What brands need to know and how to navigate

The European Union’s Ecodesign for Sustainable Products Regulation (ESPR) is reshaping what it means to bring a product to market in Europe. Brands that fail to meet these evolving standards could soon find themselves locked out of key markets.

The ESPR will work toward the goal of improving product sustainability via specific requirements around durability, recyclability, end of life handling, and more. It went into force, meaning it was formally adopted, in July 2024. But it isn’t in effect as of yet. Requirements for specific products will apply only once product group regulations are finalized through delegated acts.

For most brands, the key impact of ESPR will come after those delegated acts are in place. The earliest implementation date appears to be sometime in 2026.*

At the heart of the ESPR is a requirement that demands urgent attention for footwear brands: the Digital Product Passport (DPP). It’s anticipated that the DPP will go into effect in July 2026.*

Below, we’ll summarize the ESPR and the DPP for footwear brands operating, manufacturing, or selling in the EU. 

Why is Cirql the expert team you should trust on regulatory compliance? Two reasons:

• Cirql was designed  from the start to support circularity and traceability—making us uniquely prepared for ESPR and DPP readiness.

• ESPR compliance is not just a strategic imperative, it’s an opportunity and a brand advantage.
  

ESPR compliance isn’t just about avoiding penalties. It’s a chance for brands to lead, to differentiate, and to future-proof their supply chains. Many suppliers aren’t ready or able to satisfy ESPR and DPP requirements. 

Cirql is ready and able.

Here we go. 

[*A note on timing: The current (mid-2025) European Commission webpage on ESPR and DDP indicates earlier timeframes that reflect earlier proposals around implementation. In fact, provisions do not apply until the delegated acts are adopted and, as of now, no specific deadlines have been confirmed. Based on the current process, implementation is likely to begin in 2026.]

What Is ESPR?

ESPR is the EU’s new framework for sustainable product design and circularity. 

It mandates stringent requirements around:

• Material traceability
• Recycled content thresholds
• Durability and repairability
• End-of-life management
• The new Digital Product Passport (DPP)
  

What Is the DPP?

The DDP  is a cornerstone of the EU’s sustainability agenda. It’s akin to a detailed, digital identity card for many products sold in the EU. While the DPP will be a key element of the ESPR, it will not apply to every product. Only products in categories selected through future delegated acts will require DPPs. Footwear is considered a high-priority category, but the final list and timeline are not confirmed.

With that expectation, Cirql is prepared. Footwear brands should also be planning to satisfy the intent of DPPs, which is to provide regulators, consumers, and supply chain partners with standardized information on:

• Material content and composition
• Recycled content
• Repairability and durability
• Environmental impact
• End-of-life handling (recyclability, compostability, etc.)
• Supply chain traceability
• Regulatory compliance and certifications

DPPs will be presented as unique scannable code, like an NFC chip or a QR code for every product that requires one. The information must be verifiable, machine-readable, and kept current. The goal of these codes is to ensure ease of accessibility by EU regulators and possibly consumers. It’s not yet been confirmed whether the access point will be via a single, central database or a network of interoperable systems.

It’s a tall order for footwear brands, and one that will be incredibly difficult to reach with opaque or fragmented supply chains.

Importantly, noncompliant products could be blocked from entering the EU market.

We understand if brands are scrambling to piece this together. Cirql is ready and here to help.

Cirql Makes ESPR and DDP Compliance Easy

Here’s how Cirql delivers:

• Full Material Traceability: Every component and input is tracked from raw material to finished product, so DPP fields can be populated with accurate data.
• Verified Recycled Content (GRS-certified): Our foams contain third-party verified recycled content that meets or exceeds ESPR threshold. We provide the documentation to prove it.
• Circular by Design: Cirql materials meet ESPR’s requirements for end-of-life and performance data. Our products are engineered for durability, and end-of-life circularity, whether through recyclability or biodegradation through industrial composting.
• DPP-Ready Data Delivery: We provide structured, verifiable data that can be easily integrated into your DPP system, saving your compliance and product teams time and cost.

Cirql Is More Than a Material. We’re Your Regulatory Partner.

We’ve always believed that performance and sustainability can–and should–go hand in hand. With ESPR and DPP, we’re proving it transparently at the data level.

Partner with Cirql to:

• Adhere to ESPR and DPP deadlines
• Reduce risk across the supply chain
• Support marketing claims with data
• Streamline compliance workflows
• Build trust with regulators and consumers 

When you work with Cirql, you get more than premium foam with end of life circularity potential. You get a head start on one of the biggest regulatory shifts in product history.

Join us.

Explore Cirql Products: Cirql rTPU30 and Cirql ZeroTo speak to a Cirql representative, contact us here.