US Brands Expanding to Europe: How to Prepare for ESPR and Digital Product Passport Requirements

The rules for access to the EU market are changing. 

With the Ecodesign for Sustainable Products Regulation (ESPR), compliance moves closer to the product itself. It no longer depends on what brands report, but on how product-level information is structured, verified, and made accessible across systems.

These requirements apply to products placed on the EU market that fall within ESPR scope and any applicable delegated acts regardless of where it is made. For US brands, this means existing operations must adapt to a different model of compliance.

Here is how to prepare.

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What changes in practice

This is where the shift becomes operational.

ESPR changes how compliance is managed.

In practice, product data becomes part of product architecture. Compliance is no longer handled separately, but embedded into how products are developed, sourced, and managed. Systems need to support continuity of information across the entire lifecycle.

Digital Product Passports are what make this visible.

They act as a structured layer connecting product data, compliance information, and systems, enabling access to product information for different actors across the value chain.

In doing so, they expose inconsistencies that previously remained hidden across documents, teams, and suppliers.

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The real exposure for US brands: imports, checks, and enforcement

The impact of this shift becomes visible at the point where products enter and circulate in the EU.

Under ESPR, any product placed on the EU market must comply, regardless of where it is produced. This includes goods imported from outside the EU. 

Compliance will no longer be assessed only through documentation held internally or shared on request. Product information must be accessible and usable across systems, because it may be required at different points:

• by importers and distributors
• during market surveillance checks
• across digital systems linked to the Digital Product Passport
  
  

If required product information is missing, inconsistent, or cannot be made available when requested, products may face: 

• delays
• additional scrutiny
• restrictions as part of importer, customs, or market-surveillance checks. 

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For products found not to comply with applicable EU requirements, authorities may also require corrective action, restrict market access, or order withdrawal from the market. These consequences will depend on the product category and the specific rules that apply.

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Why this creates friction across the value chain

The difficulty for US brands is not about geography. It comes from how compliance responsibilities are structured when selling into the EU.

When a product is placed on the EU market by a non-EU brand, responsibility is shared across multiple actors:

• the importer placing the product on the EU market
  
  
• the distributor making it available
  
  
• and the brand, which ultimately needs to provide the required product information
  
  

This creates a specific operational dynamic.

EU-based operators are required to ensure that products comply with applicable requirements and that the necessary documentation and information are available. This means that, in practice, importers and distributors rely on the brand to provide consistent and complete product data.

The friction does not come from regulation itself, but from this dependency.

If product information:

• is not structured
• cannot be linked clearly to the product
• or is difficult to retrieve across systems
  
  

it creates delays, repeated requests, and misalignment between actors in the value chain.

This is where most issues emerge.

Not because requirements are unclear, but because product data is not organized in a way that supports multiple actors working on the same product across different systems and jurisdictions.

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What US brands should put in place now

ESPR defines what information must be available, but not how companies should organize to deliver it. In practice, readiness depends on how data, systems, and responsibilities are set up.

This is increasingly reflected in how EU product compliance is being framed, where the focus shifts from documentation to the availability and reliability of product-level information across systems.

At this stage, the question is no longer what ESPR requires in theory, but what needs to exist in practice for a product to move smoothly across the EU market.

There are a few concrete elements that make the difference.

First, someone in the organization needs to be accountable for product data. Not in a reporting sense, but as an operational role. Without clear ownership, information remains fragmented and difficult to maintain.

Second, product information needs to be aligned across teams. Product, sourcing, compliance, and operations cannot work on separate versions of the same data. Misalignment internally becomes friction externally.

Third, brands need to understand what their EU partners will expect. Importers and distributors are not just commercial intermediaries. They rely on the brand to provide complete and consistent product information, and gaps tend to surface at that interface.

And finally, brands need to test their readiness before it is required.

This means asking simple but critical questions:

• Can we retrieve all required product information quickly?
  
  
• Is it consistent across systems and teams?
  
  
• Can it be shared in a format that others can use?
  
  

If the answer depends on manual work, multiple documents, or internal coordination, the system is not ready.
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What this looks like in reality

If you are already selling in the EU, this is what changes.

Under ESPR, product information is no longer something you can assemble when needed. It must already exist as structured data, ready to be used within systems such as the Digital Product Passport.

This changes the sequence.

Instead of collecting and preparing information after a request, you need to ensure that product data is already:

• defined at product level
• aligned across systems
• continuously maintained over time

The Digital Product Passport is where this becomes concrete.

It is the point where product information is expected to be complete, consistent, and usable, not just internally, but across the value chain.

In this model, compliance is no longer triggered by a request. It is built into how product data exists from the start.

This is the difference.

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Where to start

Renoon supports this transition by turning product data into a structured, operational system that is ready for ESPR and Digital Product Passport requirements. By connecting product, supplier, and compliance information across existing systems, brands can ensure that data is already consistent, accessible, and usable at product level, rather than assembled when needed.

For brands already selling in Europe, the starting point is not collecting new information, but understanding how current data is structured and where it does not yet align with EU requirements.

👉 Still unsure where to start? Explore Renoon’s Advisory Program to assess your readiness and define a clear path toward Digital Product Passport implementation.