ESPR & Digital Product Passport: What Kitchen Appliance Importers Need to Do Before 2027
Compliance | Published June 22, 2026 | 10 min read | Author: Devin Chen · APEXDURA / Zhongshan Zhenmei Electrical Appliance Co., Ltd.
ESPR & Digital Product Passport: What Kitchen Appliance Importers Need to Do Before 2027
The EU's most ambitious product regulation is already in force. The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR) entered into force on 18 July 2024, replacing the old Ecodesign Directive that only covered energy-related products. It now extends to virtually every physical product placed on the EU market — including kitchen appliances. The Digital Product Passport (DPP) Registry goes live in July 2026. Horizontal repairability requirements targeting small household appliances are expected in 2027. Kitchen appliance importers who treat ESPR as a distant problem are already running late.
📌 Key Facts
- 📋 ESPR (EU) 2024/1781 entered into force on 18 July 2024 — it is not a future regulation, it is current EU law (European Commission, 2024)
- 🗂️ The EU Central DPP Registry goes live July 19, 2026 — the infrastructure that enables automated customs checks on product passports (PassportCraft, June 2026)
- 🔧 Horizontal repairability requirements for consumer electronics and small household appliances are targeted for 2027 under the ESPR Working Plan 2025–2030 (European Commission, April 2025)
- 🌍 ESPR applies to all importers selling into the EU market, regardless of where the manufacturer is based — Chinese OEM factories are not exempt (Complir, April 2026)
- ⚠️ The destruction ban on unsold clothing, accessories and footwear — the first hard ESPR enforcement date — takes effect 19 July 2026 for large enterprises, signalling that the regulation's enforcement machinery is now operational
What ESPR Actually Is — and Why It Is Different from the Old Ecodesign Directive
The old Ecodesign Directive (2009/125/EC) only covered energy-related products: appliances with motors, heating elements, lighting. If you imported air fryers or microwaves, it applied. If you imported blenders or food processors without energy labelling requirements, it largely did not.
ESPR changes this fundamentally. Under Regulation (EU) 2024/1781, the European Commission can set ecodesign requirements for virtually any physical product. The regulation defines two categories of requirements that will be applied through product-specific delegated acts:
Performance requirements set minimum product thresholds for: durability, reusability, repairability, energy and resource efficiency, recycled content, carbon footprint, and restrictions on substances that impede circularity. The regulation lists 20 potential parameters per product group.
Information requirements mandate that each product carries a Digital Product Passport — a machine-readable digital record accessible via QR code, NFC, or RFID — containing material composition, environmental performance data, repairability scores, substances of concern, and end-of-life instructions.
"In our manufacturing experience serving European B2B clients, the shift from Ecodesign Directive to ESPR is not incremental — it is structural. Buyers in Germany and the Netherlands are already asking APEXDURA for material composition data and disassembly documentation that did not exist in their procurement checklists two years ago. The DPP formalises what leading buyers are already demanding informally."
The ESPR Timeline: What Applies to Kitchen Appliances and When
The Digital Product Passport: What It Is and What It Will Contain
The DPP is not a product label. It is a structured digital record — hosted in a verified system, linked to a physical product via QR code or NFC chip — that stores and communicates compliance data throughout the product's entire lifecycle. Three stakeholders can access it: consumers (sustainability and repair info), market surveillance authorities (compliance verification), and recyclers (end-of-life material composition).
For a kitchen appliance importer, the DPP data fields expected under ESPR product-specific delegated acts will include:
- Material composition: percentage breakdown of plastics, metals, and electronic components by weight
- Substances of concern: identity, location in the product, concentration, and safe handling instructions (linked to REACH substance obligations)
- Repairability score: standardised metric based on spare parts availability, disassembly time, and software repair capability
- Carbon footprint: lifecycle CO₂ equivalent, calculated per unit, per production run
- End-of-life instructions: dismantling guide, recyclable material streams, hazardous component identification
The technical infrastructure — data formats, API standards, interoperability requirements — is being finalised through CEN/CENELEC harmonised standards. The 8 DPP standards are currently in prEN/FprEN draft stage, with final publication expected mid-2026 (the March 2026 target was missed). These standards define what systems must be built against. Importers using DPP platforms should confirm their provider is tracking these standards.
What Kitchen Appliance Importers Must Do Now — in Priority Order
① Audit your supplier's material composition data — now. The DPP's most data-intensive requirement is material composition. Most Chinese OEM factories can provide bill of materials (BOM) data, but few currently have it structured to ESPR's machine-readable standard. Requiring suppliers to provide material declarations at RFQ stage — not post-order — is the single most effective preparation step available today.
② Map your product range against the ESPR Working Plan 2025–2030. The Commission's working plan explicitly names product groups and timelines. Air fryers, blenders, and microwave ovens fall under the 2027 repairability requirements and the 2028–2029 electronics DPP window. Knowing your compliance date lets you sequence investment and negotiate supplier contracts with the correct specification requirements.
③ Remove all unsubstantiated sustainability claims from marketing materials before September 27, 2026. The EU Green Claims Ban (ECGT Directive 2024/825) applies from that date. Generic terms like "eco-friendly", "sustainable design", or "green product" without verified, third-party substantiation are prohibited. Review all product listings, packaging copy, and website content.
④ Require supplier disassembly documentation. ESPR's repairability requirements will include standardised disassembly time measurements and spare parts availability guarantees. Factories that cannot provide repair manuals and spare parts catalogues will not be able to support ESPR compliance. Build this requirement into new supplier contracts now — retrofitting it after tooling is locked is significantly more expensive.
⑤ Select a DPP platform before the July 2026 Registry goes live. The EU DPP Registry requires products to be registered before market placement once requirements apply. Choosing a compliant DPP platform — one building against CEN/CENELEC draft standards — in H2 2026 gives importers a full year of operational experience before the 2027 repairability requirements create hard compliance obligations.
Frequently Asked Questions
Does ESPR apply to kitchen appliances imported from China even if the factory is not in the EU?
Yes, without exception. ESPR applies to any product placed on the EU market, regardless of where it was manufactured. The importer — the EU-registered entity that places the product on the market — bears the compliance obligation. This means Chinese OEM factories supplying European importers must provide the documentation and product data that supports DPP compliance. Importers who cannot obtain this data from their supplier should treat it as a sourcing risk and begin supplier qualification on ESPR readiness.
What is the difference between ESPR and the existing CE marking requirement?
CE marking under the LVD and EMC directives confirms electrical safety and electromagnetic compatibility — it remains mandatory and unchanged. ESPR adds a separate, parallel layer of sustainability and transparency requirements. A product can be CE marked and still fail ESPR compliance if it does not meet durability, repairability, or DPP information requirements. Both layers must be satisfied independently.
When will the Digital Product Passport become mandatory for air fryers specifically?
Air fryers fall under the small household appliances category within the ESPR Working Plan. Repairability requirements are targeted for 2027 (horizontal measure across consumer electronics and small appliances). The full DPP requirement — with complete material composition and lifecycle data — is expected through the electronics delegated act, with compliance dates approximately 2028–2029 following an 18-month transition period after delegated act adoption. These are indicative dates; the exact timeline will be confirmed when the delegated acts publish.
What does the EU Green Claims Ban mean for APEXDURA product marketing?
From 27 September 2026, any environmental claim — on packaging, in product listings, or on websites — must be substantiated by verified evidence using an approved EU certification scheme. Claims like "energy-saving design", "eco-friendly materials", or "sustainable manufacturing" require documented proof. APEXDURA provides third-party test reports from SGS and Bureau Veritas that can serve as substantiation for energy performance claims. Generic terms without verification must be removed before the deadline.
How should I brief my OEM factory in China on ESPR requirements?
Start with three specific requests: (1) a full bill of materials (BOM) listing all component materials by weight and substance, (2) a product disassembly guide showing step-by-step removal of all serviceable components, and (3) a spare parts availability commitment for a minimum of 7 years post-sale. Factories experienced in supplying European buyers will recognise these requirements — those that cannot respond are not ESPR-ready and represent a medium-term supply chain risk.
Source Your ESPR-Ready Kitchen Appliances with APEXDURA
APEXDURA is the international brand of Zhongshan Zhenmei Electrical Appliance Co., Ltd. — 16 years of OEM/ODM manufacturing experience, 500,000 units annual output, 0.8% defect rate across 12 production lines.
✅ Full BOM material composition data available for all models — ESPR DPP preparation ready ✅ CE, RoHS, CB, LFGB certified — third-party test reports from SGS and Bureau Veritas at RFQ stage ✅ Product disassembly guides and 7-year spare parts availability — repairability requirement compliant ✅ PFAS-free non-stick coatings on applicable models — ahead of EU substance restriction trajectory
📧 Email: devin@zszhenmei.com 💬 WhatsApp: +86 136 1272 5240
Related reading: ErP 2026: What the New EU Standby Power Rules Mean for Your Kitchen Appliance Orders | CE Certification for Kitchen Appliances: 2026 Importer's Guide