Ecodesign (ESPR): a step towards lead markets for low-carbon steel

Publish date: May 2, 2024

The EU takes a leap towards stronger product sustainability with the adoption of the Ecodesign for Sustainable Products Regulation (ESPR) on April 23rd by the European Parliament. But what exactly does this mean for consumers and the environment?  

Stricter sustainability requirements 

This new regulation, which enables the introduction of environmental sustainability requirements for most products sold in the EU, builds on the Ecodesign Directive, which so far only included energy-related products. The regulation’s goal is to improve EU products circularity, energy performance, and other environmental sustainability aspects. The regulation sets a highly positive precedent, by aiming to make all products sustainable by default and giving the European Commission the right to implement stricter sustainability requirements across various product categories. The most polluting products are given priority, i.e. intermediate products such as iron, steel and aluminium, lubricants, and chemicals; and products, such as textiles, detergents, electronics, among others.  

Bellona welcomes that the regulation identifies iron and steel as one of the key product groups, and that it sets clear performance requirements and product parameters, also including carbon and material footprint (ESPR, 2024). In addition to enhancing product sustainability across the EU, the ESPR requires producers to integrate ecological considerations from design to disposal and disclose mandatory product information (e.g. the number and weight of unsold consumer products discarded annually; the reasons for discarding the products; the proportion of the delivery of discarded products, whether directly or through a third party; measures taken and measures aimed at preventing the destruction of unsold consumer products). The regulation also has great potential for the future, as it sets a clear path towards closing the materials loop, with opportunities for continuous improvement (ECOS, 2024).  

What about enforcement? 

The main point of concern is the ambiguity related to consequences for non-compliance with the new rules, and the lack of clarity on how the enforcement of the regulation is guaranteed in spaces where the rules of the physical marketplace do not apply (e.g. online spaces). This absence of enforcement is a precarious precedent to set, since it can greatly hinder the positive impacts of the regulation, as it does not give the Member States clear incentives on why they should be motivated to follow the new rules, nor are there clear penalties set in place for nonconformity (ECOS, 2024). 

Zooming in on building materials 

All in all, it is positive to see the emphasis on materials such as steel, as it addresses the pressing need for regulations targeting carbon-intensive products. The requirements this regulation sets forth are crucial for establishing lead markets, which in turn plays a great role in the uptake of sustainable construction materials. In terms of cement, the ESPR does not cover it a priori, but it acts as a backstop in case the Construction Product Regulation (CPR) does not deliver on cement decarbonisation by 2029, by requiring a Delegated Act covering cement in that year (ESPR, 2024). 

Next steps – a delegated act that tackles steel emissions 

As an intermediate product, steel is included in the first working plan of delegated acts, and will be prioritised together with aluminium, iron, textiles, etc. For the delegated act, the Commission will adopt a working plan which covers at least 3 years, and which includes the product aspects for which it intends to adopt delegated acts of horizontal application. Bellona participated in the preparatory study on iron and steel, to ensure the good quality of future discussions on the EU policies on steel with scientific basis.  


  1. ECOS. 2024. Position paper: Ecodesign for Sustainable Products Regulation (ESPR). ECOS. Accessed 29th of April 2024. Accessible via: 
  1. European Commission. 2024. Provisional Agreement resulting from Interinstitutional Negotiations: Ecodesign for Sustainable Products Regulation. Accessed 29th of April 2024. Accessible via: Item12-Ecodesign_provisionalagreement_20220095COD_EN.pdf (  

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