The ESPR working plan 2025–2030, category by category: what is prioritised, when, and what it means for you

TL;DR

• The ESPR working plan 2025–2030, adopted by the Commission on 16 April 2025, lists the products the EU will regulate first under the Ecodesign for Sustainable Products Regulation: textiles, furniture, tyres, mattresses, iron and steel, aluminium, two horizontal measures and 16 energy-related products.
• Each entry carries an indicative adoption year, from 2026 for iron and steel to the end of 2030 for mobile phones and tablets. These are planning dates. A product group has no obligations until a delegated act is adopted, and that act normally applies at least 18 months after it enters into force.
• As of October 2026, no product-group delegated act has been adopted under the ESPR. The only delegated act supplementing it, Delegated Regulation (EU) 2026/296, deals with the destruction of unsold goods.

The ESPR working plan 2025–2030 is the Commission's list of the product groups it intends to regulate first under Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR), with an estimated date for each. It was adopted on 16 April 2025 as Communication COM(2025) 187 final, accompanied by Staff Working Document SWD(2025) 112. If your product is on it, a set of ecodesign requirements, and with them a Digital Product Passport, is being prepared for it. If your product is not on it, the Commission can still regulate it later.

This guide goes through the plan entry by entry: the indicative timing for each product group, what being prioritised means in law, and the steps between the plan and an obligation on your business. For the framework itself, see our guide to Regulation (EU) 2024/1781. Everything below is stated as of October 2026.

When does each part of the plan land?

The working plan gives an indicative year of adoption for each measure. It does not give application dates. Those are set in each delegated act, and Article 4(4) of the ESPR says an act's date of application shall not be earlier than 18 months from its entry into force, except in duly justified cases.

What does the working plan prioritise?

Article 18(5) of the ESPR told the Commission which product groups to prioritise in the first working plan: iron and steel; aluminium; textiles, in particular garments and footwear; furniture, including mattresses; tyres; detergents; paints; lubricants; chemicals; energy-related products; and information and communication technology products and other electronics. The same paragraph lets the Commission leave a group out or add one, provided it gives a justification in the plan.

The plan uses that discretion. In its own words, it includes "four final products, two intermediate products and two legal acts setting horizontal requirements", plus 16 energy-related products carried over from the 2022–2024 Ecodesign and Energy Labelling working plan.

The new product groups

The energy-related products carried over

The "DPP expected?" column comes from section 3.2 of the plan, which says that every product for which ecodesign measures are adopted "will have a digital product passport, except if there is an alternative digital system providing equivalent information", naming the European Product Registry for Energy Labelling (EPREL) as the example for products that carry an energy label. Article 7(2)(a) of the ESPR backs this up: information requirements in a delegated act must include, as a minimum, requirements related to the Digital Product Passport. "Yes, or EPREL" means the plan leaves open which of the two the act will use. The content of each passport is set in the act itself; our guide to DPP data requirements covers how that works.

Category by category: what the plan says

Textiles and apparel (2027)

Ranked first among final products. The plan points to product lifetime, material efficiency, water, waste, climate and energy, and says ESPR information requirements will work alongside the Textile Labelling Regulation, which is under review. Footwear has been split off: see below. Our guide to the product passport for textiles goes into the sector in detail.

Furniture (2028)

Ranked second. The plan's case rests on resource use, since producing and supplying materials is often the main source of furniture's impact. Article 18(5) named furniture and mattresses as one group; the plan gives them separate entries and years.

Tyres (2027)

Ranked third. The plan acknowledges that tyres are already regulated by other EU law, including the Tyre Labelling Regulation (EU) 2020/740, and targets recyclability, recycled content and the management of end-of-life tyres.

Mattresses (2029)

Ranked fourth. The focus is waste generation, lifetime extension and material efficiency. Mattresses are the latest of the four final products.

Iron and steel (2026)

The earliest entry in the plan, and the first intermediate product to be addressed under the ESPR. The plan links the measure to the green steel label announced in the Clean Industrial Deal and to existing instruments such as the EU ETS and CBAM. The Joint Research Centre runs the preparatory study for iron and steel, which published a draft report in March 2026 and held its second stakeholder consultation on 13 April 2026. That work includes a separate draft study on the content of a Digital Product Passport for iron and steel.

Aluminium (2027)

The plan highlights secondary material, recyclability and supply resilience, and again expects the measure to complement the EU ETS and CBAM.

For both metals, the plan flags a specific risk: rules on an intermediate product affect every final product made from it. The options it says will be assessed include setting only information requirements, and including selected final products with a high content of the intermediate product in the scope of the act. If you make finished goods from steel or aluminium, watch these two acts as well as the one for your own product group.

Horizontal measures (2027 and 2029)

Horizontal requirements apply one rule to many product groups that share a feature, under Article 5(7) of the ESPR. The plan includes two:

• Repairability, including scoring (2027). The scope will be refined in the preparatory study and "could include products such as consumer electronics and small household appliances".
• Recycled content and recyclability of electrical and electronic equipment (2029).

ICT products do not appear as their own entry. The plan says they are included in the first working plan through the work on these two horizontal measures, and some specific ICT products through the energy-related products.

Energy-related products (2026 to 2030)

These 16 items were carried over from the 2022–2024 Ecodesign and Energy Labelling working plan because preparatory work on most of them had begun. Most are reviews of existing rules. A further 19 energy-related products remain covered by the old Ecodesign Directive until 31 December 2026 under Article 79 of the ESPR, and are not in this list.

What did the plan leave out?

The plan explains why some Article 18(5) groups are not in it:

• Detergents, paints and lubricants: lower impacts and improvement potential than the selected final products, and less support in the public consultation.
• Footwear: treated as a separate category from textiles. A study on its potential under the ESPR will be completed by the end of 2027.
• Chemicals: highly ranked, but the scope is too complex to define yet. A study was to be launched by the end of 2025 to define it, for consideration in the review of this plan or a later one.

The plan also says the Commission will not use this first plan to propose new products for the ban on destroying unsold goods, because it first wants the data from the mandatory disclosure of destroyed products.

What does "prioritised" mean legally?

Less than many summaries suggest. The working plan is a Commission communication. It is required by Article 18(3), which asks for "a list of product groups which are to be prioritised for the setting of ecodesign requirements and the estimated timelines for their setting", covering at least three years and regularly updated. It sets no requirement for any product.

Three points follow from the Regulation itself:

1. Obligations only come from a delegated act. Article 4 empowers the Commission to set ecodesign requirements by delegated act, and Article 8 lists what each act must contain.
2. The timelines are estimates. Article 18(3) speaks of "estimated timelines", and the plan calls them "indicative". The plan has a mid-term review in 2028, and Article 18(7) requires the Commission to report annually to the European Parliament and the Council on progress.
3. Being left out is no protection. Article 5(6) lets the Commission set ecodesign requirements for product groups that are not in the working plan.

What steps sit between the plan and an obligation?

For each product group, the route from the plan to a duty on your business runs through the following steps.

The preparatory study is where a business can still shape the outcome.

Where does the plan stand as of October 2026?

As of October 2026, EUR-Lex lists only one delegated act supplementing the ESPR: Delegated Regulation (EU) 2026/296 of 9 February 2026, which sets out derogations from the ban on destroying unsold consumer products and applies from 19 July 2026. No delegated act setting ecodesign or Digital Product Passport requirements for any product group in the working plan has been adopted.

Iron and steel, the only new group with a 2026 indicative date, is at the preparatory study stage described above. Six energy-related entries also carry a 2026 date. The remaining groups are scheduled for 2027 or later.

Batteries are outside the working plan. Their passport comes from Regulation (EU) 2023/1542 and applies from 18 February 2027.

Where a QR code fits, and where it does not yet

For every group in the plan, the data carrier and its placement will be chosen in the delegated act, under Article 9(2) of the ESPR. Nothing in the working plan specifies one, and no act has been adopted, so there is no carrier you are obliged to print today for furniture, tyres, mattresses or steel.

What is already fixed is Article 10: the passport must be connected through a data carrier to a persistent unique product identifier, using open standards. A GS1 Digital Link QR code meets that structure, since it encodes a product identifier in a web address that resolves to the passport. Work on identifiers and product data carries over to whichever act applies. Passport level, data fields and access rights have to wait for the act.

What to do now

1. Find your product groups in the tables above, including the steel or aluminium in what you make.
2. Note the indicative adoption year and add the application gap. Under Article 4(4), obligations normally start at least 18 months after an act enters into force.
3. Follow the preparatory study for your group and register as a stakeholder. Draft reports and stakeholder meetings are where requirements take shape.
4. Check whether your product carries an energy label. If it does, the plan expects EPREL to remain the main information channel unless the act decides otherwise.
5. Confirm your role. The working plan says nothing about who does what; that is in Chapter VII of the ESPR, covered in our guide to who is responsible for the Digital Product Passport.
6. Start on identifiers and data, because Article 10's requirements do not depend on the sector.
7. Re-check after the 2028 mid-term review.

Digital Link is a GS1 solution partner, and our platform builds standards-based product passports: a persistent identifier per product, a GS1 Digital Link QR code as the data carrier, and a page behind it that can be updated without reprinting packaging. When the delegated act for your product group is adopted, the same code can carry the passport it requires. If you want to know where your products sit in the working plan and what that means for your timeline, get in touch and our legal team will review your case.

Frequently asked questions

What is the ESPR working plan 2025–2030?

It is Commission communication COM(2025) 187 final, adopted on 16 April 2025 under Article 18 of Regulation (EU) 2024/1781. It lists the product groups and horizontal measures prioritised for ecodesign requirements up to 2030, each with an indicative adoption year.

Which products are in the ESPR working plan?

Four final products (textiles and apparel, furniture, tyres, mattresses), two intermediate products (iron and steel, aluminium), two horizontal measures (repairability, and recycled content and recyclability of electrical and electronic equipment), and 16 energy-related products carried over from the 2022–2024 plan, from dishwashers to mobile phones and tablets.

Does a product on the working plan already need a Digital Product Passport?

No. The plan sets no requirement. A passport becomes mandatory for a product group only when a delegated act under Article 4 of the ESPR is adopted and its application date arrives, normally at least 18 months after the act enters into force.

When will furniture and mattresses need a Digital Product Passport?

The plan gives an indicative adoption year of 2028 for furniture and 2029 for mattresses. Application dates will be set in the delegated acts and will normally fall at least 18 months after each act enters into force, so obligations come later than those years.

Has any ESPR delegated act been adopted yet?

One, and it is not about a product group. As of October 2026, Delegated Regulation (EU) 2026/296, on derogations from the ban on destroying unsold consumer products, is the only delegated act supplementing the ESPR listed on EUR-Lex.

Can the dates in the working plan change?

Yes. The plan calls its timelines indicative, Article 18(3) requires it to be regularly updated, and the plan schedules a mid-term review in 2028. The binding date is always the one in the delegated act for your product group.