Insights / ESPR (Ecodesign) guide

ESPR for Transformers, Motors and Grid Equipment: The Guide

Regulation (EU) 2024/1781 (ESPR) sets ecodesign requirements through delegated acts, product group by product group. A product group gets new requirements, and a digital product passport, only once its delegated act says so.

Until then, what applies to grid equipment is what applied before: the regulations adopted under the repealed Ecodesign Directive, Regulation (EU) No 548/2014 on power transformers and Regulation (EU) 2019/1781 on motors and drives among them, still bind. The ban on destroying unsold products covers apparel, clothing accessories and footwear, not grid equipment.

What Applies Today

ESPR and Transformers: Does Regulation 548/2014 Still Apply?

The Ecodesign Directive was repealed. Do Regulation (EU) No 548/2014 on transformers and the motor regulation still apply?

Yes. Regulation (EU) 2024/1781 (ESPR) repealed Directive 2009/125/EC from 18 July 2024, but not the regulations adopted under it: Regulation (EU) No 548/2014 on power transformers and Regulation (EU) 2019/1781 on motors and drives still bind until they are repealed or replaced (Article 79(1)(b)). 31 December 2026 is not an end date for them and not a start date for ESPR. ESPR sets requirements for a product only through a delegated act under Article 4.

• Article 79(1): The Directive is repealed, its implementing regulations are not.
• Article 79(2): ESPR Articles 3, 40 and 66 to 71 already apply to those products.
• Article 4(4): A delegated act applies no earlier than 18 months after its entry into force, save in duly justified cases.

Does the ESPR Ban on Destroying Unsold Products Apply to Electrical Equipment?

Does the ESPR ban on destroying unsold products apply to cables, meters, transformers or other electrical equipment?

No. The ban in Article 25(1) of Regulation (EU) 2024/1781 applies from 19 July 2026 only to the consumer products in Annex VII: apparel, clothing accessories and footwear. Components and intermediate products are not consumer products (Article 2(36)), and no grid equipment is in Annex VII. Micro and small enterprises are exempt; medium-sized enterprises are covered from 19 July 2030.

• Article 25(1) and Annex VII: Apparel and clothing accessories (CN 4203, 61, 62, 6504 and 6505) and footwear (CN 6401 to 6405).
• Article 24(1): The yearly disclosure of discarded unsold consumer products has the same company-size rules.

What Comes Next

The ESPR Working Plan: Which Product Groups, and When

Which product groups does the ESPR working plan cover, and in which years?

The Commission's first working plan under Article 18 of Regulation (EU) 2024/1781, COM(2025) 187 of 16 April 2025, gives indicative years for adopting delegated acts: iron and steel 2026, aluminium 2027, textiles and apparel 2027, tyres 2027, furniture 2028, mattresses 2029, repairability (horizontal) 2027, recycled content and recyclability of electrical and electronic equipment (horizontal) 2029, and among the energy-related products carried over, electric motors and variable speed drives 2028 and EV chargers 2028. These are adoption years, not dates the requirements apply; the plan itself imposes nothing.

• Article 18(3): The working plan lists priorities and estimated timelines; it creates no requirement.
• Article 4(4): A delegated act applies no earlier than 18 months after its entry into force, save in duly justified cases.
• Power transformers and PV: The plan sets no new adoption year for them; Regulation (EU) No 548/2014 keeps applying to power transformers.

When is a Digital Product Passport Required Under ESPR?

Do we need a digital product passport for our products from 2026?

Only once a delegated act for your product group requires one. Under Article 9 of Regulation (EU) 2024/1781 a product needs a digital product passport only where the delegated act under Article 4 for that product group says so, and that act sets the data and the data carrier. The registry rules in Implementing Regulation (EU) 2026/1778, in force since 6 August 2026, organise registration; they do not by themselves require a passport.

• Article 9(1) and (2): A passport is required by the applicable delegated act, which sets its content and level (model, batch or item).
• Article 13(1): The Commission had to set up the registry by 19 July 2026.
• Implementing Regulation (EU) 2026/1778: In force on 6 August 2026, the twentieth day after publication (Article 24).
• Working plan COM(2025) 187: Indicative adoption years, for example iron and steel 2026, aluminium 2027, motors and drives 2028.

Last checked against the act text on 2026-10-20. For information only, not legal advice.