The EU’s Ecodesign for Sustainable Products Regulation (ESPR), which came into force in early 2025, marks a transformative shift in how manufacturers must approach environmental responsibility. Building on the earlier Ecodesign Directive, the ESPR now applies far beyond energy-related products, extending its requirements to nearly all categories sold in the EU market. This sweeping regulation compels manufacturers, including electronics firms, to perform comprehensive supply-chain impact assessments as a standard part of their design and production processes. For companies aiming to stay compliant—and competitive—the time for action is now.
Under the ESPR, environmental performance is no longer limited to a product’s energy consumption in use. Instead, manufacturers must account for the entire life cycle, from raw material extraction and processing to manufacturing, distribution, use, and end-of-life. The objective is clear: promote circularity, reduce resource use, and minimize environmental harm at every stage. For EU electronics manufacturers, this means looking far deeper into supply chains to assess energy efficiency, material selection, durability, reparability, and recyclability.
So how can companies meet these demanding new obligations? The first step is to adopt robust tools for quantifying supply-chain environmental impacts. Open life-cycle assessment (LCA) databases offer a cost-effective and credible way to start. Resources such as the European Commission’s Product Environmental Footprint (PEF) database, Ecoinvent, and other publicly accessible LCA repositories provide detailed emissions and resource-use data for thousands of materials, components, and processes. By integrating these databases with their product development and procurement systems, electronics firms can generate reliable environmental footprint data across the full life cycle of their goods.
Using open LCA tools doesn’t just help with compliance—it also supports smarter design decisions. For example, when selecting between two suppliers of circuit boards, a manufacturer can evaluate not just cost and technical specifications, but also the environmental impacts of each option, from energy use during fabrication to the recyclability of materials. Similarly, manufacturers can use LCA data to identify hotspots—stages in the supply chain where environmental impacts are disproportionately high—and target these for improvement through redesign or supplier engagement.
Of course, assessing data remotely is only part of the picture. The ESPR encourages manufacturers to verify environmental claims and performance improvements through direct engagement with their suppliers. This means implementing supplier site audits that go beyond traditional quality or social compliance checks. A well-designed audit program should focus on areas such as energy efficiency (e.g., the type and source of energy used in production), material efficiency (e.g., waste rates and use of recycled inputs), and progress toward circularity (e.g., take-back schemes or modular product designs).
To support firms in planning these audits, it is advisable to develop a scheduling template that aligns with product development cycles and major procurement milestones. A typical template might include the following elements: supplier name and location; primary material or component supplied; last audit date; audit focus areas (energy, materials, circularity measures); planned audit date; and responsible auditor or team. The schedule should prioritize suppliers that contribute most significantly to the product’s overall environmental footprint or those located in regions where environmental risks are higher. Firms can use this template to build a multi-year supplier engagement roadmap that aligns audit efforts with their product portfolio and sustainability targets.
Transparency will also play a key role. The ESPR is designed to drive market-wide improvements by making reliable, comparable environmental data available to consumers and regulators. Electronics manufacturers will need to disclose product-specific environmental information through digital product passports, a core feature of the ESPR framework. These passports will draw directly on the supply-chain impact data gathered through LCA tools and supplier audits, creating a clear link between supply-chain practices and the product’s environmental performance on the EU market.
Manufacturers that act decisively now will not only achieve compliance—they will also gain a competitive advantage. The ESPR aligns strongly with shifting consumer preferences, investor expectations, and public procurement criteria. Firms that can demonstrate superior environmental performance at the product level will be well-positioned to win market share, secure public contracts, and attract sustainability-conscious investors. Moreover, by building deep supply-chain transparency and fostering collaborative relationships with suppliers, companies can uncover opportunities for cost savings, innovation, and resilience.
The EU Ecodesign for Sustainable Products Regulation represents a step-change in environmental governance for products sold in the EU. It challenges manufacturers to move beyond incremental improvements and instead deliver comprehensive supply-chain impact reductions. By leveraging open LCA databases, implementing rigorous supplier audit schedules, and embedding environmental considerations into core design and procurement decisions, electronics firms can rise to the challenge—and help drive the transition to a truly circular economy.