ESPR Working Plan 2025 to 2030: Which Products Come First and When

The EU's Ecodesign and Energy Labelling Working Plan 2025 to 2030, adopted on 16 April 2025, is a key milestone in making sustainable product regulation a reality. It sets which products get ESPR rules first: iron and steel, textiles, tyres, aluminium, furniture and mattresses.

This Working Plan outlines the first concrete steps to implementing the Ecodesign for Sustainable Products Regulation (ESPR), including which products will be prioritised and what requirements they'll face.

If your business is preparing for the ESPR, here’s what matters right now.

Understanding the 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.

Adopted on 16 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.

Read more: What is ESPR?

The EU is boosting product sustainability with its new Ecodesign for Sustainable Products Regulation (ESPR). This regulation broadens ecodesign requirements for many products, aiming to lessen environmental impact and ensure fair competition among EU businesses. It also sets the stage for global sustainability standards. For textiles, adoption of the delegated act is planned for Q4 2027; obligations follow at least 18 months after it enters into force, so around 2029 is a planning estimate.

Read the Guide: Ecodesign for Sustainable Products Regulation

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Textiles, tyres, 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 prioritised?

The plan names these product groups for delegated acts between 2025 and 2030, each with its planned adoption year (indicative):

Final products

• Textiles & apparel (2027)
• Tyres (2027)
• Furniture (2028)
• Mattresses (2029)

Intermediate products

• Iron (2026)
• Steel (2026)
• Aluminium (2027)

Horizontal requirements

• Repairability (including a standardised repair score) (2027)
• Recycled content and recyclability of electrical and electronic equipment (2029)

The plan also carries over 16 energy-related products from the previous working plan, and ICT products are covered by the two horizontal measures.

What products are not included (yet)?

Footwear is handled separately, with a Commission study due by the end of 2027. Detergents, paints, lubricants and chemicals are not scheduled in this working plan and may be addressed in future ones.

Terms to Know: Horizontal Requirement

Horizontal requirements are rules that apply across multiple products within a sector or category.

This is different from vertical requirements, which are tailored to one specific product at a time.

For example, a horizontal requirement for repairability could apply to a range of products, such as certain consumer electronics and small household appliances, instead of setting separate repair rules for phones, laptops, and washing machines individually.

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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. The exact data is set per product group in each delegated act.

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. The EU DPP registry has been live since 20 July 2026; it holds identifiers and registration data, not whole passports, and its being live does not make passports compulsory for any product group.

See a sample DPP from Tappr.

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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: conditional, with no date yet. ESPR lets the Commission set mandatory sustainability criteria for public purchasing through implementing acts, and the plan says it will assess which of its products should get them. No such implementing act has been adopted; the first, on apparel textiles, is indicated for Q4 2027.
• Unsold Product Disposal: since 19 July 2026, large companies may not destroy unsold apparel and footwear, except under the derogations of Delegated Regulation (EU) 2026/296; medium-sized companies follow on 19 July 2030. That ban comes from ESPR itself, and large enterprises already disclose each year how many unsold products they discard and why, for all unsold consumer products, with a common reporting format from 2 March 2027. The Working Plan does not add bans for other products.

ESPR working plan timeline by product group

Each product group follows a staged process: adoption (the Commission adopts the delegated act, which is then published and enters into force) and application (when companies must comply). Obligations apply at least 18 months after a delegated act enters into force, subject to exceptions. For apparel, adoption of the textile act is planned for Q4 2027, so the first requirements, passports included, are likely around 2029.

Here is the plan with the Commission's latest timing. For each group: the working-plan year, the latest Commission timing, and the earliest obligation estimate. All dates are indicative, and the estimates are not deadlines.

• Iron and steel: working plan 2026; latest timing act Q4 2026; earliest obligations around 2028.
• Textiles and apparel: working plan 2027; latest timing act Q4 2027; earliest obligations passports around 2029.
• Tyres: working plan 2027; latest timing act Q3 to Q4 2027; earliest obligations around 2029.
• Aluminium: working plan 2027; latest timing act Q3 to Q4 2027; earliest obligations around 2029.
• Furniture: working plan 2028; latest timing act 2028; earliest obligations around 2030.
• Mattresses: working plan 2029; latest timing act 2029; earliest obligations around 2031.
• Repairability, including scoring (horizontal): working plan 2027; latest timing act 2027; earliest obligations around 2029.
• Recycled content and recyclability of electrical and electronic equipment (horizontal): working plan 2029; latest timing act 2029; earliest obligations around 2031.

Footwear is separate, with a study due by the end of 2027. Detergents, paints, lubricants and chemicals are not scheduled.

What to expect in 2027 and 2028

In 2027 the Commission plans to adopt the textile, tyre and aluminium acts; none of them is a company deadline. Two dates are fixed: battery passports from 18 February 2027 and the unsold-goods reporting format from 2 March 2027. In 2028 the plan gets its mid-term review.

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ESPR working plan: questions, answered

What is the ESPR working plan?

The Ecodesign and Energy Labelling Working Plan 2025 to 2030, adopted by the Commission on 16 April 2025, sets which product groups get ESPR delegated acts first and in what order. It is still the current plan and has not been formally revised.

Which products come first under the ESPR working plan?

Iron and steel, with the act expected in Q4 2026, then textiles and apparel in Q4 2027, tyres and aluminium in Q3 to Q4 2027, furniture in 2028 and mattresses in 2029. All of these dates are indicative, and no product delegated act has been adopted yet.

When do textiles need a Digital Product Passport?

Not yet. Adoption of the textile delegated act is planned for Q4 2027 (indicative), and obligations apply at least 18 months after it enters into force, so textile passports are likely around 2029 (estimate).

Does a working-plan year mean companies need a DPP that year?

No. It is the planned adoption year; requirements apply at least 18 months after the act enters into force.

Do the DPP standards set the product-specific data fields?

No. They cover how passports work; each product act sets its own fields.

Is the EU registry where the whole passport is hosted?

No. It holds identifiers and registration data, not the full passport.

Are unsold-goods reporting and the destruction ban the same obligation?

No. Reporting covers all unsold consumer products; the ban covers apparel and footwear.

Useful Resources

• Ecodesign and Energy Labelling Working Plan 2025 to 2030 (EUR-Lex)
• Commission rolls out plan to boost circular and efficient products in the EU
• Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030
• Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (EUR-Lex)