EU regulation
Ecodesign Directive: requirements during the ESPR transition
Overview
Short answer
Directive 2009/125/EC has been repealed, but specified provisions and product requirements continue to apply under ESPR’s transitional rules. For an energy-related product, identify the actual implementing measure before changing its documentation or requirements assessment. ESPR Article 79.
Legal status
Transitional rules
Checked 11 October 2026. Repealed since 18 July 2024 with provisions retained under ESPR Article 79.
Part 1
A framework for energy-related products
The Directive established a system for setting ecodesign requirements for products that affect energy consumption. It did not impose one performance threshold on all electronics. Implementing measures established requirements for defined product groups. The link between framework and product measure therefore remains central to the company’s assessment. Articles 1 and 15.
Part 2
Repeal does not remove every product requirement
ESPR repealed the Directive on 18 July 2024. Article 79 nevertheless retains specified provisions for products regulated by implementing measures until those measures are repealed or declared obsolete. It also permits narrowly defined further rulemaking. Read the transitional provision itself rather than relying on a document status label. Article 79.
Part 3
Manufacturers and importers need the same view of the requirements
For a product still governed by such a measure, the manufacturer or authorised representative must assess conformity. The Directive also specifies importer responsibilities where the manufacturer is outside the EU and there is no authorised representative. Check these conditions before assigning responsibilities among purchasing, supplier and product teams. Articles 4 and 8.
Part 4
CE marking and technical evidence
Retained rules cover CE marking, the EC declaration and relevant documentation. The declaration must reference the correct implementing measure. Keep test values, calculations and product information connected to the assessed model version. Simply replacing a Directive reference with ESPR in an existing document does not demonstrate conformity under a new framework. Articles 5 and 8 and Annex IV.
Part 5
Start with the product measure
A practical approach is to list the model, intended use and product group, identify the applicable measure and check its latest amendments. Record the requirement level, measurement method, evidence needed and application date. Assign responsibility for checking whether the measure has been replaced. This is a working recommendation, not a new universal legal document format.
Part 6
Separate retained requirements from new product passports
ESPR does not create a simultaneous passport requirement for all energy-related products. Check what the applicable act actually requires. Keep previous assessments traceable and add the next requirements version when adopted and relevant. Read about the wider framework on the ESPR page. Articles 4, 9 and 79.
Checklist
Key takeaways
- The Directive is repealed with explicit transitional exceptions.
- The implementing measure for the product determines the applicable requirements.
- Existing CE and documentation requirements may continue.
- A new framework does not impose identical new requirements on every product.
Questions and answers
Frequently asked questions
Is the Directive still in force?
It was repealed on 18 July 2024, with specified provisions retained by ESPR Article 79.
Does an existing product regulation disappear automatically?
No. Check its own status and Article 79 transitional rules.
Is a generic ESPR reference sufficient?
No. Identify the measure and requirements version actually applicable to the product.
Does every product need a digital passport now?
No. The applicable act determines the passport requirement, not simply the existence of ESPR.
Further reading
Official sources
How Verca helps
How Verca can support the process
Verca organises product evidence, documents and version history. The company remains responsible for assessment. Explore the platform.