July 25, 2025
The European Commission has released a five-year working plan to continue implementing the Ecodesign for Sustainable Products Regulation (ESPR) and Energy Labelling Regulation. The ESPR was adopted in July 2024 to improve circularity and reduce unnecessary waste. It establishes a framework allowing lawmakers to set ecodesign requirements for specific product groups, with priority given to highly impactful products.
The latest working plan identifies the high impact product categories that will need to adopt the ecodesign and energy labelling requirements first. These include mandates to address several key areas, such as product durability, reusability, upgradability, and repairability; the presence of chemical substances that inhibit reuse and recycling of materials; energy and resource efficiency; the use of recycled content; and carbon and environmental footprints.
The Commission notes that its working plan, which covers 2025 through 2030, “will foster sustainable, repairable, circular, and energy efficient products across Europe.” It also aligns with the Competitiveness Compass that aims to close the EU’s competitiveness gap on the global stage.
Details of the plan
Steel and aluminium, furniture, tyres, mattresses, and textiles, especially apparel, are among the priority product groups in the Commission’s strategy. This initial list of products was selected based on an extensive process with a variety of stakeholders and Member States, as well as thorough technical analysis and an in-depth consultation process. The draft working plan initially included chemicals, plastics, and footwear, but those products were removed before the final plan was published.
According to the Commission, harmonised product sustainability requirements at the EU level will achieve several key goals, including:
- Reinforcing the EU single market
- Preventing trade barriers
- Levelling the playing field to operate in or import to the EU
- Reducing the administrative burden of compliance with EU and Member State-specific rules
- Strengthening the global competitiveness of businesses that offer sustainable products
Two factors are at the centre of the new requirements. First is product performance, which may include minimum durability, minimum energy and resource-efficiency, and availability of spare parts or minimum recycled content for a product.
The second factor is product information, specifically related to key product features like carbon and environmental footprint. This information will be made available either through a Digital Product Passport (DPP) or the European Product Registry for Energy Labelling (EPREL) for products that have an energy label.
Looking ahead
The Commission plans to set out the ecodesign and energy labelling requirements through delegated acts, either on a product-by-product basis or for groups of similar products. These acts will be informed by a thorough process involving preparatory studies and impact assessments, as well as input from stakeholders through the Ecodesign Forum and other avenues.
Manufacturers who produce products listed in the Commission’s working plan should follow development of the delegated acts closely and engage in the stakeholder process to ensure the industry’s voice is heard. They should also begin preparing for more onerous ecodesign and energy labelling requirements. Across industries, businesses should prepare for EU lawmakers to continue their focus on sustainability and to advance new regulations in pursuit of a circular economy and promoting economic growth.
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