The New EU Ecodesign Directive (ESPR): Impact on the German Economy

_ J.C. Kofner, Economist, MIWI Institute. Munich, January 31, 2025.

In July 2024, the European Commission, under the leadership of Ursula von der Leyen (CDU), introduced the Ecodesign for Sustainable Products Regulation (ESPR), significantly expanding the existing Ecodesign Directive (Umweltbundesamt, 2024). This new regulation applies to nearly all physical goods placed on the EU market. Companies must collect detailed information on various aspects of their products, including durability, reusability, upgradeability, reparability, and their carbon and environmental footprint. These data must also be documented in a digital product passport. Additionally, the directive is closely linked to the planned tightening of energy efficiency requirements for heating systems, which effectively prioritizes the use of heat pumps (European Commission, 2023).

This will lead to significant additional costs for consumers and manufacturers, dampen economic growth, and weaken Europe’s international competitiveness. The Ecodesign Directive is just one in a series of the EU’s green regulatory burdens, including the EU Taxonomy, the Supply Chain Act, the Carbon Border Adjustment Mechanism (CBAM), the Corporate Sustainability Reporting Directive (CSRD), the Energy Performance of Buildings Directive, the Net Zero Industry Act, and the EU Energy Efficiency Directive.

According to EuroLex (2024), a total of 1,265 new legal acts were passed at the EU level between 2018 and 2023. Increasing regulation has measurable effects on Germany’s competitiveness. In the latest Country Index of the Foundation for Family Businesses (2025), Germany has dropped from 15th to 17th place out of 21 countries in the “Regulation” category. The German Mittelstand is particularly affected: according to a survey by DZ Bank (2024), more than four-fifths of medium-sized businesses see bureaucratic burdens as their biggest problem.

The economic impact is significant. Annual bureaucracy costs for the German economy are estimated at between 66 and 146 billion euros (NKR, 2024; ifo Institute, 2024). For small and medium-sized enterprises, this translates into an average burden of 12,500 to 28,300 euros per year (IHK, 2024). A survey by INSM (2024) found that 40.7 percent of respondents hold the CDU/CSU responsible for the high bureaucratic burden, followed by the Greens at 28 percent and the SPD at 16.2 percent.

Long-term developments also show a sharp increase in administrative requirements. Between 2011 and 2022, the costs of annual compliance efforts increased fourteenfold under the CDU/CSU-led Grand Coalition. Under the current traffic light coalition, these costs have already doubled in a much shorter period (NKR, 2024).

The Ecodesign Directive thus represents a significant additional regulatory burden. It imposes extensive documentation requirements, placing further administrative hurdles on businesses. This directive is an unnecessary and harmful burden that must be abolished immediately—along with all other EU bureaucratic monstrosities.

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