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.
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Explore the Ecodesign framework, product-specific requirements, testing, conformity assessment, CE marking and the transition toward the Ecodesign for Sustainable Products Regulation.
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.
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.
Directive 2009/125/EC
Focused on establishing ecodesign requirements for energy-related products through product-specific implementing measures.
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.
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.
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.
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.
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.
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 & 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.
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.
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.
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.
Ecodesign
Establishes mandatory design, energy-performance or environmental requirements that applicable products must satisfy before being placed on the European market.
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.
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.
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.
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.
Define the Product
Establish intended use, functions, energy source, model and technical configuration.
Classify the Product
Determine the applicable European product category.
Map EU Legislation
Identify Ecodesign, ESPR and all other applicable EU requirements.
Identify the Measure
Establish the product-specific implementing regulation or other applicable requirement.
Determine Requirements
Identify efficiency limits, design criteria and information obligations.
Select Standards
Establish applicable measurement, calculation and test methods.
Conduct Testing
Generate representative performance and technical evidence.
Evaluate Results
Compare measured and calculated performance with legal requirements.
Build Technical File
Compile engineering, test, calculation and conformity evidence.
Complete Product Information
Prepare required technical, energy and environmental information.
Declare Conformity
Complete the required declaration covering applicable EU legislation.
CE Mark & Place on Market
Apply required marking after applicable conformity obligations have been fulfilled.
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?