How Indonesian Exporters Can Prepare for EU ESPR 2027

The regulation that will reshape Indonesian export conditions

The EU's Ecodesign for Sustainable Products Regulation (ESPR, Regulation 2024/1781) entered into force in July 2024. It replaced the older Ecodesign Directive and significantly expanded its scope, from energy efficiency requirements to full product sustainability mandates including Digital Product Passports.

For Indonesian exporters, ESPR is not a distant European policy issue. It is a framework that will determine whether specific products can enter the EU market at all. The first deadlines affect batteries in February 2027. Construction materials follow in late 2027. Textiles, electronics, and furniture arrive in phases through 2030–2032.

Missing these deadlines does not mean a fine. It means products cannot be placed on the EU market. Containers stopped at Rotterdam. Import rejections. Lost contracts with EU buyers who cannot accept non-compliant goods.

Which Indonesian products are affected and when

Batteries (EU Battery Regulation 2023/1542): February 2027

The battery passport deadline is the most immediate and the most specific. Any industrial battery above 2 kWh capacity or EV battery placed on the EU market after February 18, 2027 requires a Digital Battery Passport.

Indonesia's exposure:

• Nickel exports: Indonesia's nickel sulfate and nickel intermediates are cathode materials for EU battery manufacturers. Those manufacturers must declare the origin and carbon footprint of their nickel. This data request flows upstream to Indonesian miners and refiners.
• Battery manufacturing: Companies assembling battery packs in Indonesia (including under the IBC program) who sell to EU buyers need battery passports for their products.
• EV components: Indonesian EV manufacturers targeting EU export need to understand the battery passport requirements before their first export.

Construction materials (CPR 2024/3110): Expected Q4 2027

The revised Construction Products Regulation introduces requirements for environmental product declarations (EPDs) and digital documentation of product performance. Products affected include:

• Cement and cement clinker
• Structural steel and steel profiles
• Insulation materials
• Aggregates and concrete products

Indonesian cement exporters (Indocement, SemenIndonesia) who sell to EU markets or serve EU-funded infrastructure projects will face these requirements.

Textiles and garments: Expected 2028–2030

ESPR delegated acts for textiles are in development. Expected requirements include:

• Material composition (fiber types and percentages)
• Recycled content percentage
• Country of manufacture for each production step
• Durability and repairability information
• Microplastic shedding data for synthetic textiles

Indonesian garment manufacturers, particularly those in the Bandung, Surabaya, and Semarang textile clusters who produce for EU brands, will face these requirements as both a regulatory mandate and a buyer condition.

Electronics and ICT: Expected 2030

ESPR delegated acts for electronics are under development. Likely requirements include repairability scores, spare part availability declarations, software support periods, and material composition with recycled content.

Indonesian electronics manufacturers and component suppliers face this timeline.

Step-by-step preparation for Indonesian exporters

Step 1: Determine your product scope

Map every product category you currently export or plan to export to the EU. For each product, identify:

• Which ESPR delegated act or specific regulation applies
• The compliance deadline for that product category
• Whether you are the manufacturer, an intermediary, or a component supplier

The importer who places the product on the EU market bears legal responsibility for DPP compliance. If you sell to an EU importer, that importer needs your product data to create the DPP. If you sell directly to EU buyers or through your own EU subsidiary, you are the responsible party.

Step 2: Join GS1 Indonesia

All DPPs require globally unique product identifiers in the GS1 format. GS1 Indonesia (a subsidiary of GS1 International) issues GTINs (Global Trade Item Numbers) and GS1 Digital Link URIs, the QR code standard that encodes product identity in the DPP data carrier.

GS1 Indonesia membership is required before any DPP can be generated. Membership provides access to the GS1 GEPIR database and Digital Link tools. Contact GS1 Indonesia (gs1id.org) for current membership pricing.

Registration: gs1id.org (GS1 Indonesia)

Step 3: Collect your product data

The data required for a DPP lives across your organization and your supply chain. Begin assembling it now:

For battery products:

• Material composition: cathode chemistry, anode chemistry, electrolyte, cell casing materials
• Critical raw material quantities: cobalt, lithium, nickel, graphite, manganese per battery
• Carbon footprint by lifecycle stage (requires an LCA study)
• Supply chain due diligence documentation for each critical material's origin
• Manufacturing plant GPS location and energy mix

For construction materials:

• Material composition by percentage and mass
• Environmental Product Declaration (EPD) per EN 15804+A2 (requires third-party verification)
• Manufacturing process carbon data

For textiles:

• Fiber composition by percentage
• Country of manufacture for spinning, weaving/knitting, dyeing, cutting/sewing
• Chemical substances used (REACH compliance data)
• Recycled content percentage and verification

Step 4: Calculate your carbon footprint

For batteries (immediately) and construction materials (by 2027), a verifiable carbon footprint declaration is mandatory. This requires:

1. A lifecycle assessment (LCA) study following ISO 14040/14044 and the product category's specific methodology (EU Battery Regulation Annex II for batteries; EN 15804+A2 for construction products)

2. Third-party verification by an accredited verifier

3. Data at the manufacturing plant level, not company-wide averages

Engaging a certified LCA consultant is the first step. Consultants in Indonesia with EU methodology experience include Sertifikasi Sistem Indonesia, Intertek Indonesia, and SGS Indonesia. International firms (Sphera, PE International, Ecoinvent) also serve Indonesian clients.

LCA studies take 3–6 months. For the February 2027 battery deadline, starting now means finishing in September–October 2026, leaving time for DPP system implementation and testing.

Step 5: Understand the cost of non-compliance

The consequences of missing DPP deadlines are not administrative fines. They are market access consequences:

Products stopped at EU customs: Without a compliant DPP, products cannot be cleared for EU market entry. This applies at the border. Retroactive compliance is not possible for goods already shipped.

Contract termination: EU buyers (importers, distributors, brands) who cannot accept non-compliant goods will terminate supplier relationships. They face their own liability if they place non-compliant products on the market.

Lost market share to compliant competitors: Indonesian nickel miners who cannot provide structured supply chain data will lose battery manufacturer customers to competitors (Australian, Philippine, Canadian miners) who can. The same dynamic applies in every affected sector.

Indonesia's exports to the EU exceeded EUR 17 billion in 2024. Access to this market depends on compliance readiness. Indonesian exporters in battery materials, textiles, and electronics sectors face real exposure if DPP requirements are not met ahead of enforcement dates.

What Indonesian exporters can do today

If your battery material export deadline is February 2027:

Begin GS1 registration and LCA scoping immediately. The gap between "we need to do this" and "our first compliant passport is live" is 12–18 months for most organizations.

If your deadline is 2028–2030:

Begin data collection and supplier engagement now. The regulatory requirements are known; the detailed data schemas are published or in development. Companies that begin data collection 2–3 years before deadlines will have clean, verified data when the deadline arrives. Those who begin 6 months before will scramble.

If you are uncertain which deadline applies:

Engage your EU buyer or importer directly. They will tell you what their compliance requirements are and when. EU buyers are increasingly making DPP readiness a supplier qualification criterion even before regulatory deadlines.

For broader context on Indonesia's position in the DPP landscape and the domestic opportunities it creates, see our overview of digital product passport implementation in Indonesia.

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