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The EU just published its 2025–2030 Ecodesign and Energy Labelling Working Plan, a key milestone in making sustainable product regulation a reality.
This Working Plan outlines the first concrete steps to implementing the Ecodesign for Sustainable Products Regulation (ESPR), including which products will be prioritized and what requirements they’ll face.
If your business is preparing for the ESPR, here’s what matters right now.
Understanding the newly released ESPR Working Plan
The ESPR sets the overarching goal: making products in the EU market more sustainable. The Working Plan defines how that goal will be achieved.
Starting in April 2025, it identifies the first product groups to face new requirements and introduces key concepts like repairability, recyclability and the Digital Product Passport.
In short, it’s the EU’s playbook for turning regulation into action.
Textile, tires, furniture, and more: priority products identified by the EU
Based on studies and stakeholder input, the EU has identified the first product groups to be regulated under the ESPR. The selection was guided by factors like environmental impact, market volume, existing regulatory gaps, and the potential to support climate and energy objectives.
What products are prioritized?
Over the next three years, the following products will fall within scope:
Final products
- Textiles & apparel
- Tyres
- Furniture
- Mattresses
Intermediate products
- Iron
- Steel
- Aluminium
Horizontal requirements
- Repairability (including a standardized repair score)
- Recycled content and recyclability
ICT and energy-related products will continue to be addressed under existing directives or upcoming reviews.
What products are not included (yet)?
Some product categories — like footwear, detergents, paints, and lubricants — aren’t part of this first phase.
Chemicals are also excluded for now, though an exploratory study is planned for late 2025. These may be addressed in future working plans.
The role of the DPP in the EU's circular economy plans
The Digital Product Passport is central to the ESPR’s implementation. It will make product-level sustainability data, like materials used, carbon footprint, durability, and repair instructions accessible across the entire value chain.
Unlike the traditional energy label, the DPP enables transparency and traceability for a wider range of products. It’s the foundational tool to support the circular economy at scale.
New ESPR rules for public procurement and unsold goods
The Working Plan also extends ESPR's reach to public procurement and product waste
- Green Public Procurement: The EU will assess whether certain products in the plan should be subject to mandatory sustainability criteria for public purchasing. This would make it necessary for public bodies to select the most sustainable option where cost-effective.
- Unsold Product Disposal: The ESPR introduces new transparency rules around unsold products, requiring businesses to disclose how and why items are discarded. While the regulation allows for bans on destroying unsold goods, the Commission has chosen not to include such bans in this Working Plan.
ESPR implementation expected timeline
Each product group will follow a staged process, adoption (when the rules are officially published) and application (when companies must comply). Businesses typically get an 18+ month preparation window. For example, in the case of apparel, the application of the first requirements could be foreseen for 2028.
Here’s what the plan looks like so far:
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