ESPR & DPP guide
ESPR Delegated Acts and the 2025-2030 Working Plan
ESPR delegated acts are the Commission acts that set the actual, binding ecodesign and Digital Product Passport requirements for each product group, adopted progressively under the ESPR framework. Without a delegated act for a given product, its specific ESPR obligations are not yet in force. The first Working Plan (2025-2030) sets the indicative sequence.
TL;DR
- Delegated acts set the binding ecodesign and DPP requirements for each product group under the ESPR framework.
- Until a delegated act exists for a product, its specific ESPR obligations are not yet in force.
- The first Working Plan (2025-2030) was adopted 16 April 2025 and names six priority product groups.
- All adoption dates below are indicative Working-Plan estimates, not yet adopted law.
What a delegated act does
ESPR itself is a framework: it sets out the toolbox of possible requirement types, the DPP architecture, the unsold-goods ban and the enforcement structure. The binding numbers for any given product are filled in later by a Commission delegated act for that product group, informed by preparatory studies and the Working Plan.
This is why ESPR can be "in force" yet impose few product-specific obligations today: most of those obligations arrive only as each delegated act is adopted.
The first Working Plan (2025-2030)
The first ESPR Working Plan was adopted on 16 April 2025. It sets, sector by sector, which product groups get ecodesign requirements, the indicative adoption windows, and when DPPs arrive. A mid-term review is planned for around 2028.
- Priority product groups: textiles (especially apparel), furniture, mattresses, tyres, iron and steel, aluminium.
- Horizontal measures: a repairability-score framework (A-E), recyclability and recycled-content requirements (especially for electrical and electronic equipment), and energy and resource efficiency.
Indicative sequencing
The dates below are indicative Working-Plan estimates only. None of these delegated acts is adopted yet, and a DPP typically applies roughly 18 months after an act enters into force.
| Product group | Indicative delegated-act adoption | Status |
|---|---|---|
| Iron & steel | 2026 (first) | Indicative |
| Textiles (apparel) | ~2027 | Indicative |
| Tyres | ~2027 | Indicative |
| Aluminium | ~2027 | Indicative |
| Furniture | Later in 2025-2030 window | Indicative |
| Mattresses | Later in 2025-2030 window | Indicative |
A note on existing measures
A repairability and disassembly framework, and related electronics measures for products such as smartphones and tablets, flow partly from pre-existing ecodesign and energy-label work already mandatory since mid-2025. Do not conflate these with the new ESPR delegated acts still in preparation.
FAQ
Common questions
- What are ESPR delegated acts?
- ESPR delegated acts are Commission acts that set the actual, binding ecodesign and Digital Product Passport requirements for each product group, adopted progressively under the ESPR framework. Without a delegated act for a product, its specific ESPR obligations are not yet in force.
- Which product groups are prioritised?
- The first Working Plan (2025-2030) names six priority product groups: textiles (especially apparel), furniture, mattresses, tyres, iron and steel, and aluminium, plus horizontal measures on repairability, recyclability and recycled content.
- When will the delegated acts be adopted?
- The Working Plan gives indicative dates: iron and steel first (around 2026), then textiles, tyres and aluminium (around 2027), with furniture and mattresses later in the 2025-2030 window. These are indicative estimates, not adopted law.
- How long after a delegated act does a DPP apply?
- A Digital Product Passport typically applies roughly 18 months after a delegated act enters into force, though the exact lag is set per act. This is why a delegated act expected around 2027 implies a DPP realistically around 2028.
Put it into practice
Work through the DPP Readiness Checklist, then explore the product groups and tools built for your situation.
This is guidance, not legal advice
Sources
- [1]Regulation (EU) 2024/1781 (ESPR), full text (EUR-Lex)retrieved 8 Jun 2026
- [2]EUR-Lex: official summary of the ESPRretrieved 8 Jun 2026
- [3]European Commission: 2025-2030 ESPR Working Planretrieved 8 Jun 2026
- [4]European Commission: Product Environmental Footprint (PEF) methodretrieved 8 Jun 2026
- [5]JRC: Digital Product Passport data-requirements methodology (JRC145830)retrieved 8 Jun 2026
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