Ecodesign for Sustainable Products Regulation: Workplan 2025-2030
The Ecodesign for Sustainable Products Regulation (ESPR) is a cornerstone of the EU’s sustainable product policy, replacing the Ecodesign Directive and expanding its scope to a broader range of products.
The EU Commission has issued its first ESPR Workplan, spanning 2025-2030 with a mid-term review in 2028, covering both the ESPR and the Energy Labelling Regulation (ELFR). This workplan outlines priorities and actions to make products more durable, reusable, upgradable, reparable, recyclable, and energy-efficient. For businesses manufacturing, selling, or trading affected products, understanding these changes is essential for compliance and maintaining market access.
ESPR Priority Products: What Businesses Need to Know
In the workplan, the following products and requirements have been prioritized:
Final Products:
Textiles and apparel (excluding footwear)
Furniture
Tires
Mattresses
Intermediary Products:
Iron and steel
Aluminum
Horizontal Requirements:
Repairability (including scoring), likely for consumer electronics and small household appliances
Recycled content and recyclability for electrical and electronic equipment
*valid for a wide range of products with similar characteristics on specific aspects where this is technically possible.
If your company deals with these products, you will need to comply with specific ecodesign requirements detailed in forthcoming delegated acts.
Products that are not included in the workplan below will be reassessed in 2028 during the 2028 mid-term review:
Detergents, paints and lubricants
Footwear
Chemicals
For energy-related products, of the 35 currently under the Ecodesign Directive, 19 will transition to the ESPR framework after 31 December 2026, adopting new requirements. The remaining 16 will be reviewed for further improvements within the 2025-2030 workplan. Businesses in these sectors should monitor updates to anticipate compliance needs.
Digital Product Passport: Preparing for Enhanced Traceability
The Digital Product Passport (DPP) is the key tool under the ESPR, designed to facilitate end-to-end product lifecycle management. It aims to do this through:
Ensuring traceability along the value chain after the product has been placed on the market, boosting the uptake of voluntary traceability solutions
Providing information on material composition and any substances of concern
Providing information on the safe use, recycling and disposal of the product.
Labelling Under ESPR: Ensuring Compliance and Transparency
The 2025-2030 workplan outlines labeling requirements under both ESPR and ELFR:
Existing energy labels will continue to be used for relevant energy-related products
For other products, the DPP will be used, potentially in combination with other labels governed by legislation, such as the Textile Labelling Regulation (under review)
The workplan confirms that labels must provide clear and trustworthy information on product features or performance, such as carbon footprint, water consumption, durability, repairability or recyclability.
Under the Empowering Consumers for the Green Transition Directive, the Commission is to establish a harmonized label for commercial guarantee of durability.
Preventing the Destruction of Unsold Goods
Effective 19 July 2026, the ESPR bans the destruction of unsold apparel and footwear (commodity codes 4203, 61, 62, 6504, 6505 for apparel/clothing accessories; 6401, 6402, 6403, 6404, 6405 for footwear). For affected companies, this requires:
Exploring alternatives like donation, recycling, or resale for unsold stock
Planning ahead to avoid penalties and support sustainability goals
While currently limited to these categories, additional products may be included later. Businesses across all sectors should consider sustainable inventory practices as a proactive measure.
Preparing Your Business for the ESPR
With delegated acts still pending, businesses can take proactive steps to ensure ESPR compliance:
Re-assess Product Design: Integrate ecodesign principles, such as sustainable materials or design for disassembly
Understand Product Composition: Document materials, components, and chemicals used
Map Your Supply Chain: Trace raw materials and components for transparency
Review Testing Protocols: Align with anticipated ecodesign standards
Plan for Unsold Inventory: Develop strategies like partnerships with charities or recycling firms
Evaluate Labels and Claims: Confirm they are clear, trustworthy, and substantiated
Stay informed about delegated acts, which will specify requirements and deadlines for your products. Engaging with industry associations or regulatory updates can keep you ahead. Compliance with ESPR also aligns with broader EU Green Deal and Circular Economy goals, enhancing your sustainability profile.
For more information on how QIMA can support contact us at info@qima.com.
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