ESPR working plan: Key products, timelines, and what manufacturers must know

The European Commission has officially adopted the Ecodesign for Sustainable Products Regulation (ESPR) working plan for 2025–2030, outlining the first wave of sustainability requirements that will reshape product design and market access in the EU. The construction sector, already navigating the revised Construction Products Regulation (CPR), must now prepare for a broader set of ecodesign rules affecting both materials and finished products.

Here’s what construction manufacturers need to know:

Prioritised products under ESPR: Focus areas for 2025–2030

Under the new ESPR working plan, the Commission has prioritised eight key product groups — four final products, two intermediate products, and two legal acts setting horizontal requirements.

Final products:

• Textiles/Apparel
• Furniture
• Tyres
• Mattresses

Intermediate products:

• Iron and steel 
• Aluminium

Horizontal measures:

• Repairability scoring applied across multiple product groups
• Requirements for recycled content and recyclability of electrical and electronic equipment
  
  

While ICT and energy-related products are not listed separately, many will be impacted through horizontal requirements or the transition of current ecodesign rules into the ESPR framework.

Energy-related products included in the first working plan

Products already regulated under the previous Ecodesign Directive (2009/125/EC) will transition to the ESPR, with reviews and new requirements still being developed. Some timelines for specific energy-related products are:

• Dishwashers: 2026
• EV chargers: 2028
• Fridges and freezers: 2028
• Electric motors: 2028
• Mobile phones and tablets: 2030

Footwear and chemicals

These are not included in the first working plan for specific requirements, but studies are underway to evaluate their potential inclusion in future ESPR plans. The study for footwear is expected to be completed by the end of 2027, and for chemicals by the end of 2025.

ESPR adoption timeline

The indicative adoption dates vary by product:

• Iron & steel: 2026
• Textiles (apparel) and tyres: 2027
• Furniture and aluminium: 2028
• Mattresses: 2029
• Horizontal requirements: Between 2027–2029
  
  

A mid-term review in 2028 will allow the Commission to adjust priorities and potentially include additional product groups based on new evidence and stakeholder feedback.

Requirements under the ESPR: What will be needed

Each prioritised product group will need to meet new ecodesign requirements that may include:

• Minimum durability and material efficiency thresholds
• Mandatory disclosure of sustainability data via a Digital Product Passport
• Enhanced requirements for recycled content and recyclability
• Repairability scores for certain consumer products
• Detailed carbon and environmental footprint data
  
  

For intermediate products like steel and aluminium, specific attention will be given to ensuring that upstream regulations do not negatively cascade into final product markets.

Conditions for successful implementation

The Commission recognises that the success of the ESPR hinges on several factors:

• Effective market surveillance: Member States must scale up enforcement efforts, particularly for online sales channels.
• Industry preparedness: Businesses will need to align their production and data collection practices with ESPR standards, supported by harmonised methodologies.
• International engagement: As the ESPR rules will also apply to imported goods, the Commission plans extensive outreach to trading partners.
• Support for SMEs: Special measures will be developed to ease the transition for smaller manufacturers, ensuring a level playing field across the Single Market.
  
  

Importantly, the upcoming digital product passport will act as a central tool to track sustainability information across supply chains, facilitating compliance and empowering greener consumer choices.

A first step towards a competitive and sustainable future

The ESPR was designed to improve the environmental sustainability of products placed on the EU market by cutting their carbon and environmental footprint across the entire life cycle. At the same time, it aims to enable the free movement of sustainable products within the internal market.

This first working plan marks a crucial milestone. The newly regulated final and intermediate products represent over EUR 1 trillion in annual EU sales — approximately EUR 600 billion in energy-related products and nearly EUR 500 billion in new product groups. Together, they account for a significant share of environmental impacts from EU consumption, driving around 31% of climate change impacts and 34% of fossil resource use.

By setting ambitious yet achievable goals, the ESPR working plan will help to advance the Clean Industrial Deal and the EU Competitiveness Compass, ensuring that manufacturing sectors can successfully combine global competitiveness with low-carbon and sustainable production. It also invites stakeholders across industries to engage in the rule-making process, building on the proven success of the ecodesign and energy labelling frameworks — and moving Europe closer to a more sustainable, circular economy.

How can manufacturers prepare for ESPR

To stay compliant and prepared, manufacturers should:

• Monitor updates from the European Commission regarding delegated acts
• Ensure all EPDs align with EN 15804+A2 to meet likely DPP requirements
• Follow guidance from standardization bodies such as CEN/TC 350
• Leverage digital tools for automated LCA and EPD compliance