ESPR Working Plan: Next Steps For The EU Ecodesign Framework

The Ecodesign for Sustainable Products Regulation (ESPR) is one of the EU’s most ambitious tools to transform the way products are made. It tackles one of the most important aspects of a product’s lifecycle: the design phase.

With the first ESPR Working Plan now published, EU businesses across the board should be paying close attention. This plan not only defines the product groups that must soon comply with new ecodesign rules — it also sets the tone for future regulatory efforts across the Single Market.

In this article, we will explore what the first Working Plan includes — and excludes — what the phased timeline for implementation looks like, and what businesses can do to avoid being caught off guard.

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The ESPR’s Role In The EU’s Sustainability Vision

The Ecodesign for Sustainable Products Regulation is the cornerstone of the EU’s strategy to make sustainable products the norm. It builds on the legacy of the Ecodesign Directive, expanding its scope beyond energy-related products to cover physical goods placed on the EU market, although they will not all be targeted at once.

With the ESPR, the European Commission is setting out to reduce the environmental impact of products throughout their lifecycle by tackling the design phase and making it mandatory to consider criteria promoting repair, recyclability, and circular business models from the beginning. The regulation opens the door to the possibility of setting market entry requirements for durability, repairability, resource efficiency, recycled content, and more. It also lays the groundwork for the highly anticipated Digital Product Passport (DPP), a key enabler of transparency and circularity.

Product Groups Covered By The First ESPR Working Plan

To transparently communicate which product groups are first in line for targeted and specific ecodesign requirements, the European Commission must adopt the initial Working Plan that has just been published. The plan covers the next five years with an intermediate review after three years, to mirror the duration of the Commission and Parliament’s mandate and to ensure predictability for businesses.

This first ESPR Working Plan identifies the priority product groups and outlines potential horizontal ecodesign requirements.

Product Groups Under The Scope

So, what products will have to comply with specific ecodesign requirements? The following product groups will be featured:

• New Final Products: Textile/apparel (excluding footwear), furniture, tyres and mattresses.
• Intermediate Products: Aluminium, iron, and steel.

Other products carried over from the original Ecodesign Directive and Energy Labelling Working Plan will also be addressed, including consumer electronics and ICT products such as mobile phones, tablets and displays, and certain home and professional appliances like washing machines, refrigerators and dishwashers.

Why these products? It was taken into account their potential to contribute to the EU’s climate, environmental and energy efficiency objectives. The Commission also considered factors such as the gaps in EU law, range of product performance, volume of sales and trade, impacts across the value chain and the need to review existing requirements.

Excluded Product Groups

Home textiles and footwear have been excluded from the plan, as they have lower impacts and lower improvement potential, lower stakeholder support than the final products selected and/or distinct use of materials, product functionality and supply chains. Detergents, paints, lubricants and chemicals will also be exempt from this first wave of requirements for the same reasons.

Horizontal Requirements

Ecodesign requirements may target individual products and product groups, or apply across multiple product groups in a horizontal manner. In this first plan, the prioritised horizontal requirements are repairability and recyclability.

For repairability, the focus is exclusively on energy-related products. This includes exploring the introduction of a ‘repair score’, as well as setting requirements for providing repair and maintenance information to independent operators and end users, ensuring the availability and timely delivery of spare parts and access to software updates.

For recyclability and recycled content, the priority will be on electrical and electronic equipment. These requirements are intended to complement the upcoming revision of the Waste from Electrical and Electronic Equipment (WEEE) directive.

At least for now, horizontal measures seem to be off the table for apparel goods.

The Implementation Timeline

The requirements established under the ESPR will be implemented progressively, with each product group following its own timeline.

Implementation time is a minimum of 18 months after adoption and so far, the indicative timeline for product requirements to be adopted is as follows:

• Apparel – Early 2027
• Furniture – 2028
• Tyres – 2027
• Steel – Q4 2026
• Aluminium – 2027

However, businesses must stay alert to other ESPR measures, such as the ban on the destruction of unsold goods, and reporting obligations regarding such products. While micro and small enterprises are exempt, the destruction of unsold textile and footwear products will be prohibited for large organisations from July 2026, and for medium-sized enterprises from July 2030.

Final Thoughts and Recommendations

Environmental organisations have advocated for a broader working plan scope, and the exclusion of items such as home textiles and footwear creates doubts around how the eco-modulation fees established by the EPR and Waste Framework Directive will be set for these products.

Nevertheless, the first ESPR Working Plan is a major milestone in the EU’s sustainability agenda — and a wake-up call for many businesses.

Even if your product group is not included in this initial round, we strongly recommend taking immediate action by:

• Assessing your current product portfolio in light of the ESPR requirements established for other industries.
• Conducting internal discussions with product development, sustainability, and compliance teams to outline a transition strategy.
• Engaging in the policymaking process to stay informed and influence outcomes where possible.

Our consultants have been hard at work creating tailored solutions to help organisations across impacted sectors prepare for the ESPR — from early impact assessments to stakeholder engagement strategies. Ready to future-proof your business with expert support? Get in touch and let’s get started!

Want someone with deep experience and connections in the EU to help guide your sustainability strategy? Get in touch!

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