The Regulatory Clock is Ticking: ESPR Compliance is Now a Board-Level Imperative for Luxury Brands

May 15, 2025

The Strategic Imperative

The landscape for luxury goods within the European Union has fundamentally shifted. The Ecodesign for Sustainable Products Regulation (ESPR) (EU) 2024/1781 isn't a future concern; it entered into force on July 18, 2024. This framework regulation, a cornerstone of the EU Green Deal, mandates a new paradigm for sustainability, impacting nearly all physical goods sold in the EU – including the core categories of luxury: textiles, footwear, and furniture. Waiting is no longer a viable strategy; proactive engagement is essential for continued market access and brand integrity.

The Immediate Threat – Unsold Goods

Beyond broad sustainability goals, the ESPR introduces sharp teeth. Critically for the fashion and luxury sectors, a ban on the destruction of unsold textiles and footwear will apply from July 19, 2026, for large enterprises, as highlighted by analyses from consultancies like Bird & Bird and TÜV SÜD. Furthermore, disclosure requirements on unsold goods began for large companies in the first financial year after the regulation's entry into force. This isn't merely an operational tweak; it demands immediate strategic reassessment of inventory management, demand forecasting, and production cycles. Ignoring this deadline invites not only regulatory sanction but also significant reputational damage.

The Boardroom Mandate

ESPR compliance, particularly the implementation of Digital Product Passports (DPPs), transcends departmental functions. It requires C-suite attention, cross-functional collaboration (design, supply chain, legal, marketing), and potentially significant investment in data infrastructure and process redesign. The question is no longer if your brand needs to adapt, but how quickly you can align strategy and operations to meet these non-negotiable requirements. Delay is a luxury you cannot afford.