Free tool
ESPR Obligations Checker
ESPR splits your duties into two layers: what applies now from the law and your role, and the product-specific obligations that only bite once your product group has a delegated act in force. Pick your role and your delegated-act status, and see exactly which is which.
Not sure you are even in scope? Start with the scope & timing checker.
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Who does what
ESPR obligations by role
ESPR places duties on economic operators. Your role decides which ones, and your product group’s delegated act decides when the product-specific ones switch on. Here is each role in plain English.
TL;DR
Manufacturer (including non-EU)
You make the product, or have it made under your name, and place it on the EU market.
Carries the fullest set: meet the ecodesign requirements, compile technical documentation, draw up the EU Declaration of Conformity, affix the CE marking, and create and maintain the Digital Product Passport. Non-EU manufacturers selling into the EU carry the same duties.
Importer
You bring a product made outside the EU onto the EU market.
Verifies the manufacturer did the conformity work and provided the documentation, Declaration of Conformity, CE marking and Digital Product Passport, and keeps the evidence. Becomes liable as a manufacturer if it places non-compliant goods or sells under its own name.
Distributor or retailer
You make the product available without making or importing it.
Acts with due care: does not make available products it knows or suspects are non-compliant, checks the basic formal requirements (CE marking, Digital Product Passport present), protects conformity in storage and transport, and cooperates with authorities.
Online marketplace
You run a platform that lets sellers reach EU customers.
Sets up the platform so required information, including the Digital Product Passport, can be displayed; cooperates with authorities and acts on orders to remove non-compliant listings; and provides information about products and traders.
Why the delegated-act status matters most
ESPR is a framework regulation. It sets out the toolbox: the possible requirement types, the Digital Product Passport architecture, the destruction ban and enforcement. But the binding product rules are filled in later by Commission delegated acts, product group by product group. Until your group has a delegated act in force, its product-specific obligations, including the precise Digital Product Passport data fields, do not yet bite. European Commission, ESPR summary
That is why this tool asks two questions, not one. Your role decides the shape of your duties; your delegated-act status decides when most of them become real. Today the only live, dated Digital Product Passport is the Battery Passport, mandatory from 18 February 2027 under the EU Battery Regulation. For textiles, iron and steel, tyres, aluminium, furniture and mattresses, the acts are expected on indicative Working-Plan timing, not yet adopted. European Commission, 2025-2030 Working Plan
One thing is the same across roles and groups from day one: if a product is found non-compliant, market-surveillance authorities can order corrective action, including recall, withdrawal or a sales ban that locks the product out of all 27 member states. Penalties themselves are set by each member state and must be effective, proportionate and dissuasive; ESPR fixes no EU-wide fine. Regulation (EU) 2024/1781
Product-specific duties activate per delegated act
Obligations questions people ask
What are the main ESPR obligations for a manufacturer?
Once your product group’s delegated act applies, a manufacturer must design the product to meet the ecodesign requirements, compile technical documentation, draw up the EU Declaration of Conformity, affix the CE marking, and create and maintain the Digital Product Passport. From the law itself, you must also cooperate with market-surveillance authorities and act on non-compliance. Non-EU manufacturers placing products on the EU market carry the same duties.
Do ESPR obligations apply before the delegated act?
Mostly no. ESPR is a framework regulation. The general role and cooperation duties exist from the law, but the substantive product-specific obligations (the ecodesign requirements, conformity assessment, CE marking and the Digital Product Passport) only bite once your product group has a delegated act in force. Today, the only live, dated Digital Product Passport is the Battery Passport, mandatory from 18 February 2027.
What does an importer have to do under ESPR?
An importer must verify that the manufacturer has done the conformity work, drawn up the documentation and Declaration of Conformity, affixed the CE marking and provided the Digital Product Passport, before placing the product on the EU market. It keeps a copy of the documentation and cooperates with authorities. If it places non-compliant goods, or sells under its own name, it can be treated as a manufacturer with the full duties.
Are online marketplaces covered by ESPR?
Yes. Online marketplaces are drawn into the framework. They must cooperate with market-surveillance authorities, act on orders to remove or restrict non-compliant listings, provide information about products and traders, and design their interface so the legally required product information, including the Digital Product Passport, can reach the consumer. The product-specific display duties firm up with each delegated act.
This is guidance to help you understand ESPR, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.
Sources
- [1]Regulation (EU) 2024/1781 (ESPR), full text on EUR-Lexretrieved 8 Jun 2026
- [2]European Commission, ESPR official summaryretrieved 8 Jun 2026
- [3]European Commission, 2025-2030 ESPR Working Planretrieved 8 Jun 2026