On 16 April, the European Commission published a Communication outlining the Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025 – 2030. This step marks the very first milestone in the implementation of the Ecodesign for Sustainable Products Regulation (ESPR), also known as Regulation (EU) 2024/1781.
The new ecodesign rules aim to boost the production, sales and consumption of sustainable products in the EU market. Thanks to new products requirements, better consumer information and new transparency obligations for businesses, products will improve in terms of circularity, energy performance, recyclability, durability, etc. But what exactly are the products concerned and how will the specific requirements be developed?
An overall clear product scope
Clarifying the scope of the rules is the very point of the Ecodesign for Sustainable Products and Energy Labelling Working Programme 2025-2030. The WP prioritises four final products (textiles/apparel, furniture, tyres, mattresses) and two intermediate products (iron & steel, aluminium). In line with the new approach to ecodesign rule-setting as defined by the ESPR, the WP also pinpoints two horizontal requirements (reparability, recycled content and recyclability) which will apply to more than one product category at the same time – one of which is already known, that is, electrical and electronic equipment. The WP also includes a list of energy-related products, which are carried over from the Ecodesign and Energy Labelling Working Plan. These notably include displays, EV chargers, washing machines, tumble dryers etc.
Each of the identified priority products will follow a specific procedure and timeline, although the final objective is common to all of them, meaning the adoption of a Delegated Act by the Commission. The year of delivery of the respective Delegated Acts ranges from 2026 (e.g., delegated act on household dishwashers) to 2030 (e.g., delegated act on mobile phones and tablets).
Procedures still to be defined (with some exceptions)
Regrettably, the WP does not provide clarity on procedural aspects of ecodesign rule-setting, that is, in which pre-existing or new regulatory framework the product-specific rules will be developed. There are some few exceptions, where working regulatory frameworks are up and running (e.g., textiles/apparel, displays). Furthermore, the WP does not further detail the Commission’s next steps to implement general exemptions from ecodesign requirements (e.g., for “products produced in very small quantities), nor does it touch upon the issue of imported second-hand products into the EU.
On the other hand, the Commission’s Communication describe so-called “key enablers” and “conditions for successful implementation”, which hint at the overarching priorities that the Commission will pursue while developing ecodesign requirements. For example, integrating the international dimension in the conception of ecodesign requirements will be crucial to make the new rules deliver. So will be a streamlined market surveillance framework, which will benefit from higher cooperation with the customs environment and support by the Commission, notably via the Ecodesign Forum. Here, the central role of the Digital Product Passport (DPP) as a tool allowing for information to flow across the supply chain up to the enforcers is underlined.
Next steps
Given the different procedures that each priority product group follows, timelines heavily depend on the specific product-related agenda. The textile/apparel workstream is currently advancing as a priority, with a Delegated Regulation introducing exemptions to the ban on the destruction of unsold apparel and footwear, expected on 19 July. Moreover, the implementation process is not limited to product-specific procedures but also includes horizontal rules. Most notably, the adoption of the Implementing Act setting out the details and format for the disclosure of the information on discarded unsold consumer products also due by 19 July. The Commission is expected to publish a Draft Implementing Regulation for stakeholders’ comments in the next few weeks.