The ESPR Delegated Act Adoption Process and the Priority Product Categories of the 2025–2030 Ecodesign and Energy Labelling Working Plan
ENFORCEMENT TIMELINE
In force since July 18, 2024 (the first Working Plan was adopted April 16, 2025; each delegated act has its own individually determined application timing)
Overview
This card focuses on the specific operational practice for the "delegated act adoption process" that actually gives rise to the ESPR's concrete obligations, and the priority product categories set out in the "2025–2030 Ecodesign and Energy Labelling Working Plan" the European Commission adopted on April 16, 2025.
The ESPR itself does not set specific requirement levels for individual product categories; legally binding obligations arise only once the European Commission conducts preparatory studies and impact assessments, consults stakeholders through the Ecodesign Forum, and adopts an individual delegated act for each product category. The first Working Plan identified new categories such as textiles (apparel and footwear), furniture, iron and steel, and aluminium as priority implementation targets, alongside energy-related products carried over from the previous Ecodesign Directive. Each delegated act generally includes a minimum transition period of 18 months so that affected businesses have time to prepare.
Enforcement Timeline
July 18, 2024: The ESPR (Regulation (EU) 2024/1781) enters into force, establishing the legal framework for adopting delegated acts.
April 16, 2025: The European Commission adopts the 2025–2030 Ecodesign and Energy Labelling Working Plan, identifying textiles, furniture, iron and steel, aluminium, tyres, ICT products, and others as priority targets.
From 2026 onward: Individual delegated acts for each priority product category are expected to be adopted and published in turn (specific obligations apply after a minimum 18-month transition period following each delegated act's entry into force).
2027–2030: Application of delegated acts under the Working Plan is expected to gain momentum.
Related Regulations / Topics
ESPR Delegated Act on Ecodesign for Textiles (Pending)
The ecodesign delegated act for textiles and apparel is planned under the ESPR (Regulation (EU) 2024/1781). In the Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025–2030 (16 April 2025), textiles/apparel is a priority product, and the indicative timeline for adoption is 2027. ESPR requirements may cover product performance (such as durability, availability of spare parts and minimum recycled content) and product information (such as carbon or environmental footprint, mainly provided through the Digital Product Passport (DPP)). The specific requirements for textiles are not settled until the delegated act is adopted. Footwear is not included in the working plan; a study on applying the ESPR to footwear is to be completed by the end of 2027.
EU ESPR: Application to Electronics and ICT Products (Horizontal Requirements)
The first ESPR Working Plan (published April 2025) does not set a dedicated delegated act for electronics and ICT products. Instead, they are to be covered in stages through two horizontal requirements that cut across product groups: (1) a reparability scoring framework and (2) recycled content and recyclability requirements for electrical and electronic equipment. Smartphones and tablets are handled separately under the energy-related products track.
Business Impact
Businesses whose products fall within the priority categories (textiles, furniture, iron and steel, aluminium, tyres, ICT products, and others) need to continuously monitor the progress of the delegated act applicable to their products, including public consultation periods and discussions at the Ecodesign Forum. Although each delegated act carries a minimum 18-month transition period after adoption, the lead time needed to redesign products to meet performance requirements can be substantial, making it advisable to begin preparation from the point the Working Plan is published.
For businesses handling products not currently included in the priority categories, proactively advancing voluntary product improvements aligned with the Article 5 parameters — with an eye to the risk of expanded scope under the next Working Plan (from 2030 onward) — is an effective way to smooth out future compliance costs.