ESPR Working Plan 2025-2030: What Businesses Need to Know

The European Commission has published its Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, setting the direction for the first major implementation phase of the Ecodesign for Sustainable Products Regulation.

For businesses placing products on the EU market, this working plan is more than a policy update. It is a roadmap showing which product groups are expected to face new or revised sustainability requirements, when the Commission intends to adopt measures, and how product information, repairability, recyclability, recycled content, and energy performance will become increasingly important for market access.

The plan also confirms that the EU is moving toward a more circular, transparent, and resource-efficient product economy. Companies that prepare early will be better positioned to reduce compliance risks, improve product data readiness, and respond confidently to upcoming regulatory changes.

What Is the ESPR Working Plan 2025-2030?

The Ecodesign for Sustainable Products Regulation, known as the ESPR, is the EU’s framework for setting ecodesign requirements for products placed on the EU market. It builds on the existing ecodesign and energy labelling approach, but with a broader scope.

While traditional ecodesign rules have focused mainly on energy-related products, the ESPR expands the regulatory focus to a wider range of products and sustainability aspects.

Future ESPR requirements may address areas such as:

• Product durability
• Repairability
• Recyclability
• Recycled content
• Material efficiency
• Carbon and environmental footprint information
• Availability of spare parts
• Product information through the Digital Product Passport

The 2025-2030 Working Plan identifies the first priority products and measures that the European Commission intends to work on under the ESPR and the Energy Labelling Framework.

Why the ESPR Working Plan Matters for EU Market Access

The ESPR applies to products placed on the EU market, including imported products. This means that both EU and non-EU companies will need to follow the relevant requirements once they are adopted for their product categories.

The working plan is especially important because it gives businesses early visibility. It allows companies to assess whether their products are likely to be affected, review product data gaps, engage suppliers, and prepare internal compliance processes before delegated acts introduce detailed requirements.

For many companies, the impact will not be limited to product design. It may also affect sourcing, supplier documentation, technical files, environmental data, labelling, digital product information, and market surveillance readiness.

In practical terms, the ESPR Working Plan signals that sustainability compliance is becoming a core part of product compliance in the EU.

Priority Product Groups Under the ESPR Working Plan

The European Commission has identified several final products, intermediate products, and horizontal measures for the 2025-2030 period.

These timelines are indicative. The final legal obligations will be defined through future product-specific or horizontal delegated acts.

Textiles, Furniture, Tyres and Mattresses: A Clear Circularity Signal

The inclusion of textiles, furniture, tyres, and mattresses shows the EU’s intention to focus on products with significant potential for circularity improvements.

For textiles and apparel, the working plan highlights the potential to improve product lifetime, material efficiency, and impacts linked to water, waste, climate change, and energy consumption. This is particularly relevant for brands, importers, and retailers that manage complex supply chains and need reliable product composition data.

For furniture, the focus is on resource use and the environmental impacts linked to materials, production, and waste. Businesses in this sector may need to pay closer attention to material sourcing, product durability, reparability, and end-of-life considerations.

For tyres, existing EU legislation already covers certain aspects, but the ESPR working plan points to further potential in recyclability, recycled content, and end-of-life tyre management.

For mattresses, the expected focus is on waste generation, lifetime extension, and material efficiency. This may increase the importance of material transparency and product design choices that support circularity.

Iron, Steel and Aluminium: Intermediate Products With Wide Supply Chain Impact

The ESPR Working Plan also prioritises iron and steel and aluminium. These are intermediate products, meaning they are often used as inputs in many final products.

This is important because requirements for intermediate products can affect multiple downstream sectors. Manufacturers using steel or aluminium in final products may need to understand how future ESPR requirements could influence supplier documentation, environmental claims, material specifications, and product compliance evidence.

The Commission notes that requirements for these materials must be carefully assessed to avoid negative downstream effects. This makes early monitoring essential for companies that rely on these materials in their supply chains.

Digital Product Passport: Product Data Becomes a Compliance Asset

A major feature of the ESPR is the Digital Product Passport.

For products covered by ESPR measures, the Digital Product Passport is expected to provide access to relevant product information across the value chain. Where another digital system provides equivalent information, such as EPREL for certain energy-related products, that system may be used instead.

The Digital Product Passport may include information such as:

• Material composition
• Substances of concern
• Safe use information
• Recycling and disposal guidance
• Sustainability-related product data
• Information needed by businesses, consumers, and authorities

For businesses, this means product data quality will become increasingly important. Companies will need structured, reliable, and traceable information from suppliers and internal teams. Product compliance will no longer depend only on having technical documentation available at the end of the process. It will require data readiness throughout the product lifecycle.

Repairability, Recyclability and Recycled Content: Key Compliance Themes

The ESPR Working Plan includes horizontal requirements for repairability and for recycled content and recyclability of electrical and electronic equipment.

This is significant because horizontal requirements can apply across several product groups, rather than only one specific product category.

Repairability requirements may include scoring systems and could potentially cover products such as consumer electronics and small household appliances, depending on the final scope defined by the Commission.

For electrical and electronic equipment, recycled content and recyclability requirements could support circularity for critical raw materials, reduce waste, and improve resource efficiency.

Businesses should monitor these areas closely because they may influence product design, component choices, spare parts strategy, supplier engagement, and claims about sustainability performance.

Energy Labelling and Energy-Related Products Remain Important

The working plan also carries forward work on several energy-related products. These include product groups such as displays, dishwashers, washing machines, refrigerating appliances, light sources, mobile phones and tablets, tumble dryers, local space heaters, electric motors, and other equipment.

For companies in these sectors, the message is clear: energy performance, energy labelling, and ecodesign requirements will continue to evolve under the broader ESPR framework.

Energy labels are expected to remain an important tool for helping consumers compare product performance. Businesses should ensure that product data, declarations, technical files, and labelling information remain accurate, updated, and aligned with applicable EU requirements.

What Businesses Should Do Now

The ESPR Working Plan does not mean that all listed obligations apply immediately. However, it provides a strong signal of where EU product compliance is heading.

Companies should start preparing by taking practical steps:

Early preparation can help businesses reduce last-minute compliance pressure and avoid fragmented product data collection when new rules become mandatory.

ESPR Compliance Is a Strategic Business Priority

The ESPR Working Plan supports the EU’s broader goals for circular economy, resource efficiency, consumer protection, competitiveness, and sustainable product markets.

For businesses, this creates both challenges and opportunities. Companies that treat ESPR readiness as a strategic priority can improve transparency, strengthen supplier collaboration, and build more resilient compliance systems.

The most prepared companies will be those that understand their product data, monitor regulatory developments, and integrate sustainability compliance into product development and market access planning.

How ComplyMarket Can Support ESPR Readiness

As the EU moves toward more detailed sustainability and ecodesign requirements, businesses need a clear and structured approach to product compliance.

ComplyMarket can support companies by helping them organise and manage the compliance activities needed to prepare for ESPR-related requirements. This includes supporting teams in understanding applicable obligations, tracking regulatory developments, identifying product data needs, and preparing documentation across the supply chain.

ComplyMarket can help businesses approach ESPR readiness through:

• Product compliance mapping for affected categories
• Supplier data collection and documentation support
• Regulatory monitoring for ESPR, ecodesign, and energy labelling developments
• Preparation for Digital Product Passport data requirements
• Support in managing evidence related to sustainability, repairability, recyclability, and material information
• Clear workflows that help compliance, sustainability, procurement, and product teams work together

The ESPR Working Plan 2025-2030 is an early warning system for future EU product compliance expectations. By preparing now, businesses can reduce risk, improve transparency, and build a stronger foundation for sustainable market access.

ComplyMarket helps businesses turn complex regulatory change into structured, manageable compliance action.