The European Commission has adopted the 2025-2030 working plan for the Ecodesign for Sustainable Products Regulation (ESPR) and the Energy Labelling Regulation, outlining a significant roadmap for sustainable product design across multiple sectors. Is your company prepared??
Priority products and timeline for implementation
The Commission’s working plan identifies key product categories that will be prioritised for ecodesign requirements and energy labelling over the next five years. For manufacturers and importers in these sectors, early preparation will be essential to maintain market access.
Priority products include:
- Steel and aluminium
- Textiles (with a focus on apparel)
- Furniture
- Tyres
- Mattresses
These categories were selected based on their potential to deliver meaningful progress toward circular economy objectives, in alignment with the EU’s Clean Industrial Deal and Competitiveness Compass.
Harmonised requirements to strengthen the single market
For product compliance managers, one of the key benefits of this approach will be the harmonisation of product sustainability requirements across the EU. This standardisation aims to reinforce the single market, prevent barriers to trade, improve the level playing field, reduce administrative burdens, and strengthen global competitiveness for businesses offering sustainable products. By creating a unified approach to sustainability requirements, the Commission seeks to reduce the fragmentation of rules that has complicated compliance for many manufacturers.
Horizontal measures for repairability and recyclability
Beyond the category-specific requirements, the Commission will introduce horizontal measures focused on repairability for consumer electronics and small household appliances. These will include a repairability score for products with the most potential, specific requirements on recyclability of electrical and electronic equipment. These measures align with growing consumer demand for more durable, repairable products and the EU’s broader circular economy objectives.
Two-part structure for ecodesign requirements
Future ecodesign and energy labelling requirements for the selected products will cover two fundamental elements primarily through two channels: the European Product Registry for Energy Labelling (EPREL) for products with energy labels and the Digital Product Passport (for most products).
1. Product performance requirements
- Durability
- Energy and resource efficiency
- Availability of spare parts
- Minimum recycled content
2. Product information requirements
- Carbon and environmental footprint
- Other sustainability characteristics
Support for SMEs
The Commission has acknowledged the potential challenges these requirements may pose for smaller businesses. When developing ecodesign requirements, special attention will be paid to the needs of SMEs, particularly micro-enterprises and small mid-cap enterprises, with tailored support made available to them. This commitment to supporting smaller businesses reflects an understanding that the transition to more sustainable products must be inclusive and economically viable across the entire market.
Next steps in the regulatory process
Ecodesign and energy labelling requirements will be established through delegated acts, developed on a product-by-product basis or for groups of similar products. This process will involve:
- Thorough preparatory studies
- Comprehensive impact assessments
- Stakeholder engagement through the newly established Ecodesign Forum
For energy-related products already under consideration from previous initiatives, relevant requirements will be adopted no later than 31 December 2026.
The broader regulatory context
The Ecodesign for Sustainable Products Regulation, adopted in July 2024, builds on the approach successfully pioneered under the EU’s current ecodesign and energy labelling frameworks. Together with the Energy Labelling Framework Regulation, it aims to guide consumers toward more sustainable and energy-efficient products.
Today’s working plan continues efforts already underway for 16 energy-related products from the 2022-2024 ecodesign and energy labelling working plan, including dishwashers, electric motors, electric vehicle chargers, and displays.
Implications for manufacturers and importers
For companies producing or importing products in the priority categories, several proactive steps are recommended:
- Monitor regulatory developments: Stay informed about emerging requirements for your specific product categories.
- Audit product sustainability: Evaluate current products against potential requirements for durability, repairability, and resource efficiency.
- Review supply chains: Assess suppliers’ ability to provide components and materials that meet recycled content requirements.
- Prepare for information requirements: Begin developing systems to capture and manage sustainability data needed for Digital Product Passports.
- Engage with industry associations: Participate in stakeholder consultations through relevant industry bodies to ensure your concerns are represented.
- Develop compliance roadmaps: Create timeline-based plans for bringing products into compliance with anticipated requirements.
- Consider product redesign opportunities: Rather than merely complying with minimum standards, explore how sustainable design principles might create competitive advantages.
Long-term strategic opportunities
While these requirements present significant compliance challenges, they also create opportunities for forward-thinking companies. Businesses that proactively embrace circular design principles may gain competitive advantages through:
- Enhanced brand reputation with sustainability-conscious consumers
- Reduced material costs through more efficient resource use
- Greater resilience against supply chain disruptions
- Early market leadership in sustainable product categories
- Alignment with global sustainability trends beyond the EU
The Commission’s working plan represents a significant step toward transforming how products are designed, manufactured, and marketed in the EU. For product compliance managers, understanding these developments and preparing strategically will be essential to maintaining market access while contributing to a more sustainable economy.
At Alura Group, we understand the challenges of navigating these evolving requirements. Our product compliance specialists can help you assess your product portfolio against emerging ecodesign standards and develop practical strategies for maintaining compliance while enhancing sustainability performance.
Source: https://ec.europa.eu/commission/presscorner/detail/en/ip_25_1071
