The European Union is in the process of rolling out one of the most significant product regulations in decades: the Ecodesign for Sustainable Products Regulation (ESPR).
If you are an independent or luxury-adjacent watch brand, you may already have heard that Digital Product Passports are coming. What is less clear is what this actually means in practice — and what it does not mean.
This article aims to explain ESPR in plain terms, specifically through the lens of watch brands.
What Is ESPR?
ESPR is a framework regulation designed to improve the sustainability, transparency, and circularity of products sold in the European Union.
Rather than focusing only on energy efficiency (as earlier ecodesign rules did), ESPR expands the scope to include:
- Materials and sourcing
- Durability and repairability
- Environmental impact across the product lifecycle
- Transparency for regulators, recyclers, and consumers
Crucially, ESPR introduces the concept of a Digital Product Passport (DPP) as the mechanism through which much of this information will be accessed.
Why Digital Product Passports Are Being Introduced
The EU’s challenge is not a lack of rules, but a lack of verifiable information.
Today, product data is:
- Fragmented across systems
- Locked in PDFs or internal databases
- Difficult to access at the point of inspection, resale, or recycling
Digital Product Passports are intended to solve this by providing a structured, machine-readable, and accessible record of a product’s key information throughout its lifecycle.
For watches, this is less about consumer novelty and more about regulatory infrastructure.
What ESPR Is Likely to Mean for Watch Brands
While detailed delegated acts are still evolving, it is reasonable to expect that watch brands selling into the EU will need to be able to provide:
- Core product identification data (model, reference, serial)
- Information on materials and components
- Origin and provenance data where relevant
- Guidance related to servicing, repair, or end-of-life handling
This information is expected to be made available via a Digital Product Passport, typically accessed through a QR code or similar mechanism.
Importantly, the passport is not a marketing page. It is a compliance artefact.
What ESPR Does Not Mean (Despite the Noise)
There is a great deal of speculation around ESPR, and much of it is unhelpful.
ESPR does not automatically require:
- Participation in resale marketplaces
- Public disclosure of sensitive supplier relationships
- Consumer wallets or accounts
- Tokenisation or speculative digital assets
- Overly complex consumer experiences
For most watch brands, ESPR is not about reinventing how watches are sold. It is about being able to produce the right information, in the right format, when required.
Timing: What Brands Should (and Shouldn’t) Panic About
ESPR is a framework regulation. That means:
- Requirements will be phased in by product category
- Timelines will be clarified through secondary legislation
- Enforcement will not be uniform on day one
That said, waiting until requirements are fully enforced before preparing is risky.
Brands that treat Digital Product Passports as last-minute compliance work are likely to face:
- Rushed implementations
- Poor customer experiences
- Internal operational strain
How Watch Brands Can Prepare Without Overbuilding
Preparation does not require speculative technology bets.
Sensible early steps include:
- Structuring product and materials data in a consistent way
- Separating compliance information from marketing content
- Choosing systems that respect brand control and discretion
- Avoiding platforms that conflate regulation with consumer hype
The goal is not to build the perfect Digital Product Passport today, but to establish calm, credible foundations.
A Note on Infrastructure
Digital Product Passports are ultimately infrastructure. They should feel quiet, stable, and unremarkable.
Platforms such as Horology.id exist to help watch brands host and present ESPR-aligned passport data in a brand-safe way, without forcing unnecessary complexity or technology decisions.
The brands that navigate ESPR best will be those that treat it not as a trend, but as a long-term operational reality.
This article is for informational purposes only and does not constitute legal advice.