ESPR Working Plan 2025-2030: Which Products Are Prioritized and When

On 16 April 2025, the European Commission adopted the First Working Plan under the Ecodesign for Sustainable Products Regulation (ESPR). This landmark document defines which product categories will be subject to DPP and ecodesign requirements, when their respective Delegated Acts will be adopted, and what specific environmental parameters will be regulated. For businesses operating in or exporting to the EU, this plan is the authoritative roadmap for regulatory compliance between now and 2030.

The Working Plan identifies 11 priority product categories, organized into three groups: final products, intermediate products, and horizontal requirements that cut across multiple categories. This article provides a comprehensive, data-driven analysis of each category, including market sizes, timelines, and the specific parameters being regulated.

The Three-Tier Prioritization Framework

The European Commission applied a structured methodology to prioritize product categories, based on:

1. Environmental impact: Contribution to EU climate, resource consumption, and waste generation
2. Improvement potential: The degree to which ecodesign requirements could reduce environmental impact without disproportionate cost
3. Cross-category relevance: Whether the category enables circularity improvements in other product groups

The result is a phased implementation schedule spanning 2026 to 2030, with the highest-impact categories receiving Delegated Acts first.

2026                 2027                 2028                 2029                 2030
  |                    |                    |                    |                    |
Textiles & Apparel     Tyres                Furniture            Mattresses           Mobile Phones
Iron & Steel                                Aluminium                                  & Tablets
Household Appliances   Repairability                             Recycled Content
                       (Horizontal)                              (EEE, Horizontal)
                                          EV Chargers
                                          Displays

Group 1: Final Products

1. Textiles and Apparel

Market size: Approximately €175 billion (EU textile and clothing market, 2024 estimate)

Delegated Act timeline: End of 2026 / early 2027

Why prioritized: Textiles are the fourth-highest-impact product category for primary raw material and water use, and the fifth-highest for greenhouse gas emissions, according to the European Environment Agency. Current recycling rates are abysmal—less than 1% of textile waste is recycled into new fiber, with the vast majority incinerated or landfilled.

Key parameters under regulation:

• Material composition (fiber-level, weight-percentage precision)
• Durability (tensile strength, color fastness, pilling resistance)
• Recycled content verification (GRS-equivalent chain of custody)
• Chemical safety (REACH SVHC declarations, ZDHC MRSL compliance)
• Repairability (availability of spare parts, design for disassembly)
• End-of-life instructions (disassembly, fiber separation, recycling pathways)
• Microplastic shedding (synthetic textiles—methodology under development)

[!WARNING]

Textiles are first for a reason. The European Commission has explicitly identified this sector as having one of the worst environmental footprints relative to its economic size. The textile Delegated Act will be the most comprehensive and demanding of all ESPR product regulations. Brands in this sector have the least time and the most requirements.

2. Furniture

Market size: Approximately €140 billion (EU furniture market)

Delegated Act timeline: 2028

Why prioritized: Furniture is the second most impactful final product category in terms of circular economy potential. The EU furniture market generates approximately 10 million tonnes of waste annually, with recycling rates below 20%. The sector has substantial opportunity for durability improvements, repair service infrastructure, and material recyclability.

Key parameters under regulation:

• Durability and structural integrity standards
• Repairability (availability of components, assembly/disassembly design)
• Material composition and chemical safety (formaldehyde emissions, flame retardants)
• Recycled content (wood, metal, foam)
• Recyclability and end-of-life disassembly instructions

3. Tyres

Market size: Approximately €45 billion (EU tyre market)

Delegated Act timeline: 2027

Why prioritized: Tyres are a major source of microplastic pollution (accounting for an estimated 28% of primary microplastics released into oceans, according to IUCN data) and have significant energy-efficiency implications for vehicles. The existing EU tyre labelling regulation provides a foundation of data infrastructure that can be extended to DPP requirements.

Key parameters under regulation:

• Rolling resistance (energy efficiency)
• Wet grip (safety)
• External rolling noise
• Abrasion rate (microplastic emissions)
• Material composition and recycled content
• End-of-life collection and recycling pathways

4. Mattresses

Market size: Approximately €10 billion (EU mattress market)

Delegated Act timeline: 2029

Why prioritized: Mattresses represent one of the most challenging waste streams—bulky, difficult to transport, and composed of complex multi-material layers (foam, springs, fabric, adhesives). EU mattress waste exceeds 30 million units annually, with recycling rates below 15% in most Member States.

Key parameters under regulation:

• Durability (compression set, sag resistance)
• Disassembly design (separable layers for recycling)
• Material composition (foam type, metal content, textile covers)
• Chemical safety (flame retardants, VOCs)
• Recycled content verification

Group 2: Intermediate Products

5. Iron and Steel

Market size: Approximately €152 billion (EU iron and steel market)

Delegated Act timeline: End of 2026 / early 2027

Why prioritized: Iron and steel production accounts for approximately 5% of EU CO2 emissions and is the largest industrial energy consumer. As an intermediate product, steel enters virtually every manufacturing supply chain—automotive, construction, machinery, appliances—so transparency in this category enables circularity improvements across multiple downstream sectors.

Key parameters under regulation:

• Recycled content percentage (scrap input ratio)
• Carbon footprint (CO2 per tonne of steel produced)
• Energy consumption in production
• Material grade and composition declarations
• Origin of raw materials (virgin vs. recycled feedstock)

6. Aluminium

Market size: Approximately €40 billion (EU aluminium market)

Delegated Act timeline: 2028

Why prioritized: Aluminium is the second most-used metal globally and has one of the highest recycling potentials—recycling aluminium requires only 5% of the energy needed for primary production. However, alloy mixing and contamination reduce effective recycling rates. Standardized material declarations can significantly improve circularity.

Key parameters under regulation:

• Recycled content (pre-consumer and post-consumer)
• Carbon footprint (smelting energy source, electrolysis technology)
• Alloy composition and grade declarations
• Origin certification (primary vs. secondary aluminium)

Group 3: Horizontal Requirements (Cross-Cutting)

7. Repairability Scoring (Consumer Electronics and Other Durable Goods)

Delegated Act timeline: 2027

Why prioritized: The EU has identified premature obsolescence and lack of repairability as major drivers of electronic waste—the fastest-growing waste stream in the EU, exceeding 12 million tonnes annually. A standardized repairability scoring system will apply across multiple product categories, beginning with consumer electronics.

Key parameters under regulation:

• Availability and pricing of spare parts (minimum availability period: 7–10 years)
• Ease of disassembly (tool requirements, assembly methods)
• Access to repair documentation and software/firmware updates
• Repairability index score (0–10 scale, visible at point of sale)
• Battery replaceability (for portable devices)

8. Recycled Content and Recyclability for Electrical and Electronic Equipment (EEE)

Delegated Act timeline: 2029

Why prioritized: EEE products contain high-value materials (precious metals, rare earth elements, high-grade plastics) but suffer from abysmal recycling rates—only 42.5% of e-waste is collected and recycled in the EU, and the actual material recovery rate is far lower. Mandatory recycled content requirements aim to create demand-pull for secondary raw materials.

Key parameters under regulation:

• Minimum recycled content percentage (plastic, metal fractions)
• Recyclability scoring (design for disassembly, material separation)
• Hazardous substance declarations (RoHS, REACH)
• Modular design requirements (upgradeability without full replacement)

Group 4: Energy-Related Products (Carried Over from Existing Ecodesign)

9. Household Appliances

Delegated Act timeline: 2026

Market significance: Existing ecodesign requirements for washing machines, dishwashers, refrigerators, and other white goods will be updated and extended to include DPP data carriers and circularity parameters.

Key updates from existing legislation:

• Addition of DPP data carrier requirements
• Extension of durability testing standards
• Recycled content declarations
• End-of-life disassembly and recycling instructions

10. Displays (Televisions, Monitors, Digital Signage)

Delegated Act timeline: 2027

Key parameters:

• Energy efficiency thresholds (updated from existing ecodesign)
• Repairability and spare parts availability
• Recycled content (plastics, metals)
• Mercury and hazardous substance declarations
• Software update and security support duration

11. Mobile Phones and Tablets

Delegated Act timeline: 2030

Key parameters:

• Battery durability (charge cycle rating)
• Battery replaceability (user-serviceable design)
• Repairability scoring (spare parts availability, 7-year minimum)
• Software update and security patch commitments (5-year minimum)
• Recycled content (rare earth elements, plastics, metals)
• Drop and water resistance durability testing

12. Electric Vehicle Chargers

Delegated Act timeline: 2028

Key parameters:

• Energy efficiency in standby and active modes
• Interoperability and communication protocol standards
• Durability and weather resistance (outdoor installations)
• Recycled content and end-of-life recyclability

Products Explicitly Omitted from the First Working Plan

Not all products identified during the Commission’s scoping phase made it into the first Working Plan. Several categories were deferred for further study or deprioritized based on environmental impact assessment:

The Mid-Term Review: 2028

The ESPR requires the Commission to review the Working Plan at least every three years. A mid-term review is scheduled for 2028, which will:

1. Assess progress on the first-wave Delegated Acts (textiles, iron and steel, tyres)
2. Incorporate updated environmental impact data
3. Evaluate the effectiveness of enforcement mechanisms
4. Potentially add new product categories based on evolving scientific evidence
5. Adjust timelines based on implementation experience

Products deferred from the first Working Plan (footwear, chemicals, detergents) are strong candidates for inclusion in the second Working Plan, anticipated in 2028–2029.

Complete Priority Product Summary Table

Actionable Takeaways

1. Know your Delegated Act date. If your products fall into one of the 11 priority categories, mark the Delegated Act timeline in your compliance calendar. Textiles (end 2026) have the shortest runway.
2. Monitor the Working Plan revisions. The Commission will issue updated plans, including the 2028 mid-term review. Products currently omitted may be added. Subscribe to Commission notifications or work through your trade association.
3. Prepare for horizontal requirements. Even if your specific product category has a later Delegated Act (e.g., mattresses in 2029), horizontal requirements (repairability, recycled content for EEE) may apply earlier.
4. Do not assume sequential implementation. Multiple Delegated Acts are being developed in parallel by different Commission teams. The adoption order may shift. Stay engaged with the legislative process.
5. Begin data infrastructure today. The specific parameters will be refined through the Delegated Act process, but the fundamental data architecture—GTINs, JSON-LD schemas, supply chain mapping—is consistent across all categories. Building this infrastructure now serves all future product-category requirements.

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📚 Regulatory & Academic Bibliography

• European Commission - ESPR Guidelines: Official EUR-Lex circular economy directives and delegated acts.
• GS1 Global Standards Registry: Technical specifications for GTIN-14 and resolver architectures.
• W3C Verifiable Credentials Core 2.0: Cryptographic verification protocols and JSON-LD syntax rules.
• ISO Quality Management Systems Catalog: Forensic laboratory and testing competence requirements (ISO 17025).