This is Part 2 of the series "Get Ready for ESPR: Shaping the Future of Sustainable Business."
The horizontal rules in the ESPR set the foundation for product sustainability, aiming to improve the durability, reparability, and recyclability of products while reducing their overall environmental impact. Applicable across different product categories, these rules create a uniform standard that ensures products meet sustainability requirements at various stages of their lifecycle.
What are the ESPR horizontal rules?
Here are the key horizontal rules that must be considered under the ESPR:
1. Durability
Products must be designed to last longer, reducing the need for frequent replacements and contributing to a reduction in waste. Durable products are essential for supporting circular economy practices by ensuring that products are used for longer periods, reducing the overall consumption of resources.
2. Reliability
Reliability ensures that products perform as expected over time, reducing the frequency of product failures and minimising waste associated with defective or non-functioning products.
3. Reusability
Designing products for reuse is critical to promoting circularity. Reusable products can be easily repaired, refurbished, or repurposed, reducing the demand for new raw materials and minimising waste.
4. Upgradability
Products should be designed in a way that allows for easy upgrades. This is particularly relevant for electronics and technology, where products can be improved with newer software or hardware, extending their useful life and reducing the need for complete replacements.
5. Repairability
Repairability is a key factor in reducing waste and increasing product lifespan. Products should be designed to allow easy repair, with accessible spare parts, repair manuals, and modular components. The JRC report suggests that repairability standards should be harmonised to make it easier for consumers and businesses to repair products, reducing waste and improving sustainability.
6. Recyclability
Products should be designed with materials that are easily recyclable, ensuring that when the product reaches the end of its life, its components can be effectively recovered and reused. This includes the use of recyclable materials and design strategies that facilitate disassembly.
7. Post-consumer recycled content
Incorporating post-consumer recycled content into products helps reduce the demand for virgin materials, conserving natural resources and supporting the recycling industry. The JRC report highlights the importance of promoting the use of recycled materials as part of the EU’s broader sustainability goals.
8. Possibility of maintenance and refurbishment
Products should be designed to allow for maintenance and refurbishment, enabling them to be restored to their original function. This helps extend the product's life and reduces the environmental impact associated with the disposal and production of new products.
9. Energy use and efficiency
Energy use is a critical factor in product design. Products must be designed to minimise energy consumption during their lifecycle, including production, use, and disposal phases. Energy-efficient products contribute to reducing carbon emissions and lowering the environmental footprint of the product.
10. Water use and efficiency
Reducing water use in product manufacturing and use phases is vital for ensuring the sustainability of resources. Products should be designed to minimise water consumption and maximise water efficiency throughout their lifecycle.
11. Resource use and efficiency
Efficient use of resources involves designing products that minimise the extraction and consumption of raw materials. Products should be designed to use fewer resources while maintaining their functionality and quality, reducing waste and conserving natural resources.
12. Possibility of remanufacturing
Products should be designed in a way that allows them to be remanufactured, extending their lifecycle and contributing to the circular economy. This involves creating products that can be disassembled, cleaned, and reassembled to restore them to a functional state.
13. Possibility of recovery of materials
Designing products for material recovery ensures that valuable materials can be extracted and reused at the end of a product’s life. This reduces the need for new raw materials and supports a more sustainable approach to resource management.
14. Environmental impacts, including carbon and environmental footprints
A product’s environmental impact, including its carbon footprint, should be minimised. The design process should focus on reducing emissions and the overall environmental footprint of the product throughout its lifecycle.
15. Expected generation of waste
Products should be designed to minimise the generation of waste during production, use, and disposal. Reducing waste at all stages of the product lifecycle is essential for a circular economy.
16. Monitored presence of substances of concern
The presence of hazardous substances, such as toxic chemicals or materials that hinder recycling, must be monitored and controlled. Products should be free from substances that can negatively impact health, the environment, or recycling processes.
How to comply with horizontal rules under ESPR
To effectively implement the horizontal rules under the Ecodesign for Sustainable Products Regulation (ESPR), follow these instructions to ensure your products meet the required sustainability standards and contribute to the EU’s circular economy goals.

1. Harmonise standards for repairability and recyclability
To facilitate easier compliance, ensure that your products meet standardised criteria for repairability and recyclability. Develop consistent product design specifications that support easy repairs, access to spare parts, and simple disassembly for recycling. Align these standards across your product lines to ensure uniformity in your sustainability practices.
2. Implement clear data labelling on products to communicate essential sustainability information
Ensure that your products feature clear and easy-to-understand labels that communicate essential sustainability information. This includes data on the product's repairability, energy efficiency, recyclability, and environmental footprint. Clear labelling will help consumers and businesses make informed decisions based on sustainability features and contribute to better compliance with ESPR.
3. Adopt circular economy metrics to track the environmental impact of your product
Develop and implement standardised metrics to assess and report on key circular economy aspects, such as resource efficiency, material recovery, and carbon footprint. These metrics will help you track the environmental impact of your products, report progress on sustainability goals, and ensure compliance with the ESPR’s resource use and recycling requirements.
4. Encourage innovation in sustainability and introduce circular business models
Drive innovation in your product design by focusing on areas like product modularity, energy efficiency, and the use of sustainable materials. Look for opportunities to exceed the minimum ESPR requirements and introduce circular business models that reduce waste, improve energy efficiency, and use renewable resources. Offering incentives for innovation can help your company stay ahead of regulatory changes and lead the way in sustainability.
In Part 3, we’ll dive into the details of the regulations on discarding and destruction of products under ESPR.
📚 Explore the series at your own pace.
Part 1: What you need to know about ESPR
Part 3: Sustainable discarding and destruction of products under ESPR
Part 4: ESPR enhances traceability and transparency with digital product passports
Part 5: Specific ESPR requirements for manufacturers, importers, distributors, and retailers
Part 6: Why stakeholder collaboration matters for ESPR compliance
Part 7: Turning compliance challenges into opportunities with ESPR
Circularise is the leading software platform that provides end-to-end traceability for complex industrial supply chains. We offer two traceability solutions: MassBalancer to automate mass balance bookkeeping and Digital Product Passports for end-to-end batch traceability.
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