The ESPR Working Plan: What You Need To Know

The ESPR Working Plan is the latest step towards fully operationalising the Ecodesign for Sustainable Products Regulation (ESPR).

Officially adopted by the European Commission on 16^th April 2025, the ESPR Working Plan sets out in detail which products will be regulated first by the ESPR, the timeline for the regulation of these products, and further details of the regulation, as well as aiming to reduce the complexity of compliance and the regulatory burden.

Additionally, it includes updates to the adjacent Energy‑Labelling Framework Regulation (ELFR) and helps to confirm the ways that these two regulations will complement each other to assist both consumers and organisations in achieving their sustainability goals.

This article dives into the ESPR Working Plan – if you’re unfamiliar with the ESPR, please read ‘What is the Ecodesign for Sustainable Products Regulation (ESPR)?’.

What are the priority product categories set out in the ESPR Working Plan?

The main point of this communication is the clarification of product categories that will be regulated. Whilst the ESPR’s original text does set out a broad scope, the Working Plan confirms the prioritised product categories, regulatory deadlines, and reasoning for choosing these specific products.

These priority product categories were chosen via a Joint Research Centre (JRC) screening, a public consultation in 2023, and the Ecodesign Forum that took place in February 2025.

Ranking various products by market size, impact, and potential for improvement, these three events resulted in four final product groups, two intermediate product categories, and two distinct horizontal requirements.

End User Product Groups

Even though they were included in the priority list in the ESPR initially, several products have been excluded from this ESPR Working Plan (2025) for various reasons.

Chemicals

• Highly complex and has overlap (e.g petrochemicals, polymers, speciality chemicals and plastics)
• Further study is needed to define Chemicals as a product group, due to be launched by the end of 2025

Detergents, Paints, Lubricants

• Has been determined that these product categories have lower environmental impact and improvement potential than products selected in this working plan
• Still governed by various other product-specific sustainability legislation, such as the EU Detergent Regulation.

Footwear

• Marked as separate from Textiles due to more complex components, supply chains, and functionality
• Initially determined that Footwear has a lower environmental impact, however a new study will be commissioned and completed by the end of 2027 to reprioritise this product group appropriately

Intermediate Products

Horizontal Requirements

In addition to specifying priority product categories, the ESPR Working Plan also expresses which of the ESPR’s horizontal requirements are to take priority.

The original text of the ESPR included the possibility to apply ecodesign requirements ‘horizontally’ when several product groups share similar attributes, and those specific requirements could vastly increase efficiency in implementing the regulation.

The horizontal ecodesign requirements prioritised in the ESPR Working Plan are:

Repairability, including scoring (2027) – “High potential for improvement; depending on the scope of the measure and coverage of resource use, increased circularity for (critical) raw materials, climate change, and targeted requirements on durability (reliability) could also be included. The scope, to be refined during the preparatory study, could include products such as consumer electronics and small household appliances.”

Recycled content and recyclability of electrical and electronic equipment (2029) – “High potential for improvement, depending on the exact scope of the measure and coverage of resource use, increased circularity for (critical) raw materials, climate change and waste prevention.”

Energy-Related Products

In future, energy-related products, including those already regulated under the Ecodesign Directive, will be regulated under the ESPR. The previous Ecodesign and Energy Labelling Working Plan (2022-2024) covered 35 of these products, giving 19 of them a transition period of up to 31^st December 2026, including:

1. Photovoltaic panels
2. Space and combination heaters
3. Water heaters
4. Solid fuel local space heaters
5. Air conditioners including air-to-air heat pumps and comfort fans
6. Solid fuel boilers
7. Air heating and cooling products
8. Ventilation units
9. Vacuum cleaners
10. Cooking appliances
11. Water pumps
12. Industrial fans
13. Circulators
14. External power supplies
15. Computers
16. Servers and data storage products
17. Power transformers
18. Professional refrigeration equipment
19. Imaging equipment.

The other 16 product categories have been carried forward to this most recent ESPR working plan, citing efficiency reasons. These include:

Key Implementation Enablers of the ESPR

The ESPR Working Plan reinforces the key pillars that will aid in the implementation of the ESPR legislation.

Digital Product Passports

Digital Product Passports form the informational backbone of the ESPR, helping to open up access to product sustainability data on a need-to-know basis for consumers, business, public authorities, and regulators.

The ESPR states that every regulated product will be required to carry a DPP within it. However, the ESPR Working Plan clarifies that this is the case except where there is an alternative digital system in place that provides equivalent information like, for example, the EPREL database for energy-related products and their labels.

The ESPR Working Plan also states that the standardisation process has been started for various aspects of the Digital Product Passport that were previously unclear – namely, the data carrier to be used, and the infrastructure required for optimum efficiency and interoperability.

This will help to ensure product traceability of products as they progress throughout the value chain and facilitate end-to-end product lifecycle management.

International Outreach and Market Surveillance

The effects and potential difficulties of implementing the ESPR, especially regarding suppliers selling into the EU, have been well documented.

The European Commission aims to “ensure a proportionate, systematic and high-quality assessment of international dimensions in the preparatory studies and impact assessments”.

The ESPR Working Plan reinforces the EU’s commitment to research and improvements to the legislation to make it more friendly towards third-country suppliers and the EU’s commitment to maintaining frictionless trade within the bloc.

This will be done through cooperation with member states on market surveillance (e.g EEPLIANT4), digital customs links, and Ecodesign Forums to monitor enforcement and tackle an estimated 10% non-compliance gap.

What’s next for the ESPR?

There are still several milestones to reach on the road towards full ESPR implementation. Importantly, the first public consultation to determine the Delegated Acts for the ESPR is expected to take place in Late 2025 – Early 2026.

The first formal delegated acts are due to be released for key sectors such as Textiles, Steel, and Furniture in Early 2027, followed by the official implementation deadline for the Batteries industry in February of the same year.

These acts will specify the exact ecodesign requirements per product group. This is especially important in the implementation of Digital Product Passports as the Delegated Acts will determine which data points will need to be included for each product.

There will be a mid-term implementation review in 2028, which will help to steer the legislation as per market realities to give businesses stability in their preparations for compliance, as well as adding deadline dates for any previously deprioritised industries.

Expected Impacts By 2030

The European Commission has made efforts to calculate the expected impacts that the ESPR and Energy Labelling Regulation will have across the region by the year 2030. Those are:

Households: extra € 473‑736 saved per year on energy bills.

Industry: over € 1 trillion of annual EU sales will face clearer, single‑market rules; first‑movers in “green steel”, aluminium recycling, repair services and traceability tech gain advantage.

Environment: maintains 145 Mt CO₂ annual reductions from legacy Ecodesign and expands savings to material footprints, covering 31 % of climate impacts and 34 % of fossil‑resource use in the EU consumption basket.

Jobs & Competitiveness: builds on the 346,000 jobs created by earlier Ecodesign rules and dovetails with the 2025 Clean Industrial Deal, Competitiveness Compass, and upcoming Circular Economy Act.

What can businesses do to prepare?

As Digital Product Passports will be one of the key drivers of the ESPR legislation, this should be one of the top priorities for businesses when preparing for ESPR compliance.

Depending on the size of the company and the degree of product coverage set out for their industry via the ESPR, certain businesses may have hundreds, if not thousands, of data points they’ll need to map out. Therefore, businesses should start mapping their product data right away.

Read Protokol’s preparation guide for DPPs to find out how to give your business the competitive edge, or visit our Digital Product Passport Consulting page for more information on our services.