EU: Product categories under ESPR finally announced.

 

The EU Commission has finally announced the prioritized product groups under the Ecodesign for Sustainable Products Regulation (ESPR) in its working plan for 2025-2030.

The Ecodesign for Sustainable Products Regulation (ESPR) provides the legal basis for establishing ecodesign requirements. Alongside the Energy Labelling Framework Regulation (ELFR), it aims to support informed consumer choices and promote the adoption of more sustainable and energy-efficient products. The European Commission has now published a Communication outlining which products will be prioritised for action under the ESPR and ELFR through to 2030.

The ESPR sets out criteria for selecting products to be included in working plans, which must cover a minimum of three years. Product inclusion is based on their potential to advance the EU’s climate, environmental, and energy efficiency goals. Additional considerations include existing regulatory gaps, variation in product performance, sales and trade volume, environmental impact throughout the value chain, and the need to update existing requirements.

For the first working plan, the list of priority products is defined directly in the Regulation (Article 18). These include: iron and steel; aluminium; textiles (particularly garments and footwear); furniture (including mattresses); tyres; detergents; paints; lubricants; chemicals; energy-related products; and ICT and other electronics. However, the Regulation allows the Commission to adjust this list—either by omitting certain products or adding new ones—provided a clear justification is given.

The working plan also identifies products to be prioritised for energy labelling in line with the ELFR. This includes updating and rescaling older labels to keep pace with market and technological developments.

To align with the duration of the current Commission and Parliament mandates and to provide greater predictability for businesses, the Commission is proposing a five-year ESPR and energy labelling working plan covering 2025 to 2030, with a mid-term review scheduled for 2028.

The products/aspects to be included in the working plan are:

Product / aspect	Improvement potential	Year of adoption
Textiles/Apparel	High potential to improve product lifetime extension, material efficiency and to reduce impacts on water, waste generation, climate change and energy consumption. Information requirements under the ESPR will work in synergy with the Textile Labelling Regulation, currently under review	2027
Furniture	High potential to improve aspects of resource use, with impacts of production and supply of materials often being the main contributor across different environmental impact categories (e.g. climate change, acidification, eutrophication), and waste generation. Positive impact on other categories such as air, soil and biodiversity.	2028
Tyres	Though already regulated by other pieces of EU legislation (including the Tyre Labelling Regulation (EU) 2020/740), potential to improve recyclability and recycled content and to mitigate risks related to waste management of end-of-life tyres	2027
Mattresses	High potential to improve waste generation, lifetime extension and material efficiency	2029
Iron & Steel	High potential to improve the impacts on climate change, energy consumption, water, air and to boost the EU’s resilience, strategic autonomy and technological innovation. Measures under the ESPR will complement the green steel label announced in the Clean Industrial Deal as well as existing environmental and climate measures on steel products and production such as the ETS and CBAM.	2026
Aluminium	Potential to improve effects on climate change, energy consumption, air, water, biodiversity, soil pollution and raw materials. Incorporating secondary materials during manufacturing can reduce greenhouse gas emissions by up to 11 times. Aluminium is one of the metals with the highest potential for recyclability and for increasing EU supply resilience. Measures under ESPR are expected to complement existing environmental and climate measures on aluminium products and production such as ETS and CBAM.	2027
Repairability	High potential for improvement; depending on the scope of the measure and coverage of resource use, increased circularity for (critical) raw materials, climate change, and targeted requirements on durability (reliability) could also be included. The scope, to be refined during the preparatory study, could include products such as consumer electronics and small household appliances.	2027
Recycled content and recyclability of electrical and electronic equipment	High potential for improvement, depending on the exact scope of the measure and coverage of resource use, increased circularity for (critical) raw materials, climate change and waste prevention.	2029

 

Products not included in the first working plan:

Based on the assessment methodology mentioned earlier, the availability of resources, and the justifications provided below, certain products listed in Article 18 of the ESPR have not been included in the initial ESPR working plan. However, it is proposed that work begin on some of these products through preliminary studies, with the findings to be reassessed during the mid-term review after three years.

For detergents, paints, and lubricants, the JRC study on new product priorities indicates that these groups have relatively lower environmental impacts and limited improvement potential compared to the final products included in the working plan. Additionally, the public consultation revealed a comparatively lower level of support for prioritising these products.

Although footwear is categorised separately from textiles due to differences in material composition, product function, and supply chains, it also exhibits lower impacts than the selected priority products. Nonetheless, because of the environmental implications and the potential to apply ecodesign criteria for eco-modulating extended producer responsibility fees under the Waste Framework Directive, a study will be launched during the implementation of this working plan. The goal is to assess the potential for improving the environmental sustainability of footwear under the ESPR, with results expected by the end of 2027.

The chemicals product group was identified in the JRC study as having both high environmental impacts and strong potential for improvement. This was also echoed in public consultation feedback, which supported including chemicals in the plan. However, the group is particularly complex. The JRC study focused on large-volume organic and inorganic chemicals as intermediate products, whereas the broader chemicals category includes petrochemicals, polymers, specialty chemicals, and plastics—making it difficult to define a clear scope. To address this, a study will be initiated by the end of 2025 to more precisely identify which chemicals could fall under the ESPR, and to explore specific product aspects that may be targeted in future delegated acts. These findings will inform either a revision of the current working plan or the development of a subsequent one.

Information on all parts of the value chain: the digital product passport

A central component of the ESPR is the introduction of the digital product passport. All products subject to ecodesign measures will be required to have a digital product passport, unless an alternative digital system—such as the EPREL database for energy-labelled products—already provides equivalent information.

This passport will enable controlled access to product data for businesses, consumers, and public authorities, following open, non-proprietary international standards. To support its implementation, the European Commission has launched a standardisation process to establish rules for data carriers, infrastructure, and interoperability.

The specific information to be included in the digital product passport will be defined in product-specific delegated acts under the ESPR, and potentially under other relevant legislation. The passport is designed to ensure traceability throughout the product’s value chain after it enters the market. This could encourage the broader voluntary use of traceability tools, foster market innovation, and support sustainable trade beyond the EU.

The passport will contain essential data such as material composition, the presence of any substances of concern, and guidance on safe use, recycling, and disposal. This will enable comprehensive product lifecycle management from production to end-of-life.

 

Source: COMMUNICATION FROM THE COMMISSION, Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, 16.04.2025