Author
Mesbah Sabur
Founder @ Circularise

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This is Part 7 of the series "Get Ready for ESPR: Shaping the Future of Sustainable Business." 

The Ecodesign for Sustainable Products Regulation (ESPR) is going to be transformative, but it comes with its fair share of challenges. Businesses must navigate overlapping reporting requirements, tight deadlines, and the need to modernise outdated systems — all while ensuring that suppliers and stakeholders stay engaged. This article will explore these challenges in detail and provide actionable strategies to help your organisation.

Figure 1: Common challenges companies face with ESPR compliance.

What are the key challenges of ESPR compliance?

1. Overlapping reporting requirements 📊

The ESPR does not operate in isolation. Businesses must also comply with other reporting frameworks, such as the Corporate Sustainability Due Diligence Directive (CS3D) and the Corporate Sustainability Reporting Directive (CSRD). The overlap between these frameworks can create confusion and increase the administrative burden. You can address this by:

  • Identifying the various regulations your company is affected by 
  • Conducting a gap analysis to identify commonalities between the different requirements.
  • Streamlining data collection processes by integrating systems to reduce duplication of effort.
  • Appointing a compliance officer or team to oversee all sustainability reporting requirements and ensure alignment across frameworks.

2. Pressing deadlines ⌛

The ESPR introduces staggered compliance deadlines, with some requirements starting as early as 2025. For businesses operating across global supply chains, these deadlines can feel unmanageable, especially for those who have yet to start preparing. Get started by:

  • Developing a compliance roadmap with clear milestones leading up to key ESPR deadlines.
  • Prioritising high-risk areas, such as digital product passports (DPPs) or waste management systems, to address immediate regulatory needs.
  • Engaging external consultants or legal advisors to ensure your timeline is realistic and actionable.

3. Supplier fatigue 🥱

Suppliers are facing increasing demands to provide data, implement new processes, and meet various compliance standards. "Supplier fatigue" can lead to delays or lapses in cooperation, hindering your compliance efforts. For companies operating across multiple regions, aligning supply chain operations with ESPR can be challenging, particularly when working with non-EU suppliers unfamiliar with the regulation. Address this challenge by:

  • Fostering collaboration by providing suppliers with clear guidance, templates, and tools for compliance.
  • Providing clear guidance and training for non-EU suppliers to ensure they understand the requirements.
  • Building long-term partnerships by offering training and resources to help suppliers understand their role in meeting ESPR requirements.
  • Rotating compliance checks among suppliers to avoid overwhelming them with frequent audits or requests.
  • Using digital product passports (DPPs) to enhance traceability and streamline data sharing across global supply chains.
  • Collaborating with industry peers to set shared standards and expectations for suppliers.

4. Outdated systems and cumbersome processes 💾

Traditional systems, such as email chains or siloed databases, are no longer sufficient for managing the complex data-sharing and traceability requirements of ESPR. In order to not rely on outdated systems and risk falling behind in your compliance efforts, you can: 

  • Invest in modern traceability and data management tools that support interoperability, such as blockchain-based systems or centralised compliance platforms.
  • Automate repetitive tasks, such as data collection and reporting, to reduce errors and improve efficiency.
  • Transition from email-based communication to collaborative platforms that allow for real-time data sharing and updates.

5. Lack of internal alignment 🤝

Achieving ESPR compliance requires input from multiple departments, including design, legal, procurement, and marketing. Misalignment between these teams can lead to delays and inefficiencies. Therefore, it is important to:

  • Establish cross-functional teams dedicated to ESPR compliance, ensuring regular communication and alignment of goals.
  • Use project management tools to track progress and responsibilities across departments.
  • Provide company-wide training to ensure all teams understand the importance of compliance and their specific roles.

6. Financial and resource constraints 💸

Meeting ESPR requirements often involves significant upfront investment in technology, staff training, and operational changes. Here are some ways to manage this challenge:

  • Explore government grants or subsidies aimed at supporting businesses in their sustainability efforts.
  • Phase in compliance measures to spread costs over time.
  • Leverage partnerships with industry groups to share resources and reduce costs.

While the path to sustainability has its challenges, each obstacle presents an opportunity to strengthen your organisation’s sustainability practices. By addressing overlapping reporting frameworks, engaging suppliers, modernising systems, and fostering internal alignment, businesses can not only meet regulatory requirements but also position themselves as leaders in the transition to a circular economy.

This concludes our ESPR 7-part series and email course designed to help you navigate the challenges and opportunities of the Ecodesign for Sustainable Products Regulation (ESPR). We hope these lessons have provided valuable insights into compliance strategies, sustainability practices, and the tools you need to succeed in a circular economy.

📚 Explore the series at your own pace.

Part 1: What you need to know about ESPR 

Part 2: Horizontal rules under 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

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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.

Achieve sustainability and compliance across your supply chain

Need help setting up a traceability system to comply with ESPR? Our team can help you get started today.

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Blog
April 9, 2025
5 minutes

Turning compliance challenges into opportunities with ESPR (Part 7)

Mesbah Sabur
Founder @ Circularise
Ziva Buzeti
Policy Researcher
Tian Daphne
Senior Copywriter

Circularise is the leading software platform that provides end-to-end traceability for complex industrial supply chains

This is Part 7 of the series "Get Ready for ESPR: Shaping the Future of Sustainable Business." 

The Ecodesign for Sustainable Products Regulation (ESPR) is going to be transformative, but it comes with its fair share of challenges. Businesses must navigate overlapping reporting requirements, tight deadlines, and the need to modernise outdated systems — all while ensuring that suppliers and stakeholders stay engaged. This article will explore these challenges in detail and provide actionable strategies to help your organisation.

Figure 1: Common challenges companies face with ESPR compliance.

What are the key challenges of ESPR compliance?

1. Overlapping reporting requirements 📊

The ESPR does not operate in isolation. Businesses must also comply with other reporting frameworks, such as the Corporate Sustainability Due Diligence Directive (CS3D) and the Corporate Sustainability Reporting Directive (CSRD). The overlap between these frameworks can create confusion and increase the administrative burden. You can address this by:

  • Identifying the various regulations your company is affected by 
  • Conducting a gap analysis to identify commonalities between the different requirements.
  • Streamlining data collection processes by integrating systems to reduce duplication of effort.
  • Appointing a compliance officer or team to oversee all sustainability reporting requirements and ensure alignment across frameworks.

2. Pressing deadlines ⌛

The ESPR introduces staggered compliance deadlines, with some requirements starting as early as 2025. For businesses operating across global supply chains, these deadlines can feel unmanageable, especially for those who have yet to start preparing. Get started by:

  • Developing a compliance roadmap with clear milestones leading up to key ESPR deadlines.
  • Prioritising high-risk areas, such as digital product passports (DPPs) or waste management systems, to address immediate regulatory needs.
  • Engaging external consultants or legal advisors to ensure your timeline is realistic and actionable.

3. Supplier fatigue 🥱

Suppliers are facing increasing demands to provide data, implement new processes, and meet various compliance standards. "Supplier fatigue" can lead to delays or lapses in cooperation, hindering your compliance efforts. For companies operating across multiple regions, aligning supply chain operations with ESPR can be challenging, particularly when working with non-EU suppliers unfamiliar with the regulation. Address this challenge by:

  • Fostering collaboration by providing suppliers with clear guidance, templates, and tools for compliance.
  • Providing clear guidance and training for non-EU suppliers to ensure they understand the requirements.
  • Building long-term partnerships by offering training and resources to help suppliers understand their role in meeting ESPR requirements.
  • Rotating compliance checks among suppliers to avoid overwhelming them with frequent audits or requests.
  • Using digital product passports (DPPs) to enhance traceability and streamline data sharing across global supply chains.
  • Collaborating with industry peers to set shared standards and expectations for suppliers.

4. Outdated systems and cumbersome processes 💾

Traditional systems, such as email chains or siloed databases, are no longer sufficient for managing the complex data-sharing and traceability requirements of ESPR. In order to not rely on outdated systems and risk falling behind in your compliance efforts, you can: 

  • Invest in modern traceability and data management tools that support interoperability, such as blockchain-based systems or centralised compliance platforms.
  • Automate repetitive tasks, such as data collection and reporting, to reduce errors and improve efficiency.
  • Transition from email-based communication to collaborative platforms that allow for real-time data sharing and updates.

5. Lack of internal alignment 🤝

Achieving ESPR compliance requires input from multiple departments, including design, legal, procurement, and marketing. Misalignment between these teams can lead to delays and inefficiencies. Therefore, it is important to:

  • Establish cross-functional teams dedicated to ESPR compliance, ensuring regular communication and alignment of goals.
  • Use project management tools to track progress and responsibilities across departments.
  • Provide company-wide training to ensure all teams understand the importance of compliance and their specific roles.

6. Financial and resource constraints 💸

Meeting ESPR requirements often involves significant upfront investment in technology, staff training, and operational changes. Here are some ways to manage this challenge:

  • Explore government grants or subsidies aimed at supporting businesses in their sustainability efforts.
  • Phase in compliance measures to spread costs over time.
  • Leverage partnerships with industry groups to share resources and reduce costs.

While the path to sustainability has its challenges, each obstacle presents an opportunity to strengthen your organisation’s sustainability practices. By addressing overlapping reporting frameworks, engaging suppliers, modernising systems, and fostering internal alignment, businesses can not only meet regulatory requirements but also position themselves as leaders in the transition to a circular economy.

This concludes our ESPR 7-part series and email course designed to help you navigate the challenges and opportunities of the Ecodesign for Sustainable Products Regulation (ESPR). We hope these lessons have provided valuable insights into compliance strategies, sustainability practices, and the tools you need to succeed in a circular economy.

📚 Explore the series at your own pace.

Part 1: What you need to know about ESPR 

Part 2: Horizontal rules under 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

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