Shining a spotlight on ESPR

Examining the expected impact to the footwear industry caused by ESPR legislation.

by Nicola Pichel-Juan

The European Union’s ‘Ecodesign for Sustainable Products Regulation’ (ESPR) will have a significant impact across the footwear industry in the coming years. Unlike some sustainability or Environmental, Social and Governance (ESG) reporting regulations, which mainly affect only the largest organisations, ESPR applies to all products placed on the EU market. It is a wide-ranging regulation that forms part of the EU’s ‘Green Deal’ and ‘Circular Economy Action Plan’. ESPR will require organisations to focus on design-stage impacts and not just supply chain transparency.

What exactly is ESPR?

ESPR replaces the 2009 ‘Ecodesign Directive’, which focused on energy-related products. The increased scope of ESPR covers almost all physical products, including footwear. It is a ‘framework regulation’, which means that delegated acts will follow with specific requirements for different types of products. The regulation covers both performance and information requirements relating to products.

What is the timeline for ESPR?

ESPR entered into force in July 2024 and its implementation is being phased in over a period of time. A working group specifically considering sustainability aspects of footwear has been established, and its work is due to conclude at the end of 2027. It is therefore unlikely that a ‘delegated act’ for footwear (a type of EU legislation that allows the European Commission to supplement or amend specific aspects of existing legislation), as well as clarity on ‘Digital Product Passport’ (DPP) requirements for footwear will be published before then.

Key Ecodesign requirements

Article 5 of ESPR provides a list of product aspects that should be considered in the delegated acts if relevant to that product type. Most of these aspects are likely to be relevant at least to some extent for all footwear supply chains. Table 1 lists the product aspects and indicates at which stage(s) in the product lifecycle it may need to be addressed.

Table 1: Product aspects and applicable stages
Product aspect	Raw materials	Footwear production	Distribution and sales	Use	End of life
a) Durability				X
b) Reliability				X
c) Reusability				X	X
d) Upgradability		X
e) Repairability				X
f) Possibility of maintenance and refurbishment				X
g) The presence of substances of concern	X
h) Energy use and energy efficiency		X
i) Water use and water efficiency		X
j) Resource use and resource efficiency	X	X
k) Recycled content	X
l) The possibility of remanufacturing		X
m) Recyclability					X
n) The possibility of the recovery of materials					X
o) Environmental impacts, including carbon footprint and environmental footprint	X	X	X	X
p) Expected generation of waste		X

Some of these aspects will be more straightforward than others for the footwear industry to work on. For example, there is widespread availability of materials and components that incorporate recycled content (although cost and performance must still be considered). However, very few footwear products are designed with a particular end of life solution in mind, or are easy to dismantle and recycle.

Wider industry impacts

ESPR will further impact the footwear industry through:

• a ban on the destruction of unsold products
• the introduction of DPPs
• a restriction on substances hindering circularity
• mandatory green public procurement criteria.

These will all be discussed in greater detail below.

The first delegated and implementing acts under ESPR were adopted in February 2026 and relate to the destruction of unsold consumer goods, including apparel, clothing accessories, and footwear. Under ESPR, destruction means discarding products as waste. This excludes preparation for reuse such as refurbishment or remanufacturing. It is estimated that currently between 4 and 9 per cent of all textile products on the EU market are destroyed before use.

Large organisations (defined as having more than 250 employees and a EUR 50 million-plus turnover or a EUR 43 million-plus balance sheet) will be legally obliged to disclose information on unsold products destroyed. This includes 1) the volume of unsold products, 2) the type of product, 3) the reason for destruction and 4) measures taken to prevent destruction.

Medium-sized companies will be obliged to report from 2030.

Tables 2 and 3 show examples of what will be classed as ‘unsold stock’, and the legal exceptions (or derogations) where the destruction of unsold stock would be permitted.

Table 2: Examples of types of 'unsold stock'

end-of-season stock overstock unworn returns surplus inventory deadstock

Digital product passports (DPPs) have been discussed in earlier SATRA Bulletin articles (see ‘The use of digital product passports’). A further delegated act will define the exact requirements for footwear DPPs. However, this is unlikely to be published until the working group on footwear sustainability has concluded at the end of 2027.

Table 3: Exceptions where destruction is permitted

health, hygiene and safety reasons damage caused to products as a result of their handling or detected after products have been returned, which cannot be repaired in a cost-effective manner products are not fit for purpose, taking into account EU and national law and technical standards non-acceptance of products offered for donation unsuitability of products for preparing for reuse or for remanufacturing unsaleability of products due to infringement of intellectual property rights, including counterfeit products destruction being the option with the least negative environmental impacts.

This makes it likely that DPPs for footwear will not be required before 2028 or 2029. In order to prepare for DPPs, SATRA recommends that all organisations start work now to gather as much information as possible about their products and their supply chains.

ESPR is also expected to introduce requirements relating to specific substances, as well as elements of product design that may hinder circularity and recycling. This may include substances already restricted in footwear such as PFAS and certain plasticisers. What is perhaps more significant is the potential for restrictions or guidelines relating to how products are designed and the materials that can be used.

Adhesives can contaminate materials and make components difficult to separate. Items such as laminated textiles, coated fabrics and multi-layer outsoles can make footwear harder to recycle. Of course, this does not mean that adhesives and combination materials will be banned, but ESPR will require that greater consideration is given to how products can effectively be dismantled for recycling.

Finally, ESPR will bring in mandatory ‘green’ public procurement. This could mean, for instance, that minimum levels of recycled content are required for products supplied against any public contracts.

In conclusion

While the implementation of ESPR has only just begun through the first delegated acts, the ‘direction of travel’ is clear. ESPR brings a fundamental shift in product regulation and will affect how products are designed and manufactured. While some of the details specific to footwear are not yet available, the key concepts are well documented, and affected organisations should start to prepare for the incoming changes now.

Publishing Data

This article was originally published on page 8 of the July/August 2026 issue of SATRA Bulletin.

Other articles from this issue »

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