Ecodesign: Directive 2009/125/EC and the ESPR, Regulation (EU) 2024/1781

Ecodesign rules set minimum environmental and energy-efficiency requirements that a product must meet before it can be placed on the market. In the EU the framework has been Directive 2009/125/EC for energy-related products. It is being replaced by the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, which entered into force on 18 July 2024.

For ecodesign compliance and CE marking of your product, apply to CE Danışmanı (CE Consultant); we manage the whole process for you.

What ecodesign means

Ecodesign looks at the whole life cycle of a product: the raw materials, the manufacturing, the use phase and the end of life. The aim is to reduce the environmental impact at every stage through decisions taken at the design stage. The parameters considered include:

• Choice and use of raw materials
• Consumption of energy and water
• Expected generation of waste
• Emissions to air, water and soil
• Packaging, distribution and transport
• Ease of disassembly, reuse and recycling

Directive 2009/125/EC

The Directive is a framework. It applies to energy-related products: products that use, generate, transfer or measure energy, and products that affect energy consumption without using energy themselves, such as insulation materials. The Directive itself does not contain limit values. The binding requirements are in implementing measures, each covering one product group.

Product groups with implementing measures

• Standby and off mode power consumption of household and office equipment
• External power supplies
• Lighting products
• Electric motors
• Circulators
• Televisions and electronic displays
• Household refrigerating appliances
• Household washing machines
• Household dishwashers
• Simple set-top boxes

The list is longer and the measures are revised regularly, so the measure in force for a product has to be checked at the time of the assessment.

How conformity is shown

1. Identify the implementing measure that covers the product and the tier of requirements in force.
2. Measure and calculate the parameters the measure sets, such as efficiency, standby power or information requirements.
3. Carry out the conformity assessment. The manufacturer uses internal design control or a management system; the applicable measure states which.
4. Draw up the technical documentation and the EU Declaration of Conformity. See technical file.
5. Affix the CE marking.

Ecodesign is one of the pieces of legislation behind a single CE marking. An electrical appliance is typically assessed under the Low Voltage Directive, the EMC Directive, RoHS and the ecodesign measure for its product group, and all of them are listed on the same Declaration of Conformity.

The ESPR: Regulation (EU) 2024/1781

The ESPR replaces the Directive as the framework. Its main changes:

• Wider scope. It is no longer limited to energy-related products. It can cover almost all physical goods, with a small number of exceptions such as food, feed and medicinal products.
• More kinds of requirement. Beyond energy efficiency, requirements can address durability, reparability, recycled content and the presence of substances of concern.
• Digital Product Passport. Products covered by a delegated act will carry a digital record of information about their sustainability.
• Same working method. The Regulation is again a framework; product-specific requirements are set in delegated acts, group by group.

The implementing measures adopted under Directive 2009/125/EC continue to apply until they are replaced under the new Regulation. For a manufacturer this means that the existing measure for the product group is still the one to comply with today, while the delegated acts under the ESPR need to be followed as they are adopted.

Ecodesign and energy labelling

Ecodesign and energy labelling work together. Ecodesign removes the least efficient products from the market by setting minimum requirements. The energy label shows consumers how the remaining products compare. Many product groups, including refrigerating appliances, dishwashers, washing machines, tumble dryers, air conditioners, ovens, light sources and electronic displays, are subject to both. See the Energy Labelling Regulation.

Ecodesign in Turkey

Turkey transposed Directive 2009/125/EC through a framework regulation on the environmentally sensitive design of energy-related products, applied since the end of 2010, and through product-specific communiqués that mirror the EU implementing measures. Products placed on the Turkish market are assessed against these communiqués, and imported products are checked through TAREKS.

How CE Danışmanı helps

• Identifying the ecodesign measure and the requirements that apply to your product
• Coordinating energy-efficiency and standby measurements with accredited laboratories
• Preparing the technical documentation and the Declaration of Conformity