Does this reach my product, and why the lists disagree

Your product is inside the ecodesign regulation only when a delegated act covers its product group. The European Commission has adopted no such act, so today the regulation reaches no product at all.

Some products sit outside it for good. Article 1(2) excludes food, feed, medicinal products, living plants and animals, and products of human origin. Food includes drink, so a carton of Marlborough sauvignon blanc is out.

This site searched 104 New Zealand pages on 16 August 2026. Thirty-nine of them leave the scope question open, and some publish a category list that the regulation does not support.

Three New Zealand lists disagree with each other

Warning: check a category list against the regulation before you act on it.

None of the three is careless work. Each writer read a Commission plan and described it. The trouble is that a plan names product groups, and a duty comes from an instrument.

Four groups get a passport from their own law, not from ecodesign

Do not look for these four in the ecodesign programme.

Batteries are the fifth, and they are the one with a live date. Regulation (EU) 2023/1542 applies from 18 February 2027 to three categories. See which products need a passport, and when.

The exclusion covers the product, and never the company

Article 1(2) of the ecodesign regulation lists what it does not reach.

• food and feed
• medicinal products and veterinary medicinal products
• living plants, animals and micro-organisms
• products of human origin
• products of plants and animals that relate directly to their future reproduction

Article 2 of Regulation (EC) No 178/2002 defines food for this purpose, and that definition covers drink. So wine, beer and spirits are food in European law. See wine, beer and spirits.

Warning: a business that sells manuka honey and merino jumpers holds one excluded product and one that a later act may cover.

Your packaging is a separate product, and the packaging regulation reaches it even where the food exclusion protects what is inside. See packaging.

Three groups people expect to be excluded are not

Cosmetics, tobacco products and medical devices stay inside the scope of the ecodesign regulation. Batteries are not on the exclusion list either.

That surprises New Zealand exporters of natural health products most. A skin care product made from a plant extract is a cosmetic, and not a food. See cosmetics and natural health products and ESPR exclusions.

The deforestation regulation is a different law, and it does reach food

Some New Zealand pages join the passport to the European deforestation regulation. LASRA does it for hides, and Farmers Weekly and BusinessDesk cover it for meat.

Those two laws are not the same. The deforestation regulation is Regulation (EU) 2023/1115, and it reaches cattle products, leather, timber and some other commodities. It has its own duties and its own dates.

An exclusion under the ecodesign regulation gives you nothing under the deforestation regulation. A New Zealand beef exporter is outside the passport rule and inside the deforestation rule.

Find your position in four steps

1. Check the exclusion list above. Food, feed and medicine sit outside for good.
2. Check the four instruments above. Your duty may come from one of them.
3. If you sell one of the three battery categories, work to 18 February 2027.
4. For everything else, find your group in which products need a passport, and when.

If you supply a component to somebody else's product, no ecodesign duty falls on you. Your customer asks you for the data instead, as a condition of purchase. See component suppliers.

The next open question is who carries the duty once one exists. See who carries the duty.