ESPR Working Plan: Which Products Come First

The ESPR working plan is the Commission's answer to the only question most manufacturers have about the Ecodesign for Sustainable Products Regulation: when does it reach my product? The first plan, COM(2025) 187 final, was adopted on 16 April 2025, runs to 2030, and names six product groups and two horizontal measures in the order the Commission intends to work through them. It also contains the caveat that most coverage drops: the years are labelled an indicative timeline for adoption, not deadlines.

What a working plan is — and what it is not

The ESPR is a framework. It does not itself say what a pair of trousers or a steel coil must do; it creates the power to say so, product group by product group, through delegated acts. The working plan is the Commission communicating which groups it will start with.

Three consequences follow, and each one is a place where readers go wrong.

A working plan is not law. It sets priorities. Nothing in it binds a manufacturer.

The adoption year is not the compliance year. The year in the table is when the Commission expects to adopt the delegated act. The act then sets its own application dates, which fall later. Reading "textiles 2027" as "textile requirements apply in 2027" overstates the position by a margin that matters for planning.

Requirements are not knowable until the act exists. Until a delegated act is adopted, nobody — including a consultant with a detailed checklist — can tell you what your product group's ESPR requirements will be. Anyone who can is describing a draft or an expectation.

The order

Iron and steel leads because the Joint Research Centre's assessment ranked it first; aluminium, ranked fourth, follows a year later. Both are intermediate products, which is a distinction worth holding on to: regulating an input reaches every final product built from it, which is why the plan notes the need to assess intermediate products carefully to avoid downstream consequences for the manufacturers who buy them.

Chemicals were considered and left out. The plan records that a study would be launched to define more precisely which chemicals might be in scope for a future working plan. If you have been told chemicals are on the ESPR schedule, the source is not this document.

What "intermediate first" means for a manufacturer who does not make steel

The sequencing has a consequence that the product-group table hides. A furniture manufacturer reads the table and sees 2028. But furniture is made of steel and aluminium in large quantities, and those acts are indicated for 2026 (expected) and 2027 (expected) — before the furniture act.

So the first ESPR requirement to reach a furniture maker will probably not be a furniture requirement. It will be a supplier passing on data obligations from the steel act, one to two years earlier than the row with your product's name on it. The same logic applies to anyone using aluminium extrusions, steel fasteners or tyres in a finished good.

That is the practical reading of an intermediate-first plan, and it is the opposite of what the table appears to say.

Walkthrough: an office furniture exporter reading the plan

A representative scenario. A manufacturer outside the EU sells steel-framed office chairs and desks into European distributors. It reads the working plan and finds furniture at 2028.

The naive plan. Nothing to do until 2027, when preparation for a 2028 act would start. Two and a half years of no action.

What the plan actually implies. The steel act is indicated for 2026 (expected). Whatever it requires of steel producers — recycled content declarations, carbon data, documentation moving with the material — travels to the customer who buys that steel, which is this manufacturer. The demand arrives through a supplier's compliance work, not through a rule addressed to furniture. Aluminium and the repairability horizontal measure follow in 2027 (expected), and repairability applies across product groups rather than waiting for the furniture row.

What it does about it. Not a compliance project — a data readiness one. Know which steel and aluminium grades go into which SKU, and which supplier each comes from. That is the input to every one of these acts, and it is knowable today without reading any of them.

The counterfactual. Suppose it had planned to the 2028 row. The first real request would have arrived from a steel supplier in 2026 or 2027, referencing an act the company had filed under "not us". The gap would not be legal exposure — no ESPR rule binds it yet — it would be a customer asking a question it could not answer while a competitor could.

Edge cases

Your product spans two groups. A mattress with a steel frame sits behind two rows. The earlier one governs your timetable.

Horizontal measures do not wait for your product group. Repairability, indicated for 2027 (expected), is horizontal by design. Do not read it as arriving with your sector's act.

The plan can change. A mid-term review is scheduled for 2028, and priorities have moved before. Treat the tail of the list as softer than the head.

Being out of the plan is not being out of EU law. The battery regulation, packaging rules and energy labelling run on their own timetables. Absence from this table says nothing about them.

"Indicative" cuts both ways. An act can slip, and it can also arrive close to schedule. Planning on slippage is a bet, not a strategy.

What a delegated act will actually contain

Knowing when an act is expected is only useful if you know what kind of thing arrives. Under the ESPR framework a product-group delegated act sets two families of requirement, and they land on different parts of a business.

Performance requirements govern the product itself — durability, reliability, reparability, energy and resource efficiency, recycled content, and substances of concern. These change engineering and sourcing decisions, and they carry the longest lead time because they can require a redesign.

Information requirements govern what must be declared and made available, and this is where the digital product passport sits. These change data systems rather than products. They are usually faster to implement and easier to underestimate, because the work is spread across suppliers rather than concentrated in a design team.

For most manufacturers reading a working plan, the information side is the one that arrives as a surprise. A performance requirement is visible in a specification. An information requirement becomes visible only when someone asks for a field nobody has ever collected — the origin, the recycled fraction, the plant, the supplier two tiers up.

That is the argument for doing the product-independent work now. Which suppliers, which materials, which plants, mapped to which SKU: none of that depends on knowing whether your act lands in 2027 or 2029, and all of it is the input the information requirements will want. The act decides the fields. It does not decide whether you can reach the people who hold them.

Zoom out: the queue is the message

Read as a whole, the working plan says something the individual rows do not. The Commission started with materials rather than with consumer goods, put two horizontal measures alongside them, and left the largest consumer categories for the back half of the decade. That ordering pushes the data burden upstream first and lets it flow down — which is the same pattern as the battery rules and the deforestation regulation, arriving from a different direction.

For a manufacturer the useful conclusion is not a date. It is that the first ESPR request you receive will most likely come from a supplier or a customer rather than from a regulator, and it will arrive before the row with your product's name on it. Our ESPR guide covers the framework these acts sit in, what a digital product passport is covers the record they will require, and the textile data guide covers the group with the largest supplier base behind it.

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