The way Europe looks at products is fundamentally changing. With the Ecodesign for Sustainable Products Regulation (ESPR), the European Union is setting new requirements for virtually all physical products entering the European market. From textiles to furniture, batteries to electronics, products must become more sustainable, repairable and recyclable. In April 2025, the European Commission published the Working Plan 2025-2030, outlining which product groups are first in line.
What is the ESPR and what does it have to do with ecodesign?
The ESPR is the successor to the 2009 Ecodesign Directive, which focused primarily on energy consumption of appliances. The new regulation goes much further. Where the old directive required, for example, that a washing machine be more energy efficient, the ESPR looks at the full life cycle: what materials are in it, how long does the product last, can it be repaired, and what happens at the end of its life?
The regulation entered into force in July 2024 and will be rolled out incrementally over the next few years through so-called delegated acts (“delegated acts”). These will lay down specific requirements for each product group.
The seven pillars of the ESPR
The ESPR rests on seven main elements that together create a new playing field for producers and importers:
- EU-wide ecodesign requirements for almost all physical products, focusing on durability, repairability, recyclability and the presence of harmful substances.
- The Digital Product Passport (DPP) becomes mandatory: a digital file that makes information about a product accessible throughout its life cycle.
- Stricter rules around Substances of Concern and mandatory transparency on material composition.
- Ban on destruction of unsold goods, which will apply first to textiles and footwear.
- Mandatory Green Public Procurement criteria, requiring governments to weigh sustainability more heavily in tenders.
- Stricter market surveillance and CE enforcement to ensure compliance.
- New EU sustainability labels to give consumers reliable information.
Which product groups are up first?
The Working Plan 2025-2030 provides clarity on priorities. The European Commission selected product groups based on their environmental impact, potential for improvement and economic relevance.
- Iron and steel top the list, with delegated acts expected in 2026. These are resource- and energy-intensive sectors where large environmental gains can be made.
- Aluminum will follow in 2027, also because of the high energy intensity of production.
- Textiles and apparel will face the first requirements in 2027-2028. This is a sector where the ESPR is going to change a lot: from material composition to reparability, and from the ban on destruction of unsold stock to mandatory product passports. For textiles, more than 100 data points are expected in the DPP.
- Furniture is planned for 2028. Here the main concerns are life extension, repairability and the use of recycled materials.
- Mattresses will follow in 2029, with similar requirements around sustainability and recyclability.
- Tires face new requirements in 2027, building on existing regulations around fuel efficiency and noise.
- Energy-related products such as heating appliances, air conditioning and lighting will be included between 2026 and 2028, as an extension of the existing Ecodesign Directive.
- ICT and electronics are scheduled for 2028-2030. Here in particular, repairability plays a major role, as does the availability of software updates and spare parts.
It is notable that a number of product groups are not yet included in the first wave of ESPR. Footwear, detergents, paints, lubricants and chemicals have not been prioritized for early delegated acts in the current Working Plan and will be investigated further first
What does this mean for your organization?
Phased implementation gives organizations time to prepare, but that time is more limited than it seems. There is typically 18 months to two years between publication of delegated acts and actual implementation. For textiles, this means that companies that must comply in 2028 should start preparing now.
The impact extends beyond the directly regulated sectors. Suppliers of materials and components face information requests from their customers. Indeed, producers need data on material composition, origin and environmental footprint to meet DPP requirements. A life cycle analysis can help gather the necessary environmental data.
For organizations already working on circular strategies, the ESPR is primarily a confirmation of the path already taken. The regulation enforces exactly the things that forerunners are already doing: designing for longer lifespans, enabling repairability, and making material flows transparent.
Start preparing now
The ESPR calls for a different way of thinking about products. Not just looking at functionality and price, but what happens when the product breaks down or comes to the end of its life. Organizations that start this early build knowledge and systems that will make a difference later.
A practical first step is to map out your product portfolio: which products fall under which product group, and when do the requirements take effect? From there, you can determine where the biggest adjustments are needed and where your data is still missing.
Want to know how your organization can prepare for the ESPR? Contact us for a no-obligation discussion about the impact on your product portfolio.