3(1), Art. 15(6) and Annex VII). Test and calculate with the measurement standards and methods the regulation prescribes; a product made to harmonised standards published in the Official Journal, or awarded the EU Ecolabel, is presumed to conform to the requirements those standards or criteria cover (Art. 9(2) and Art. 9(3)).

Assess conformity yourself. Before placing the product on the market, the manufacturer or its authorised representative ensures a conformity assessment is carried out, choosing between the Annex IV internal design control and the Annex V management system unless the measure prescribes another module; a design function inside an EMAS registration or a harmonised-standard management system is presumed to meet Annex V (Art. 8(1) and Art. 8(2)). No notified body is involved.

Compile the technical documentation. Annex IV, point 2, lists what the file must contain: a description of the product and its intended use, the environmental assessment studies used, the ecological profile where required, the design specification elements on environmental aspects, the standards applied and the solutions adopted where they were not, a copy of the Annex I Part 2 information and the measurement results against the ecodesign requirements. Series production must stay in conformity with the design specification (Annex IV, point 3).

Declare and mark. Draw up the EC declaration of conformity with the Annex VI elements, the name and address of the manufacturer or authorised representative, an unambiguous model description, the standards applied, other CE legislation applied and the signature of the person empowered to bind the manufacturer, referring to the implementing measure, and affix the CE marking of at least 5 mm to the product or, where not possible, to the packaging and accompanying documents (Art. 5(1) to (3), Annex III and Annex VI). Markings likely to mislead about the CE marking are prohibited (Art. 5(4)).

Inform users. Supply the consumer information the measure requires on the role consumers can play in the sustainable use of the product and, where required, the ecological profile and the benefits of ecodesign; Member States may require the Annex I Part 2 information in their official language when the product reaches the end user (Art. 5(5) and Art. 14). These duties sit alongside the separate energy labelling rules of Regulation (EU) 2017/1369.

Keep the file for 10 years. After placing the product on the market, keep the conformity assessment documents and declarations available for inspection for 10 years after the last unit was manufactured and produce them within 10 days of a request, in an official EU language (Art. 8(3) and Art. 8(4)). For products placed on the market under the directive before an ESPR delegated act covers them, the ESPR requires an electronic version within 10 days for the same period (ESPR Art. 79(4)).

Importers. Where the manufacturer is outside the EU and has no authorised representative, the importer must ensure the product complies with the directive and the applicable measure and keep and make available the EC declaration of conformity and the technical documentation (Art. 4); in Denmark the importer then carries the responsibility for conformity under § 4, stk. 2, of ecodesignloven.

Danish additions. Article 4 of Regulation (EU) 2019/1020 already requires an economic operator established in the Union to be responsible for the product and to be named on it; in Denmark the same rule is written into ecodesignloven: the responsible operator marks its name, trade name or trade mark and contact details on the product, packaging or an accompanying document (§ 8, stk. 2), any operator who has made the product available must immediately notify the control authority and the responsible operator of a product it believes presents a risk (§ 7 a), and operators must provide information on request and give the authority access to premises for sampling (§ 10 and § 10 b).

Products under ESPR delegated acts. Once a delegated act under Article 4 of the ESPR covers a product group, the full ESPR obligations apply: performance and information requirements, a digital product passport as a condition for placing on the market, digital instructions, identification and contact details, a complaints channel, corrective action and 10-year documentation for manufacturers (ESPR Art. 27), a limited mandate for authorised representatives (Art. 28), verification duties for importers and distributors (Art. 29 and Art. 30), label and passport access duties for dealers (Art. 31), storage duties for fulfilment service providers (Art. 33), and the manufacturer’s duties for anyone selling under its own brand or modifying the product (Art. 34). The anti-circumvention rules of ESPR Art. 40, which prohibit products designed to alter their behaviour under test or to worsen their performance through software updates, already apply to products covered by the directive’s implementing measures (Art. 79(2)).

The transition to the ESPR

The ESPR entered into force on 18 July 2024 and repealed Directive 2009/125/EC with effect from the same date, with three transitional strands (ESPR Art. 79 and Art. 80). First, Articles 1 and 2, Article 8(2), Articles 11, 14, 15, 18 and 19 and Annexes I, II, IV, V and VII of the directive continue to apply so that the Commission can adopt measures under the Article 15 procedure for photovoltaic panels, heaters, water heaters, air conditioners, boilers, ventilation units, vacuum cleaners, cooking appliances, pumps, industrial fans, circulators, external power supplies, computers, servers, transformers, professional refrigeration and imaging equipment until 31 December 2026, and technical amendments to existing measures until 31 December 2030. Second, Article 1(3), Article 2, Article 3(1), Articles 4, 5 and 8, Article 9(3), Articles 10, 14 and 20 and Annexes IV, V and VI continue to apply to products regulated by existing implementing measures until those measures are repealed or declared obsolete, in place of the corresponding ESPR articles. Third, the ESPR’s free-movement, anti-circumvention, market surveillance and safeguard articles (Art. 3, Art. 40 and Art. 66 to 71) apply to those products already.

The ESPR extends ecodesign to any physical goods, excluding food, feed, medicinal products, living organisms and vehicles for the aspects regulated by vehicle legislation (Art. 1(2)), and lets delegated acts set requirements on durability, reliability, reusability, upgradability, repairability, substances of concern, energy, water and resource efficiency, recycled content, remanufacturing, recyclability and environmental and carbon footprints (Art. 5(1)). A delegated act applies no earlier than 18 months after its entry into force except in justified cases, and the first could not enter into force before 19 July 2025 (Art. 4(4) and Art. 4(7)). The digital product passport becomes a condition for placing covered products on the market (Art. 9), with a Commission registry set up by 19 July 2026 and its implementation arrangements in Implementing Regulation (EU) 2026/1778.

The first working plan, COM(2025) 187 of 16 April 2025, prioritises textiles and apparel, furniture, mattresses, tyres, iron and steel and aluminium and carries over 16 energy-related product groups from the 2022-2024 plan for new or revised requirements, with indicative adoption dates from 2026 to 2030 and a mid-term review in 2028. Separately, from 19 July 2026 large enterprises may no longer destroy unsold apparel, clothing accessories and footwear listed in Annex VII, medium-sized enterprises follow from 19 July 2030 and micro and small enterprises are exempt (Art. 25); Delegated Regulation (EU) 2026/296 lists the documented derogations, and Implementing Regulation (EU) 2026/2 sets the format for the annual disclosure of discarded unsold products under Article 24.

Enforcement and penalties

Member States designate the market surveillance authorities, which organise compliance checks, oblige the manufacturer or authorised representative to recall non-compliant products, require information and take samples for testing (Art. 3(2)). Since 16 July 2021 the powers come from Regulation (EU) 2019/1020, in whose Annex I the directive is listed, and since 18 July 2024 the ESPR’s own market surveillance chapter applies to products covered by the implementing measures, including, for products covered by an ESPR delegated act, the right to recover the cost of document inspection and physical product testing from the responsible economic operator (ESPR Art. 66(3) and Art. 79(2)). Under the safeguard clause a Member State that finds a CE-marked product non-compliant obliges the manufacturer or authorised representative to make it comply and end the infringement, may prohibit placing on the market until compliance is established, and where non-compliance continues restricts or prohibits placing on the market or withdraws the product, informing the Commission and the other Member States (Art. 7). Penalties are national and must be effective, proportionate and dissuasive, taking into account the extent of non-compliance and the number of non-compliant units placed on the market (Art. 20).

In Denmark, Sikkerhedsstyrelsen, since January 2026 the Markedsovervågning department of Erhvervsstyrelsen, has carried out market surveillance of ecodesign and energy labelling for Energistyrelsen since 1 August 2018, checking websites, shops and documentation and testing samples, while Energistyrelsen keeps responsibility for the rules and for the EPREL database. The legal basis is ecodesignloven (lovbekendtgørelse nr. 2166 of 29 November 2021, as amended by lov nr. 431 of 6 May 2025): the control authority can order the product to be brought into conformity, require warnings, stop misleading marketing, prohibit placing on the market or making available, order withdrawal, recall or safe destruction (§ 11), have online content changed or removed (§ 11 b) and impose fines under § 15, with corporate liability. For the ESPR, the ecodesignproduktloven (lov nr. 431 of 6 May 2025, in force 1 July 2025) names Sikkerhedsstyrelsen as control authority, with prohibitions and orders under § 11 and § 12 and fines under § 21. Violations can lead to orders, prohibitions or a police report, and findings may be shared with other Danish and foreign authorities.

How Conphora helps

Conphora keeps the Ecodesign Directive, its implementing regulations and the ESPR delegated acts under watch and matches your products against the measures that actually apply, flagging gaps in efficiency, standby, repairability, spare parts, technical documentation, the declaration of conformity and CE marking before they become enforcement problems. The platform helps you build and keep the right documentation and alerts you when a product group moves from an ErP-era regulation to an ESPR delegated act, when a digital product passport becomes mandatory and when the destruction ban or disclosure duty reaches your company size.

See how Conphora works · See plans and pricing

Sources

This guide is for general information and is not legal advice.

Penalties

Enforced by National market surveillance authorities designated under Article 3(2) enforce the national laws transposing the directive and the implementing regulations with the powers of Regulation (EU) 2019/1020, in whose Annex I the directive is listed, and which in Article 4(5) also lists the directive, so since 16 July 2021 a manufacturer, importer, authorised representative or fulfilment service provider established in the Union must be identifiable as the responsible economic operator, and since 18 July 2024 the market surveillance and safeguard articles of the ESPR also apply to products covered by the implementing regulations; in Denmark, Sikkerhedsstyrelsen, since January 2026 the Markedsovervågning department of Erhvervsstyrelsen, has carried out ecodesign market surveillance for Energistyrelsen since 1 August 2018 under the act on ecodesign of energy-related products (ecodesignloven), the legal chain being section 10(1) of that act, under which the minister for industry, business and financial affairs or a body it empowers carries out the control, after the royal decree of 22 June 2018 moved responsibility for ecodesign market surveillance from the climate and energy minister to the minister for industry (executive order nr. 861 of 24 June 2018 on the distribution of business between ministers), while lov nr. 431 of 6 May 2025 names Sikkerhedsstyrelsen directly in the new section 14(2) of ecodesignloven, and Energistyrelsen keeps responsibility for the rules, and for the ESPR under the ecodesignproduktloven in force since 1 July 2025. The toolkit is orders to bring the product into conformity, to end the infringement and to provide information and samples, prohibition or restriction of placing on the market, withdrawal and recall, orders to correct or remove online content, and national penalties that must be effective, proportionate and dissuasive, taking into account the extent of non-compliance and the number of non-compliant units placed on the market, in Denmark fines under section 15 of ecodesignloven and section 21 of ecodesignproduktloven.

Member States lay down the penalties for infringing their national transposing provisions; they must be effective, proportionate and dissuasive, taking into account the extent of non-compliance and the number of non-compliant units placed on the market, and had to be notified to the Commission by 20 November 2010. Under the safeguard clause a Member State that finds a CE-marked product non-compliant obliges the manufacturer or authorised representative to make it comply and end the infringement, may prohibit placing on the market until compliance is established where there is sufficient evidence of non-compliance, and where non-compliance continues restricts or prohibits placing on the market or putting into service or withdraws the product, informing the Commission and the other Member States. Since 18 July 2024 the ESPR safeguard procedure also applies to products covered by the directive's implementing measures: corrective action within a period commensurate with the risk, otherwise prohibition, restriction, withdrawal or recall, and orders to end formal non-compliance such as a missing or wrongly affixed CE marking, a missing or incorrect EU declaration of conformity, incomplete technical documentation or missing identification details, with the authorities entitled to recover the cost of document inspection and physical product testing from the responsible economic operator where a product is found not to comply with a delegated act adopted under Article 4 of the ESPR, which for now means products whose group has already moved from an ErP implementing regulation to an ESPR delegated act. In Denmark, Sikkerhedsstyrelsen, since January 2026 the Markedsovervågning department of Erhvervsstyrelsen, can order the product to be brought into conformity, require warnings, stop misleading marketing, prohibit placing on the market or making available, order withdrawal, recall or safe destruction and order online content to be changed or removed, and infringements are punished by fines under section 15 of ecodesignloven (lovbekendtgørelse nr. 2166 of 29 November 2021, as amended by lov nr. 431 of 6 May 2025) and, for the ESPR, section 21 of ecodesignproduktloven (lov nr. 431 of 6 May 2025), with corporate criminal liability for companies.

Source · Art. 7(1) and Art. 20Source · Art. 66(3), Art. 69, Art. 71 and Art. 79(1)(b) and (2) (Article 20 of the directive applies instead of Article 74 of the ESPR to products regulated by the directive's implementing measures)Source · § 11, § 11 b og § 15Source · § 6, § 11, § 12 og § 21Source

What changed

Entry into force, amendments and Compliance Radar entries for ErP, newest first.

  1. Applies

    ESPR destruction ban and disclosure duty reach medium-sized enterprises

    From this date medium-sized enterprises may no longer destroy unsold apparel, clothing accessories and footwear listed in Annex VII and must disclose discarded unsold consumer products annually; micro and small enterprises stay outside both duties.

    Source · Art. 24(1) and Art. 25(1)
  2. Applies

    Regulation (EU) 2025/2052 replaces the external power supply regulation

    The regulation of 13 October 2025 on external power supplies, wireless chargers, wireless charging pads, battery chargers for portable batteries and USB Type-C cables applies from this date and repeals Regulation (EU) 2019/1782, with point 3 of its Article 9 applying from 14 December 2025.

    Source · Art. 1, Art. 10 and Art. 11
  3. Applies

    Disclosure format for discarded unsold consumer products applies

    Implementing Regulation (EU) 2026/2 of 9 February 2026 applies to products discarded in each financial year from the first full financial year after this date; economic operators disclose the information in the Annex I format within 12 months after the end of that year, or inside their sustainability reporting.

    Source · Art. 1, Art. 2 and Art. 4
  4. Applies

    End of the window for new implementing measures under Article 15 of the directive

    After this date the Commission can no longer adopt measures under the directive's Article 15 procedure for photovoltaic panels, heaters, water heaters, air conditioners, boilers, ventilation units, vacuum cleaners, cooking appliances, pumps, industrial fans, circulators, external power supplies, computers, servers, transformers, professional refrigeration and imaging equipment; technical amendments to existing measures remain possible until 31 December 2030.

    Source · Art. 79(1), point (a)
  5. Guidance

    Guide rebuilt on the SPEC-62 model from the consolidated text

    The body was rewritten from the consolidated text of 4 December 2012, the ESPR and the implementing regulations named in the sources. Corrections to the previous version: the ESPR repeal of 18 July 2024 is now described with its Article 79 exceptions and end dates; Denmark's enforcement is corrected from Energistyrelsen as competent authority to Sikkerhedsstyrelsen, now the Markedsovervågning department of Erhvervsstyrelsen, carrying out the surveillance for Energistyrelsen since 1 August 2018 under ecodesignloven, with the ecodesignproduktloven of 1 July 2025 for the ESPR; the 10-year document retention and 10-day production deadline of Article 8(3) are stated with their source.

    Source · Art. 8(3)Source · Art. 79Source
  6. Amendment

    Implementing Regulation (EU) 2026/1778 on the digital product passport registry in force

    Adopted on 16 July 2026 and published on 17 July 2026, it lays down the implementation arrangements for the registry established under Article 13 of the ESPR, including access management and the verification of economic operators, for products covered by ESPR delegated acts and by the battery, construction product, toy and detergent regulations.

    Source · Art. 1 and final article
  7. Applies

    Regulation (EU) 2024/1834 on fans applies

    The regulation of 3 July 2024 on fans with an electric input power between 125 W and 500 kW, including fans integrated into other products, applies from this date as amended by Regulation (EU) 2025/2481; Regulation (EU) No 327/2011 is repealed, with its Annexes I to III continuing to apply until 24 July 2027 to integrated fans and until 24 July 2037 to spare-part fans.

    Source · Art. 1, Art. 11 and Art. 12Source · Art. 1
  8. Applies

    Destruction ban on unsold apparel and footwear applies; digital product passport registry due

    Large enterprises may no longer destroy unsold consumer products listed in Annex VII (apparel, clothing accessories, headgear and footwear), subject to the documented derogations of Delegated Regulation (EU) 2026/296 for dangerous, non-compliant, counterfeit, damaged or unrepairable products and for products refused as donations; the Commission had to set up the digital product passport registry by the same date.

    Source · Art. 13(1), Art. 25(1) and Annex VIISource · Art. 2, Art. 3 and Art. 6
  9. Amendment

    Delegated Regulation (EU) 2026/296 on derogations from the destruction ban in force

    Adopted on 9 February 2026 and published on 22 April 2026, the delegated regulation lists the circumstances in which unsold Annex VII products may still be destroyed and the documentation to keep for five years; it applies from 19 July 2026.

    Source · Art. 2, Art. 3 and Art. 6
  10. Amendment

    Implementing Regulation (EU) 2026/2 on the disclosure format in force

    Adopted on 9 February 2026 and published on 10 February 2026, it establishes the details and format for disclosing information on discarded unsold consumer products under Article 24 of the ESPR and applies from 2 March 2027.

    Source · Art. 1 and Art. 4
  11. Applies

    Tumble dryers and local space heaters regulations apply; Danish ecodesignproduktloven in force

    Regulation (EU) 2023/2533 on household tumble dryers, repealing Regulation (EU) No 932/2012, and Regulation (EU) 2024/1103 on local space heaters and separate related controls, repealing Regulation (EU) 2015/1188, apply from this date; in Denmark lov nr. 431 of 6 May 2025 supplements the ESPR and the market surveillance regulation and names Sikkerhedsstyrelsen as control authority.

    Source · Art. 1, Art. 11 and Art. 12Source · Art. 1, Art. 11 and Art. 12Source · § 6 og § 22
  12. Applies

    Ecodesign requirements for smartphones and tablets apply

    Regulation (EU) 2023/1670 of 16 June 2023 on smartphones, mobile phones other than smartphones, cordless phones and slate tablets applies from this date; Regulation (EU) 2025/2006 of 18 December 2025 corrects and amends it with the same application date for legal certainty.

    Source · Art. 1 and Art. 12Source · Art. 1 and Art. 2
  13. Applies

    New standby and off-mode regulation applies

    Regulation (EU) 2023/826 of 17 April 2023 on off mode, standby mode and networked standby energy consumption of electrical and electronic household and office equipment applies from this date and repeals Regulations (EC) No 1275/2008 and (EC) No 107/2009; Regulation (EU) 2025/2262 later clarified its definitions and measurement conditions.

    Source · Art. 1, Art. 10 and Art. 11Source · Art. 1
  14. Guidance

    First ESPR and energy labelling working plan 2025-2030 adopted

    The Commission's communication COM(2025) 187 sets the product priorities up to 2030, with a mid-term review in 2028: textiles and apparel, furniture, mattresses, tyres, iron and steel and aluminium as new product groups, and 16 energy-related product groups carried over from the 2022-2024 plan for new or revised requirements.

    Source · sections 2.1 and 2.2Source · Art. 18(3) and Art. 18(5)
  15. Amendment

    ESPR in force: Directive 2009/125/EC repealed with transitional provisions

    Regulation (EU) 2024/1781 of 13 June 2024, published on 28 June 2024, enters into force and repeals the directive with effect from this date, keeping its core articles and Annexes IV to VI alive for products regulated by existing implementing measures until those are repealed or declared obsolete, allowing new Article 15 measures for listed product groups until 31 December 2026 and technical amendments until 31 December 2030, and applying its own free-movement, anti-circumvention and market surveillance articles to those products; the Ecodesign Forum is set up by Decision (EU) 2024/2779 of 24 October 2024.

    Source · Art. 79 and Art. 80Source
  16. Applies

    Light sources regulation applies

    Regulation (EU) 2019/2020 on light sources and separate control gears applies from this date and repeals Regulations (EC) No 244/2009, (EC) No 245/2009 and (EU) No 1194/2012; Regulation (EU) 2021/341 of 23 February 2021 had amended it and the other 2019 regulations before application.

    Source · Art. 1, Art. 11 and Art. 12Source · Art. 9
  17. Amendment

    Regulation (EU) 2019/1020 becomes the market surveillance basis

    The market surveillance regulation applies from this date; Directive 2009/125/EC is listed in its Annex I and Articles 15 to 29 of Regulation (EC) No 765/2008 are deleted, so references to those articles are read as references to Regulation (EU) 2019/1020. Denmark aligned ecodesignloven's control powers by lov nr. 1176 of 8 June 2021.

    Source · Art. 39, Art. 44 and Annex I, point 32Source · fodnote 10 og § 5 i lov nr. 1176 af 8. juni 2021
  18. Applies

    The 2019 ecodesign package applies to appliances and displays

    Regulations (EU) 2019/2019, 2019/2021, 2019/2022, 2019/2023 and 2019/2024 apply from this date to refrigerating appliances, electronic displays, household dishwashers, household washing machines and washer-dryers and refrigerating appliances with a direct sales function, repealing the earlier measures for those groups; electric motors follow on 1 July 2021 under Regulation (EU) 2019/1781.

    Source · Art. 12Source · Art. 12Source · Art. 13Source · Art. 13Source · Art. 11Source · Art. 11
  19. Amendment

    Directive 2012/27/EU in force: buildings carve-out added to Article 6(1)

    The energy efficiency directive of 25 October 2012, published in OJ L 315 on 14 November 2012, adds a sentence to Article 6(1) so that free movement of compliant products is without prejudice to national energy performance and system requirements for buildings under Directive 2010/31/EU, and inserts recital 35a.

    Source · Art. 27(3) and Art. 29
  20. Applies

    Transposition deadline; penalty rules notified

    Member States had to bring into force the laws transposing Articles 1 to 9, 11, 14, 15 and 20 and Annexes I to V, VII and VIII by this date and to notify their penalty provisions to the Commission.

    Source · Art. 20 and Art. 23(1)
  21. In force

    Directive 2009/125/EC enters into force

    Adopted on 21 October 2009 and published in OJ L 285 on 31 October 2009, the recast directive entered into force on the twentieth day after publication and repealed Directive 2005/32/EC on energy-using products, extending the framework to all energy-related products.

    Source · Art. 24 and Art. 25

Tools and training

What Conphora offers for ErP.

Start from the problem

Our product needs an energy label and EPREL registration

Energy labelling under Regulation (EU) 2017/1369: the delegated act for your product group, EPREL before the first unit, labels, sheets and ads.

Regulation guides → Product validation

We import power adapters and chargers

What an importer of mains adapters and chargers checks under the Low Voltage, EMC and RoHS Directives and the ecodesign rules for external power supplies.

Product validation → Documentation generator

We sell LED lamps or luminaires

The rules for LED lamps and luminaires: ecodesign Regulation (EU) 2019/2020, the A to G energy label, EPREL registration, electrical safety and EMC.

Regulation guides → Product validation

Our product falls under an ecodesign regulation

What an ecodesign implementing regulation requires now that Regulation (EU) 2024/1781 repealed the Ecodesign Directive: conformity, CE marking, documents.

Regulation guides → Product validation → Compliance Radar

We advertise durability or repairability

Lifetime and repair claims are banned when false since 27 September 2026, and repair duties apply to some products. What to check before you say it lasts.

GreenWashing scanner → Knowledge & insights

Questions people ask about ErP

Is the Ecodesign Directive still in force?

Regulation (EU) 2024/1781, the ESPR, repealed Directive 2009/125/EC with effect from 18 July 2024, but with wide exceptions. The definitions, the placing-on-the-market rule, the importer, marking, conformity assessment, ecolabel presumption, standards, consumer information and penalty articles and Annexes IV, V and VI continue to apply to products regulated by the directive's implementing measures until those measures are repealed or declared obsolete, and the Commission may keep adopting measures under the directive for the listed energy-related product groups until 31 December 2026 and technical amendments until 31 December 2030. In practice the implementing regulations, and therefore the ErP rules, still govern most energy-related product groups today.

Source · Art. 79(1) and Art. 80
Which products does ErP apply to?

Any good that has an impact on energy consumption during use and is placed on the market or put into service, including parts sold separately to end users whose environmental performance can be assessed independently; means of transport for persons or goods are excluded. Concrete requirements exist only for product groups with an implementing regulation, such as refrigerating appliances, washing machines and washer-dryers, dishwashers, tumble dryers, light sources, electronic displays, smartphones and tablets, external power supplies, electric motors, fans, space and water heaters, local space heaters, ventilation units, servers, welding equipment and the standby and off-mode consumption of household and office equipment.

Source · Art. 1(3), Art. 2, point 1, and Art. 15Source · Art. 1Source · Art. 1Source · Art. 1
Do I need a notified body for ecodesign?

Normally not. The implementing measures leave the manufacturer the choice between the Annex IV internal design control and the Annex V management system for assessing conformity, both self-assessment routes; only where duly justified and proportionate to the risk may a measure prescribe another module from Decision No 768/2008/EC. A design function covered by an EMAS registration, or a management system implemented to harmonised standards published in the Official Journal, is presumed to meet Annex V.

Source · Art. 8(2), Annex IV and Annex V
How long must I keep the technical documentation and how fast must I produce it?

The manufacturer or its authorised representative keeps the conformity assessment documents and the declarations of conformity available for inspection for 10 years after the last unit of the product was manufactured, and must make them available within 10 days of a request from a Member State authority, in an official EU language. For products placed on the market under the directive before an ESPR delegated act covers them, the ESPR requires an electronic version to be available within 10 days for the same 10-year period.

Source · Art. 8(3) and Art. 8(4)Source · Art. 79(4)
What happens to a product that fails an ecodesign check?

The manufacturer or authorised representative must make the product comply and end the infringement under the conditions the Member State imposes; with sufficient evidence of non-compliance the authority may prohibit placing on the market until compliance is established, and where non-compliance continues it restricts or prohibits placing on the market or putting into service or withdraws the product and informs the Commission and the other Member States. In Denmark, Sikkerhedsstyrelsen issues orders to correct, warn, stop marketing, withdraw, recall or destroy the product, can have online content removed, and infringements are fined under section 15 of ecodesignloven.

Source · Art. 7 and Art. 20Source · § 11, § 11 b og § 15
Who enforces ecodesign in Denmark, Energistyrelsen or Sikkerhedsstyrelsen?

Both have a role. Since 1 August 2018 Sikkerhedsstyrelsen has carried out market surveillance of ecodesign and energy labelling of energy-related products for Energistyrelsen: it checks websites, shops and documentation, takes and tests samples and issues the decisions, and violations can lead to orders, prohibitions or a police report. Energistyrelsen keeps overall responsibility for developing and interpreting the rules and for the EPREL database. The legal chain is section 10(1) of ecodesignloven, under which the minister for industry, business and financial affairs or a body it empowers carries out the control after the royal decree of 22 June 2018 moved ecodesign market surveillance to that minister, and lov nr. 431 of 6 May 2025 names Sikkerhedsstyrelsen directly in the new section 14(2) of the act. Since January 2026 Sikkerhedsstyrelsen is the Markedsovervågning department of Erhvervsstyrelsen with the same tasks, and for the ESPR the ecodesignproduktloven in force since 1 July 2025 names Sikkerhedsstyrelsen directly as the control authority.

SourceSourceSourceSource · § 10, stk. 1, og note 3Source · § 6 og § 23, nr. 1
What does the ESPR change for my products?

The ESPR covers any physical goods, not only energy-related products, and lets the Commission set performance and information requirements on durability, reliability, reusability, upgradability, repairability, substances of concern, energy, water and resource efficiency, recycled content, remanufacturing, recyclability and environmental and carbon footprints through delegated acts, each applying no earlier than 18 months after its entry into force except in justified cases. It introduces the digital product passport as a condition for placing covered products on the market, with a Commission registry set up by 19 July 2026 under Implementing Regulation (EU) 2026/1778, a ban on destroying unsold apparel and footwear from 19 July 2026, and full obligations for manufacturers, authorised representatives, importers, distributors, dealers, fulfilment service providers and online marketplaces. Until a delegated act replaces an existing implementing regulation, your product keeps following the ErP-era rules.

Source · Art. 1, Art. 4(4), Art. 5(1), Art. 9, Art. 13(1), Art. 25(1), Art. 27 to 35 and Art. 79Source · Art. 1
Which product groups come first under the ESPR working plan?

The first ESPR and energy labelling working plan, adopted on 16 April 2025 for 2025 to 2030 with a mid-term review in 2028, prioritises the final products textiles and apparel, furniture, mattresses and tyres, the intermediate products iron and steel and aluminium, and carries over 16 energy-related product groups from the 2022-2024 plan, including low-temperature emitters, displays, EV chargers, dishwashers, washing machines and washer-dryers, professional laundry and dishwashing appliances, electric motors, refrigerating appliances, light sources, welding equipment, mobile phones and tablets, local space heaters, tumble dryers and standby consumption, with indicative adoption dates from 2026 to 2030.

Source · sections 2.1 and 2.2Source · Art. 18(5)

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Sources

  1. Directive 2009/125/EC on ecodesign requirements for energy-related products, consolidated text of 4 December 2012 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009L0125-20121204
  2. Directive 2009/125/EC as published in OJ L 285, 31 October 2009 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0125
  3. Document information, dates and relationships for CELEX 32009L0125 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009L0125
  4. Directive 2012/27/EU on energy efficiency, amending Directive 2009/125/EC (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012L0027
  5. Regulation (EU) 2024/1781 on ecodesign requirements for sustainable products (ESPR), repealing Directive 2009/125/EC (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1781
  6. Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020
  7. Communication COM(2025) 187: Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187
  8. Commission Delegated Regulation (EU) 2026/296 on derogations from the prohibition of destruction of unsold consumer products (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R0296
  9. Commission Implementing Regulation (EU) 2026/2 on the format for disclosing information on discarded unsold consumer products (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R0002
  10. Commission Implementing Regulation (EU) 2026/1778 on the digital product passport registry (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R1778
  11. Commission Decision (EU) 2024/2779 setting up the Ecodesign Forum (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024D2779
  12. Commission Regulation (EU) 2019/2019 on refrigerating appliances (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2019
  13. Commission Regulation (EU) 2019/2020 on light sources and separate control gears (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2020
  14. Commission Regulation (EU) 2019/2021 on electronic displays (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2021
  15. Commission Regulation (EU) 2019/2022 on household dishwashers (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2022
  16. Commission Regulation (EU) 2019/2023 on household washing machines and washer-dryers (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2023
  17. Commission Regulation (EU) 2019/2024 on refrigerating appliances with a direct sales function (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2024
  18. Commission Regulation (EU) 2019/1781 on electric motors and variable speed drives (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1781
  19. Commission Regulation (EU) 2019/1782 on external power supplies (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1782
  20. Commission Regulation (EU) 2019/1784 on welding equipment (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1784
  21. Commission Regulation (EU) 2019/424 on servers and data storage products (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R0424
  22. Commission Regulation (EU) 2021/341 amending the 2019 ecodesign regulations (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R0341
  23. Commission Regulation (EU) No 813/2013 on space heaters and combination heaters (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R0813
  24. Commission Regulation (EU) No 814/2013 on water heaters and hot water storage tanks (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R0814
  25. Commission Regulation (EU) No 1253/2014 on ventilation units (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R1253
  26. Commission Regulation (EU) 2023/826 on off mode, standby mode and networked standby (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R0826
  27. Commission Regulation (EU) 2023/1670 on smartphones, mobile phones, cordless phones and slate tablets (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1670
  28. Commission Regulation (EU) 2025/2006 correcting and amending Regulation (EU) 2023/1670 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2006
  29. Commission Regulation (EU) 2023/2533 on household tumble dryers (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R2533
  30. Commission Regulation (EU) 2025/2262 amending Regulations (EU) 2023/826 and (EU) 2023/2533 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2262
  31. Commission Regulation (EU) 2024/1103 on local space heaters (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1103
  32. Commission Regulation (EU) 2024/1834 on fans driven by motors between 125 W and 500 kW (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1834
  33. Commission Regulation (EU) 2025/2481 amending Regulation (EU) 2024/1834 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2481
  34. Commission Regulation (EU) 2025/2052 on external power supplies, wireless chargers, battery chargers and USB Type-C cables (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2052
  35. Ecodesign for Sustainable Products Regulation (European Commission, DG Environment) https://environment.ec.europa.eu/strategy/circular-economy/ecodesign-sustainable-products-regulation_en
  36. Kontrol og tilsyn: Ecodesign og energimærkning (Sikkerhedsstyrelsen) https://www.sik.dk/erhverv/produkter/eco-design-og-energimaerkning/kontrol-og-tilsyn-ecodesign-og-energimaerkning
  37. 1. juli 2019 fører Sikkerhedsstyrelsen tilsyn med energimærkning og ecodesign (Sikkerhedsstyrelsen) https://www.sik.dk/nyheder/1-juli-2019-foerer-sikkerhedsstyrelsen-tilsyn-energimaerkning-og-ecodesign
  38. Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Sikkerhedsstyrelsen) https://www.sik.dk/sikkerhedsstyrelsen-del-erhvervsstyrelsen
  39. Lovbekendtgørelse nr. 2166 af 29. november 2021 om miljøvenligt design af energirelaterede produkter, ecodesignloven, som ændret ved lov nr. 431 af 6. maj 2025 (Retsinformation) https://www.retsinformation.dk/eli/lta/2021/2166
  40. Lov nr. 431 af 6. maj 2025 om supplerende bestemmelser til ecodesignforordningen og markedsovervågningsforordningen, ecodesignproduktloven (Retsinformation) https://www.retsinformation.dk/eli/lta/2025/431
  41. Bekendtgørelse nr. 244 af 3. februar 2026 om Energistyrelsens opgaver og beføjelser (Retsinformation) https://www.retsinformation.dk/eli/lta/2026/244

About this guide

Reviewed by
Conphora compliance team, Compliance editors, Conphora
Reviewed
24 September 2026
Next review
12 March 2027

Written from the official text on EUR-Lex and the Commission’s guidance, with a source for every fact. It is not legal advice.

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Conphora (2026). ErP: Ecodesign Directive (Directive 2009/125/EC), explained. Retrieved 13 October 2026 from https://www.conphora.com/regulations/erp/
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