The topic of regulation may sound dry. In practice, however, it determines how effectively a product is developed, documented, and later brought to market. The EU Ecodesign Regulation illustrates this point. It has been in effect since July 2024 and aims to make sustainable products the standard in the EU internal market. The data and classification provided here are taken from the ZVEI guidance document. The ZVEI is the Association of the Electrical and Digital Industries and brings together industry knowledge, positions, and practical guidance for companies. And as is always the case, regulations rarely come with confetti; more often than not, they bring a clipboard…
One tangible point is the disclosure of information regarding disposed unsold consumer products. In this context, “unsold” refers not only to excess inventory but also to slow-moving items and goods returned by consumers after purchase. As things stand, large companies must first disclose this information in 2026 for the 2025 fiscal year. Medium-sized companies will follow starting July 19, 2030. Small and micro-enterprises are exempt.
The following information must be disclosed: the number and weight of products disposed of, the reasons for disposal, the respective waste treatment methods, and the measures taken and planned to prevent destruction. This information must be published prominently on the website or via a clear link in the sustainability report. This fundamental obligation already stems from the ESPR. Implementing Regulation 2026/2 defines, effective March 2, 2027, the format for this reporting, the product scope based on CN codes, the requirement to disclose information within twelve months of the end of the fiscal year, and the obligation to retain supporting documentation for five years.
For many of our customers, the key issue right now is determining the scope of application! This specific obligation does not automatically apply to every industrial company. It pertains to unsold consumer products that have been placed on the EU market. Components, intermediate products, and product parts are not covered. Spare parts are generally exempt as well. Companies that primarily develop or supply products in the B2B sector are often not immediately subject to this reporting requirement. As soon as a product is primarily intended for consumers, the situation changes.
A look at current discussions reveals where the EU is focusing its attention. For example, consumer goods with high return and destruction rates are already in the spotlight. These include clothing, shoes, consumer electronics, and small household appliances. Large volumes of returns and excess inventory are particularly common in online retail.
Many traditional industrial sectors, on the other hand, are currently less directly affected. Products from mechanical engineering, industrial components, control systems, assemblies, or custom-built systems are generally not considered consumer products and therefore do not currently fall within the direct scope of this specific reporting requirement. For many of our industries, this means that regulatory scrutiny is on the horizon, but usually with a time lag.
The EU wants transparency regarding disposal practices, reasons, and countermeasures. In my view, this means for our customers that product development, data structure, logistics, and external communication are becoming more closely integrated. Those who fail to distinguish between consumer products, components, and intermediate products create unnecessary bottlenecks in approval, documentation, and reporting.
According to ZVEI, the data typically comes from warehouse and inventory management, the returns department, and the records of waste management companies. If you wait until the end of the year to gather this information, you’re not doing reporting—you’re on a treasure hunt, aren’t you? Excel can do a lot, but clairvoyance isn’t one of its features.
The information is publicly accessible. National authorities conduct risk-based audits, request supporting documents, cross-check data with waste management companies’ records, and can notify other member states if a violation crosses national borders. A discrepancy of less than 10 percent between disclosed figures and verified documentation is considered acceptable.
I would therefore not focus on the subsequent publication, but rather on the chain of events leading up to it. Does the product even fall within the scope of application? Can quantities, weights, reasons, and disposal routes be reliably recorded? Have measures to prevent destruction already been incorporated into development, take-back, and product maintenance?
For us, regulatory compliance logically belongs at the start of the project. It must be included in the specifications, the system architecture, and the data pathways. Later on, it costs money.
