The European Union's regulatory framework for sustainable products has entered a new phase. The Ecodesign for Sustainable Products Regulation (ESPR) extends environmental requirements to virtually all goods sold in the EU market and introduces Digital Product Passports as a mandatory transparency mechanism. For e-commerce businesses, manufacturers, and supply chain operators, this creates new documentation obligations where visual evidence plays an increasingly important role.
What is ESPR?
The Ecodesign for Sustainable Products Regulation (EU) 2024/1781, in force since July 2024, represents a significant expansion of the EU's ecodesign framework. While previous ecodesign rules focused primarily on energy-related products, ESPR extends requirements to nearly all physical goods placed on the EU market.
The regulation establishes three core pillars. First, performance requirements mandate that products meet minimum standards for durability, repairability, recyclability, and resource efficiency. Delegated acts will define specific criteria for each product category. Second, information requirements ensure that detailed product data is made available to consumers, businesses, and authorities, including material composition, recycled content percentages, substances of concern, and expected product lifespan. Third, Digital Product Passports require each product to carry a unique identifier linking to a standardized digital record containing all required sustainability information.
The European Commission's ESPR portal outlines that priority product categories include textiles and apparel, furniture, mattresses, tires, and consumer electronics. These sectors will face the earliest and most comprehensive requirements.
Digital Product Passports Explained
The Digital Product Passport (DPP) is ESPR's central innovation. It functions as an electronic identity card for each product, accessible via QR code or similar persistent identifier. The Commission describes the DPP as a system that "will store relevant information to support products' sustainability" and must be electronically accessible to consumers, businesses, and authorities.
A DPP typically contains technical performance specifications, material composition and origins, recycled content percentages, substances of concern, repair and maintenance information, recycling and disposal instructions, compliance documentation such as CE marking and declarations of conformity, and lifecycle environmental impact data.
For e-commerce platforms, Article 29 of ESPR creates specific obligations. Marketplaces must organize their online interfaces so sellers can enter all required ecodesign data. They must also permit market surveillance tools to access listings and verify compliance. This means product pages will need to display or link to DPP information, transforming how online listings present product data.
Customs authorities will use DPPs to automatically verify that imported goods have valid passports, making compliance essential for market access.
Supply Chain Transparency Requirements
ESPR obligations extend throughout the supply chain. Upstream actors, including component suppliers, material processors, fabric mills, and recyclers, are legally required to provide information that enables downstream businesses to verify compliance and complete DPP entries.
The regulation empowers authorities to require supply chain actors to provide information related to their supplies relevant to verifying compliance with ecodesign requirements. In practice, fabric mills must document fiber composition and recycled content, material processors must provide certificates for recycled inputs, component suppliers must disclose substances of concern, and manufacturers must trace origins of key materials.
For e-commerce retailers and third-party marketplace sellers, this translates to new sourcing due diligence. Sellers must ensure suppliers furnish the details needed for DPP entries: exact material types, recycled fractions, and traceable origins of key components.
Third-party marketplace sellers are not exempt. If a vendor is considered the manufacturer or importer under EU law, they must ensure a DPP is created for each product. Distributors must verify product compliance and maintain records to provide to authorities upon request.
The Role of Visual Documentation in Compliance
While ESPR focuses on data and documentation, visual evidence increasingly supports compliance verification. Product photographs serve multiple functions within the ESPR framework:
Product Identification: Images of products, serial numbers, and unique identifiers help establish which physical item corresponds to which DPP record.
Material Verification: Photographs of material certificates, recycled-content labels, and batch stamps provide supporting evidence for DPP claims.
Supply Chain Documentation: Visual records at each production stage, from raw materials through manufacturing, packaging, and shipping, create an audit trail that reinforces data accuracy.
Compliance Labels: Images of CE conformity marks, energy labels, and other regulatory markings demonstrate that required certifications are present.
The challenge is that digital images can be manipulated. Without verification, a photograph of a recycled-content certificate or a CE label cannot be trusted as authentic evidence. This is where photo forensics and visual traceability become relevant to ESPR compliance.
How Lumethic Enables ESPR Compliance
Lumethic provides the technical infrastructure to ensure visual documentation used in ESPR compliance is authentic and verifiable. The platform offers three complementary tools:
Lumethic Capture App
The Lumethic Capture iOS app allows supply chain operators to photograph critical compliance items with cryptographic attestation. Each image captured through the app undergoes forensic analysis to confirm it was taken by a real camera sensor, then receives a C2PA manifest with a cryptographic signature certifying the image's origin and the device used.
The app is ideal for photographing product serial numbers and unique identifiers, material certificates and recycled-content documentation, CE conformity labels and compliance markings, production batches and manufacturing stages, and packaging with DPP QR codes.
Web Verification Platform
The Lumethic web platform verifies existing photographs by comparing them against original RAW camera data files using forensic computer vision analysis. Users upload both the final image and the corresponding RAW file from the camera. When verification succeeds, the platform applies C2PA content credentials and generates a shareable verification report. The RAW file is analyzed but never stored, protecting intellectual property.
This is valuable for verifying product images already in your database, authenticating supplier-provided documentation photos, creating verified visual records for DPP attachment, and establishing chain of custody for compliance audits.
API Integration
The Lumethic API enables enterprise integration for automated verification workflows. Like the web platform, the API requires both the final image and the original RAW camera data file for verification. Businesses can build this verification process directly into their product information management systems, quality control processes, or DPP platforms.
API capabilities include batch verification of product imagery, automated C2PA manifest generation, integration with existing compliance databases, and webhook notifications for verification results.
Practical Use Cases
Textile and Apparel Compliance
A fashion brand sources organic cotton from multiple suppliers. Using Lumethic Capture, quality inspectors photograph material certificates at each supplier's facility. These verified images are attached to the DPP for each garment, providing consumers and regulators with authenticated visual proof that the claimed organic content is genuine.
Furniture Manufacturing
A furniture manufacturer must document the origin of wood components and recycled metal content. At each supply chain stage, verified photographs capture batch numbers, forest certification labels, and recycled-content stamps. When regulators request evidence, the manufacturer provides DPP data backed by cryptographically signed visual documentation.
E-commerce Marketplace Verification
An online marketplace requires sellers to provide product compliance documentation. By integrating Lumethic's API, the platform can verify that uploaded product images and compliance labels are authentic before listing items. This reduces the risk of fraudulent documentation entering the marketplace.
Import Documentation
An importer bringing products into the EU must demonstrate compliance at customs. Verified photographs of products, labels, and certifications, captured at the origin facility, provide customs authorities with authenticated visual evidence that supports the DPP data.
Building Trust Through Verified Documentation
ESPR creates a framework where product sustainability claims must be substantiated with verifiable data. While the regulation focuses on textual and numerical information within Digital Product Passports, visual documentation provides crucial supporting evidence.
Lumethic's photo forensics and C2PA-based verification ensure that visual evidence attached to DPPs is authentic and tamper-evident. By preventing manipulation of product images and creating a traceable chain of custody, these tools complement the DPP's data integrity requirements.
For e-commerce businesses, manufacturers, and supply chain operators navigating ESPR compliance, verified visual documentation transforms photographs from unverifiable claims into cryptographically secured evidence. This strengthens compliance posture, reduces fraud risk, and builds the trust that the regulation's transparency requirements are designed to achieve.
Explore how Lumethic can support your ESPR compliance strategy →