Technical Insight

GAR INSIGHT
Ecodesign Directive 2009/125/EC & ESPR (EU) 2024/1781 — Ecodesign Requirements, Product Sustainability & CE Marking
GAR INSIGHT · ECODESIGN · ENERGY PERFORMANCE · EU MARKET ACCESS

Energy efficiency and environmental performance have become fundamental design considerations for products supplied to the European market. The EU Ecodesign framework has progressively transformed these objectives into legally enforceable product requirements.

Directive 2009/125/EC established the European framework for setting ecodesign requirements for energy-related products and provided the legal basis for numerous product-specific implementing regulations covering equipment ranging from electric motors and pumps to heating, refrigeration, lighting and electronic products.

The Directive did not establish one universal efficiency requirement applying to every product. Instead, detailed requirements were introduced through implementing measures addressing individual product groups, their performance characteristics, measurement methods, information requirements and conformity procedures.

The regulatory framework has now entered a new phase. Regulation (EU) 2024/1781 — the Ecodesign for Sustainable Products Regulation, commonly referred to as the ESPR — establishes a substantially broader framework addressing environmental sustainability beyond traditional energy efficiency.

Existing product-specific ecodesign measures remain highly important during this transition. Manufacturers must therefore understand both the established requirements developed under Directive 2009/125/EC and the developing obligations introduced through the ESPR framework.

This GAR Insight explains how the Ecodesign framework operates, how product-specific requirements are identified, how testing and technical documentation support conformity, how CE marking is connected with ecodesign compliance and how the regulatory system is evolving toward broader product sustainability.

ARTICLE GUIDE

Navigate This Article

Explore the Ecodesign framework, product-specific requirements, testing, conformity assessment, CE marking and the transition toward the Ecodesign for Sustainable Products Regulation.

01
REGULATORY FOUNDATION

Understanding Directive 2009/125/EC

Directive 2009/125/EC established a framework for setting ecodesign requirements for energy-related products supplied within the European Union.

Its central purpose was to improve the environmental performance of products while supporting the functioning of the European internal market through harmonised product requirements.

Framework Directive 2009/125/EC
Traditional Scope Energy-Related Products
Compliance Model Product-Specific Measures
Successor Framework ESPR 2024/1781
Directive 2009/125/EC was a framework Directive rather than a single universal energy-efficiency standard. Detailed requirements were established through product-specific implementing measures covering defined categories of energy-related products.
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02
CURRENT LEGAL POSITION

From the Ecodesign Directive to the ESPR

The European product-sustainability framework changed significantly with the adoption of Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products.

The new legislation is generally known as the Ecodesign for Sustainable Products Regulation — ESPR. It expands the European Ecodesign approach beyond the traditional focus on energy-related products and energy efficiency.

ESTABLISHED FRAMEWORK

Directive 2009/125/EC

Focused on establishing ecodesign requirements for energy-related products through product-specific implementing measures.

NEW FRAMEWORK

Regulation (EU) 2024/1781 — ESPR

Establishes a wider product-sustainability framework capable of addressing durability, repairability, circularity, resource use, environmental footprint, product information and other sustainability characteristics.

Existing Ecodesign implementing measures do not simply disappear because the ESPR has been adopted. Manufacturers must continue to identify the product-specific requirements that remain applicable while monitoring new requirements developed under the ESPR framework.
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03
PRODUCT SCOPE

What Is an Energy-Related Product?

The Ecodesign framework developed under Directive 2009/125/EC covered energy-related products — products that use energy directly or otherwise have an impact on energy consumption during use.

Product scope is established through the relevant implementing measure. A manufacturer should therefore never assume that a product is subject to Ecodesign requirements merely because it uses electricity, gas or another form of energy.

Electric Motors & Drives

Industrial motors and variable-speed drives can be subject to specific minimum energy-performance requirements.

Pumps & Fans

Pumps, circulators and ventilation equipment can fall within product-specific Ecodesign measures.

Heating Equipment

Boilers, space heaters, water heaters and related products may have dedicated Ecodesign requirements.

Cooling & Refrigeration

Refrigeration, air-conditioning and cooling equipment can be subject to energy-performance requirements.

Lighting & Electronics

Lighting products, displays, power supplies and certain electronic equipment are covered by dedicated measures.

Industrial Equipment

Transformers and other energy-related industrial products can also fall within the Ecodesign framework.

Correct product classification comes before testing. Testing against the wrong implementing measure can produce technically valid measurements that provide no useful evidence of legal conformity.
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04
IMPLEMENTING MEASURES

How Product-Specific Ecodesign Requirements Work

The Ecodesign framework establishes the legal architecture, while individual implementing measures define the detailed requirements applicable to particular product groups.

These product-specific measures can establish minimum performance thresholds, measurement methods, information requirements and other technical obligations that must be satisfied before a covered product is placed on the EU market.

Product Definition

The implementing measure defines which products and configurations fall within its scope.

Minimum Requirements

Mandatory efficiency or environmental-performance thresholds can determine whether the product may enter the market.

Measurement Methods

Prescribed calculations, test conditions and measurement procedures establish how performance must be determined.

Information Requirements

Technical literature, manuals, websites or product documentation may need to provide defined performance information.

Ecodesign compliance is product-specific. Requirements applicable to a motor, boiler, refrigerator, display or transformer can differ significantly even though every product sits within the broader Ecodesign framework.
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05
DESIGN & PERFORMANCE

What Can Ecodesign Requirements Address?

Ecodesign requirements can address much more than a single measured energy-efficiency value. Their exact content depends on the relevant product legislation.

Energy Efficiency

Minimum energy-performance thresholds can establish whether a product may be placed on the European market.

Power Consumption

Active, standby, networked standby or off-mode power consumption may be regulated for applicable products.

Functional Performance

Efficiency requirements can be linked to actual product performance so that energy reductions do not undermine intended functionality.

Resource Efficiency

Certain measures increasingly address materials, components, maintenance and resource use.

Repair & Spare Parts

Applicable rules can include requirements concerning repair access, spare-part availability and product servicing.

Product Information

Manufacturers may need to publish prescribed technical, environmental or performance information.

The applicable requirement must be established from the exact product-specific measure. Generic claims such as “energy efficient” or “eco-designed” do not demonstrate legal conformity.
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06
PERFORMANCE VERIFICATION

Testing, Measurement & Technical Evaluation

Reliable Ecodesign conformity depends on performance data generated according to the measurement and calculation methods applicable to the product.

The required assessment can vary considerably according to product type and may involve laboratory testing, engineering calculations, technical evaluation or a combination of these activities.

Energy Consumption

Electrical, fuel or other energy consumption may need to be measured under prescribed operating conditions.

Efficiency

Product efficiency may need to be established at defined operating loads, temperatures or duty conditions.

Standby & Off Mode

Low-power operating states can be subject to dedicated power limits for applicable products.

Seasonal Performance

Heating and cooling products can require calculations reflecting performance across representative seasonal operating conditions.

Functional Testing

Performance measurements may need to confirm that efficiency improvements do not compromise required product function.

Resource Performance

Where applicable, durability, repairability or other resource-related characteristics may also need supporting technical evidence.

Test results are only meaningful when the correct methodology, representative configuration and applicable acceptance criteria have been established. The compliance programme should therefore be defined before laboratory testing begins.
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07
CONFORMITY PROCESS

Ecodesign Conformity Assessment

Before placing a product subject to applicable Ecodesign requirements on the EU market, the manufacturer must establish conformity with the relevant legal and technical requirements.

The precise assessment procedure depends on the applicable legislation, but a structured conformity process normally connects product classification, technical requirements, verification evidence, documentation and production control.

Stage Purpose Key Question
Applicability Determine whether the product is regulated. Which Ecodesign or ESPR requirements apply to this exact product?
Technical Requirements Identify mandatory design and performance criteria. Which limits, calculations and information obligations must be met?
Verification Generate reliable conformity evidence. Which tests, measurements or calculations demonstrate compliance?
Documentation Build the technical evidence package. Can conformity be demonstrated to a market-surveillance authority?
Production Control Maintain conformity in manufactured products. Does ongoing production remain consistent with the assessed design?
Ecodesign conformity is not completed by obtaining a laboratory test report alone. The tested product, technical documentation, declared values, manufactured product and market information must form one coherent compliance chain.
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08
EU MARKET CONFORMITY

Ecodesign & CE Marking

CE marking should be understood as the conclusion of the applicable European conformity process rather than as an independent product approval.

Where the applicable Ecodesign measure requires CE marking, the manufacturer must establish conformity with the relevant requirements before the marking is affixed and the product is placed on the market.

Identify Applicable Legislation

Determine the Ecodesign measure and all other EU legislation applicable to the product.

Evaluate the Product

Complete the required testing, calculations and technical conformity assessments.

Prepare Documentation

Compile the evidence demonstrating that the product satisfies the applicable requirements.

Declare & Mark

Complete the applicable declaration process and affix CE marking only after the required conformity obligations are fulfilled.

CE marking is not an energy-efficiency certificate. It indicates conformity with applicable EU legislation requiring CE marking. Ecodesign may be one element of the total legal framework applying to the product.
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09
COMPLIANCE EVIDENCE

Technical Documentation

Technical documentation provides the evidence connecting the product’s design and performance with the applicable Ecodesign requirements.

The exact contents depend on the relevant implementing measure and other applicable EU legislation, but the documentation should be sufficiently complete to demonstrate how conformity was established.

01
Product identification. Record model designation, product type, configuration and intended use.
02
Applicable legislation. Identify the relevant Ecodesign measure, ESPR provisions where applicable and other applicable EU legislation.
03
Design information. Maintain drawings, specifications, component information and relevant engineering documentation.
04
Performance requirements. Identify mandatory energy, environmental and product-information requirements.
05
Test reports. Maintain reports supporting declared performance and compliance.
06
Calculations. Retain efficiency, seasonal-performance or other required calculations.
07
Standards. Identify applicable harmonised or other technical standards used during evaluation.
08
Product information. Maintain required manuals, technical data, labels and published information.
09
Production controls. Demonstrate that manufactured products remain consistent with the assessed product design.
10
Declaration of Conformity. Identify applicable legislation and conformity information correctly.
Technical documentation should demonstrate conformity — not merely collect unrelated certificates and laboratory reports. Each document should support a defined legal or technical requirement applying to the actual product placed on the market.
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10
COMBINED EU REQUIREMENTS

Ecodesign Rarely Operates Alone

Many energy-related products fall within several European regulatory frameworks simultaneously.

Ecodesign performance should therefore be assessed as one component of a wider product-conformity strategy rather than as an isolated compliance project.

Electrical Safety

Electrical products may need evaluation against applicable Low Voltage requirements.

Electromagnetic Compatibility

Electronic and electrical products can also require EMC assessment.

Machinery

Industrial equipment may also fall under applicable European machinery legislation.

RoHS

Electrical and electronic products may require restricted-substance compliance assessment.

Radio Equipment

Connected products incorporating radio functionality can require additional conformity assessment.

Other Product Rules

Pressure equipment, gas appliances, chemicals and other sector-specific legislation may also apply depending on product design and function.

The correct compliance question is not “Which Directive applies?” but “Which EU legal requirements apply to this product?” A complete regulatory map should be established before testing, certification or technical-file preparation begins.
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11
ENERGY INFORMATION

Ecodesign & Energy Labelling

Ecodesign and Energy Labelling are closely related European policy instruments, but they perform different regulatory functions.

Ecodesign establishes mandatory product requirements, while applicable Energy Labelling rules communicate comparative energy-performance information to purchasers.

MARKET REQUIREMENTS

Ecodesign

Establishes mandatory design, energy-performance or environmental requirements that applicable products must satisfy before being placed on the European market.

MARKET INFORMATION

Energy Labelling

Provides prescribed comparative information enabling consumers and professional buyers to evaluate the energy performance of products within applicable categories.

Product Data

Declared values should correspond with the applicable measurement and calculation methodology.

Energy Label

Where required, the product must display the appropriate label and associated information.

Product Information

Suppliers may need to provide prescribed technical and performance information.

EPREL

Products subject to applicable registration obligations may require entry in the European Product Registry for Energy Labelling.

Ecodesign conformity does not automatically complete Energy Labelling obligations. Where both frameworks apply, the manufacturer or supplier must address each set of requirements correctly.
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12
FUTURE PRODUCT SUSTAINABILITY

ESPR & the Digital Product Passport

Regulation (EU) 2024/1781 significantly expands the Ecodesign concept by creating a framework through which sustainability requirements can be developed for a much broader range of products.

Future product-specific requirements under the ESPR can move beyond traditional energy efficiency and increasingly address the complete sustainability performance of products throughout their lifecycle.

Durability

Product requirements can increasingly consider expected useful life, resistance to deterioration and continued performance.

Repairability

Design and information requirements can support maintenance, disassembly and repair.

Reusability

Products and components can increasingly be evaluated in terms of reuse and extended service life.

Resource Efficiency

Material use, waste generation and efficient resource consumption can become relevant design parameters.

Recycled Content

Product-specific requirements can address the use and documentation of recycled materials.

Environmental Footprint

Product sustainability assessment can increasingly extend beyond energy consumed during the use phase.

Digital Product Passport

One of the most significant elements of the ESPR framework is the Digital Product Passport. For product groups where it becomes applicable, the passport can provide structured access to prescribed product, sustainability, compliance and traceability information.

Product Identification

Digital information can connect the physical product with its relevant regulatory and sustainability data.

Traceability

Supply-chain and product information can be made more accessible throughout the product lifecycle.

Sustainability Information

Applicable environmental characteristics can be communicated through structured digital records.

Compliance Information

Relevant conformity and regulatory information can become more transparent to authorities and market participants.

The ESPR changes Ecodesign from primarily an energy-performance framework into a broader product-sustainability architecture. Manufacturers should increasingly integrate regulatory, engineering, materials, supply-chain and product-data functions when planning future European market access.
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13
COMPLIANCE RISKS

Common Ecodesign Compliance Mistakes

Using Only Directive 2009/125/EC

The manufacturer considers the framework legislation without identifying the applicable product-specific requirements or current ESPR context.

Wrong Product Classification

Testing begins before the exact product category and applicable implementing measure have been established.

Testing to the Wrong Method

Energy performance is measured using a method that does not correspond with the applicable legal requirements.

Incomplete Technical File

Performance values appear in documentation without sufficient supporting calculations, reports or design evidence.

Ignoring Other EU Legislation

Ecodesign is assessed while electrical safety, EMC, RoHS, machinery or other applicable requirements are overlooked.

Confusing Ecodesign & Energy Labels

The two regulatory mechanisms are treated as though satisfying one automatically satisfies the other.

Uncontrolled Product Changes

Components, software, controls or construction are changed without assessing their effect on energy or environmental performance.

Ignoring the ESPR Transition

The manufacturer focuses solely on historical Ecodesign requirements without monitoring emerging sustainability and product-information obligations.

The greatest Ecodesign compliance risk is beginning with a test rather than beginning with the legislation and product classification. A technically correct test cannot compensate for an incorrect regulatory pathway.
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14
COMPLIANCE ROADMAP

From Product Classification to EU Market Access

A structured Ecodesign conformity programme should establish the regulatory pathway before testing, documentation and CE marking activities are undertaken.

01

Define the Product

Establish intended use, functions, energy source, model and technical configuration.

02

Classify the Product

Determine the applicable European product category.

03

Map EU Legislation

Identify Ecodesign, ESPR and all other applicable EU requirements.

04

Identify the Measure

Establish the product-specific implementing regulation or other applicable requirement.

05

Determine Requirements

Identify efficiency limits, design criteria and information obligations.

06

Select Standards

Establish applicable measurement, calculation and test methods.

07

Conduct Testing

Generate representative performance and technical evidence.

08

Evaluate Results

Compare measured and calculated performance with legal requirements.

09

Build Technical File

Compile engineering, test, calculation and conformity evidence.

10

Complete Product Information

Prepare required technical, energy and environmental information.

11

Declare Conformity

Complete the required declaration covering applicable EU legislation.

12

CE Mark & Place on Market

Apply required marking after applicable conformity obligations have been fulfilled.

The practical sequence is legislation → classification → requirements → standards → testing → technical evidence → declaration → market access. Following this sequence reduces the risk of unnecessary testing, incomplete documentation and incorrect CE marking.
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From Energy Efficiency to Sustainable Product Design

Directive 2009/125/EC played a fundamental role in transforming European energy-efficiency policy into product-specific technical requirements. Through the implementing measures developed under its framework, numerous categories of energy-related products became subject to harmonised performance, measurement and product-information requirements.

But Ecodesign compliance has never been a matter of applying one universal efficiency value. Manufacturers must determine the exact product category, identify the applicable implementing measure, establish the required technical characteristics and generate evidence using the prescribed measurement and calculation methods.

This regulatory approach is now evolving further. Regulation (EU) 2024/1781 establishes a significantly broader European framework capable of addressing product durability, repairability, resource efficiency, circularity, environmental performance and digital product information alongside traditional energy considerations.

Manufacturers supplying the European market should therefore manage Ecodesign conformity as an integrated engineering and regulatory process. Product design, testing, calculations, technical documentation, production controls, product information and declarations should all correspond with the actual product placed on the market.

The Performance Question

Has the product’s energy and environmental performance been established using the requirements and methodologies applicable to its exact regulatory category?

The Regulatory Question

Can the manufacturer demonstrate that the product satisfies the complete European conformity framework applicable at the time it is placed on the market?

The defining Ecodesign compliance question is: can the manufacturer demonstrate a continuous technical and regulatory chain from correct product classification and applicable requirements through testing, calculation, controlled production and technical documentation to the exact product ultimately placed on the European market?
Technical note: Directive 2009/125/EC established the European framework for setting ecodesign requirements for energy-related products and formed the legal basis for numerous product-specific implementing measures. Regulation (EU) 2024/1781 — the Ecodesign for Sustainable Products Regulation (ESPR) — establishes the successor framework for sustainable product requirements and provides transitional arrangements relevant to existing Ecodesign measures. Manufacturers should therefore verify the current legal status of the product-specific implementing measure, applicable harmonised standards, test and calculation methods, energy-labelling requirements, other applicable EU product legislation and emerging ESPR obligations before beginning a new conformity or European market-access project. This article provides general technical and regulatory information and does not replace a product-specific conformity assessment.
GLOBAL ALLIANCE REGISTER

How Global Alliance Register Can Support You

Global Alliance Register supports manufacturers, suppliers and responsible economic operators with independent technical-assurance services relevant to Ecodesign for Sustainable Products Regulation (ESPR) within the sustainability and ESG context. Based on the article's emphasis on regulatory review, performance and reliability verification and requirements mapping, GAR can coordinate competent specialists, laboratories, inspectors, auditors and accredited conformity-assessment resources as appropriate to the actual technical need. Within the context of this article, Global Alliance Register can support you in the following areas:

01

Review test records, inspection evidence, calculations, reports and other technical documentation relating to Ecodesign for Sustainable Products Regulation (ESPR) for completeness, consistency and traceability.

02

Map the applicable standards, specifications, acceptance criteria and technical requirements for Ecodesign for Sustainable Products Regulation (ESPR) to the evidence needed to demonstrate compliance, quality or performance.

03

Review the applicable regulatory, technical and scope requirements for Ecodesign for Sustainable Products Regulation (ESPR) and define the responsibilities, classifications and assurance pathway relevant to the product or equipment.

04

Determine the applicable conformity-assessment route for Ecodesign for Sustainable Products Regulation (ESPR), coordinate the required technical evidence and support independent third-party or Notified Body involvement where the governing framework requires it.

05

Review commissioning readiness and coordinate functional, performance and acceptance verification relevant to Ecodesign for Sustainable Products Regulation (ESPR), including defects, retesting and close-out evidence.

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