Circular production is no longer just about recycling waste at the end of the chain. Since the entry into force of the European regulation ESPR in July 2024, the very design of products has become the main area of action. This regulatory shift transforms a model that was long based on voluntary measures into a binding framework that affects nearly all physical goods sold on the European market.
ESPR Regulation and Circular Production: What the European Framework Changes in 2024
The Regulation (EU) 2024/1781 Ecodesign for Sustainable Products Regulation (ESPR), which came into force on July 18, 2024, replaces the old ecodesign directive that only covered energy-related products. Its scope now extends to almost all physical products placed on the European market, with notable exceptions for food and pharmaceuticals.
The logic is simple: instead of managing waste afterward, sustainability, reparability, and recyclability criteria are imposed from the design phase. Obligations will be defined by product families (textiles, electronics, furniture, construction materials) through delegated acts, meaning that the implementation timeline will vary by sector.
For companies, the direct consequence is a complete reassessment of their production chains. A furniture manufacturer, for example, will need to demonstrate that its products meet specific thresholds for recyclability and resource efficiency. This is no longer a voluntary approach valued in communication: it is a condition for market access.
The shift from an incentive-based approach to a binding regulatory framework marks a clear break, and companies already exploring sustainable solutions on Partagez are measuring the extent of the necessary adaptation.
Digital Product Passport: Traceability and Transparency in the Production Chain
The ESPR introduces a tool that could redefine the relationship between producers, distributors, and consumers: the Digital Product Passport (DPP). Each affected good will need to carry a digital identifier providing access to its composition data, material origin, reparability, and end-of-life information.
The stated goal is twofold. On one hand, to allow recyclers and repairers access to reliable information about the materials used. On the other, to offer consumers real transparency about what they are purchasing.
Field feedback on this point varies. Some manufacturers see the DPP as a lever for commercial differentiation, while others point to the complexity of collecting and updating data throughout a product’s life. The question of interoperability between systems from different country suppliers remains open.
What Data Will Be Included in the Digital Passport
- Detailed composition of materials, including the possible presence of critical raw materials or substances of concern
- Repairability score and disassembly instructions to facilitate maintenance and refurbishment
- Percentage of recycled content integrated during manufacturing and recommended recycling pathways at end of life
- Carbon footprint associated with the production and transport of the good
The gradual implementation of these digital passports represents a considerable technical challenge. Each product will carry its own environmental history, transforming how the residual value of a good is assessed.
Circularity Rate in Europe: Where Do We Really Stand
According to Eurostat data, the circular material use rate in the European Union remains low, far below what political rhetoric might suggest. The majority of raw materials consumed in Europe still follow a linear path: extraction, processing, use, landfill, or incineration.
Several factors explain this gap between ambition and reality. The cost of virgin materials often remains lower than that of recycled materials, particularly for plastics. Collection and sorting infrastructures vary significantly from one member country to another. And high-value-added recycling pathways (chemical recycling of polymers, recovery of rare metals in electronics) have not yet reached sufficient industrial scale.
Structural Barriers to Scaling Up
The first barrier is economic. As long as virgin materials benefit from direct or indirect subsidies (favorable taxation for extraction, environmental costs not internalized), recycled material remains disadvantaged in terms of pricing. The second barrier is technical: recycling a mixed cotton-polyester textile or an electronic device containing dozens of different materials requires processes that few players master at scale.
The third barrier is organizational. Circular production requires coordination among actors who historically have had no relationship: the product designer, the waste collector, the recycler, and sometimes the consumer themselves for returning the used good.
Circular Design of Products: The Challenge is Before Manufacturing
Competitors of this article often emphasize recycling as a central pillar of the circular economy. The reality is that the majority of a product’s environmental impact is determined at the design stage. The choice of materials, assembly (glued or screwed), the modularity of components: these upstream decisions determine whether a product can be repaired, refurbished, or recycled at the end of its life.
The ESPR precisely pushes in this direction by imposing design requirements before market launch. For companies, this means training R&D teams on ecodesign principles, integrating circularity criteria into supplier specifications, and rethinking business models (leasing, subscription, take-back) that extend the usage duration.
- Favor mono-component materials or easily separable materials to simplify recycling at end of life
- Design disassemblable assemblies (screws rather than glue, reversible clips) to allow for repair and refurbishment
- Integrate a minimum percentage of recycled material from the specifications, in line with future ESPR requirements by product family
The transition to effective circular production does not solely depend on companies’ willingness. It relies on alignment between regulation, recycling infrastructure, and price signals. The ESPR regulation sets the legal framework. Digital passports will provide the data. The still fragile link remains the real recycling economy, where secondary material must become competitive with virgin material for the loop to truly close.
