COMMUNICATION FROM THE COMMISSION Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030
Date: 2025-04-16
Institutions: Directorate-General for Environment, European Commission
Subjects: EU action, EU energy label, action programme, administrative formalities, consumer information, eco-label, ecodesign, environmental impact, product life, sustainable product

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.4.2025  COM(2025) 187 final  COMMUNICATION FROM THE COMMISSION Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 {SWD(2025) 112 final}  
 
 
COMMUNICATION FROM THE COMMISSION 

Ecodesign for sustainable products and energy labelling working plan for 2025-2030 

1. 

INTRODUCTION 

1.1.  A single market for sustainable products 

The  Ecodesign  for  Sustainable  Products  Regulation (ESPR) (1)  is  the  legal  framework  for 
setting  ecodesign  requirements.  Together  with  the  Energy  Labelling  Framework  Regulation 
(ELFR)  it  facilitates  consumer  choice  and  encourages  the  take-up  of  more  sustainable  and 
energy-efficient  products.  This  Communication  specifies  the  products  to  be  prioritised  for  the 
work to be carried out up until 2030 under the ESPR and the ELFR. 

Setting harmonised ecodesign requirements applicable throughout the single market helps boost 
the  uptake  of  sustainable  products,  production  and  consumption.  Stakeholders  support  this 
initiative because it reduces compliance costs, simplifies the system and enables producers and 
consumers  to  benefit  from  the  economies  of  scale  that  a  market  with  450  million  consumers 
provides.  This  stimulates  investment  and  innovation,  creating  more  demand  for  sustainable 
products, which promotes the competitiveness of EU manufacturers and encourages sustainable 
choices  throughout  the  value-chain.  Setting  ambitious  thresholds  to  place  products  on  the  EU 
market, which apply to both EU and non-EU companies, is a valuable opportunity to increase the 
sustainability of global value chains. Moreover, incentives can help promote sustainable products 
and ensure their affordability for all consumers. 

Ecodesign requirements are effective in reducing the environmental, energy and climate impacts 
of  products  and  energy  consumption  and  in  improving  circularity.  By  providing  more 
information  on  product  sustainability,  the  requirements  help  consumers  make  better  informed 
purchase decisions and create economic benefits for producers of more sustainable products. The 
development of ecodesign requirements on the repairability of consumer products is also relevant 
for  extending  the  consumer’s  right  to  repair  established  by  the  Directive  EU/2024/1799  on 
promoting  the  repair  of  goods (2).  As  a  result,  ecodesign  requirements  contribute  to  major  EU 
policy goals related to the environment, energy, climate, consumer protection, competitiveness, 
resilience and the single market. 

This  working  plan  will  also  contribute  to  the  aims  of  the  recently  adopted  Competitiveness 
Compass  (3)  by  helping  to  close  the  innovation  gap  and  to  boost  competitiveness, 
decarbonisation  and  EU  economic  security.  Moreover,  it  can  help  develop  lead  markets  for 

(1)  Regulation  (EU)  2024/1781  of  the  European  Parliament  and  of  the  Council  of  13 June  2024  establishing  a 

framework for the setting of ecodesign requirements for sustainable products. 

(2)  Directive  (EU) 2024/1799 of the  European  Parliament  and of  the  Council of 13  June  2024  on  common  rules 
promoting  the  repair  of  goods  and  amending  Regulation  (EU)  2017/2394  and  Directives  (EU)  2019/771  and 
(EU) 
ELI: 
http://data.europa.eu/eli/dir/2024/1799/oj  

relevance),  OJ 

(Text  with 

2024/1799, 

2020/1828 

10.7.2024, 

EEA 

L, 

(3)   COM(2025) 30 final. 

1 

 
 
 
sustainable and circular products, in line with the recent Clean Industrial Deal (4) and the Steel 
and Metals Action Plan (5). The Commission plans to issue a related Circular Economy Act and 
an Industrial Decarbonisation Accelerator Act to complement this initiative.  

ESPR  is  a  key  contribution  to  the  Clean  Industrial  Deal’s  ambition  to  make  the  EU  the  world 
leader on circular economy by 2030.  The adoption of the product requirements under ESPR  – 
complemented  by  the  upcoming  Circular  Economy  Act  –  will  be  central  for  making  our 
economies  more  circular  by  developing  lead  markets  for  sustainable  and  circular  products, 
making sure that products containing valuable and scarce materials are reused efficiently and for 
as  long  as  possible  before  they  become  waste,  and  by  incorporating  criteria  promoting 
reparability, recyclability and recycled content. In brief, the ESPR will significantly advance our 
goal of a clean, decarbonised, and resource-efficient EU economy. 

1.2. Contributing to the goals of simplification and burden reduction 

This working plan is the first to apply the wider scope of the ESPR to specific products. It aims 
to strike a balance between the ESPR’s potential positive environmental impacts, its capacity to 
deliver  and  the  need  to  simplify  regulations.  Several  provisions  of  the  ESPR  explicitly  require 
that  the  Commission,  when  setting  ecodesign  rules  (including  on  reporting),  avoids  placing  a 
disproportionate administrative burden on businesses, in particular on SMEs (6). 

The  goal  of  simplification  is  at  the  very  core  of  the  ESPR.  By  setting  harmonised  product 
sustainability  requirements  at  EU  level,  applicable  across  all  Member  States,  it  will  prevent 
barriers to  trade and level  the playing field  for businesses operating on  or exporting to  the EU 
single market, in turn reducing their administrative burden. 

The working plan identifies the first set of key priorities to build up experience and the capacities 
needed  for  the  ESPR  to  reach  its  full  regulatory  potential,  in  partnership  with  Member  State 
authorities.  In parallel, it  paves the way  to  cover more  product  groups  in future by conducting 
preliminary scoping studies and detailed assessments of the potential impacts and improvements. 
This approach helps keep the commitments to issuing new regulatory measures, reduces the risk 
of delays and contributes to a stable business environment. 

The building up of experience includes methodological aspects, especially on carbon accounting 
where the working  plan  implementation  will contribute to  the  objective of the Clean Industrial 
Deal  communication  to  simplify  and  harmonise  carbon  accounting  methodologies,  in 
complementarity with the voluntary label also announced in the Clean Industrial Deal. 

(4)   COM(2025) 85 final. 

(5)  COM (2025) 125 final.  

(6)   In particular, ESPR Articles 5, 7, 13, 16, 36, 39, 47 and 60. 

2 

 
 
 
 
 
1.3. Building on the success story of the ecodesign and energy labelling 

The  ESPR  builds  on  the  approach  successfully  pioneered  under  the  EU’s  current  Ecodesign 
and Energy Labelling Framework for two, respectively three, decades now. 

It is estimated (7) that the current ecodesign and energy labelling requirements achieved a 12% 
reduction in final energy consumption in 2023. This is more than the combined final energy 
consumption of Belgium and Czechia combined, avoiding 145 million tonnes of CO2 emissions 
that year. In 2020, the requirements are also estimated to have led to an increase of 346 000 jobs, 
and cost savings of between EUR 182 and EUR 266 per household, a figure estimated to rise to 
between EUR 473 and EUR 736 per household by 2030. It has also paid off for business: 93% 
of  consumers  recognise  the  energy  label  when  buying  labelled  products  and  suppliers  and 
retailers see an increase in demand for higher performance products (helping consumers factor in 
more  than  simply  the  cost  of  purchase).  Lastly,  this  framework  has  promoted  more  energy 
efficient  production  patterns worldwide and  it has  encouraged  many third countries to  bring in 
similar legislation. 

The  ESPR  aims  to  replicate  this  success  on  a  broader  scale  while  maintaining  the  close 
synergies achieved with the Energy Labelling Framework. The ESPR will enable ecodesign 
requirements to be set for a much wider range of products (8). The requirements may cover two 
aspects:  product  performance  (e.g.  durability,  availability  of  spare  parts,  minimum  recycled 
content)  and/or  product  information  (e.g.  key  product  features,  its  carbon/environmental 
footprint).  Product  information  will  mainly  be made  available  via  the  Digital  Product  Passport 
or,  for  products  with  energy  labels,  via  the  European  Product  Registry  for  Energy  Labelling 
(EPREL). Ecodesign requirements will be set via delegated acts, on a product-by-product basis, 
or  horizontally  for  groups  of  similar  products  at  a  time.  When  developing  ecodesign 
requirements,  the  Commission  will  pay  special  attention  to  the  needs  of  SMEs,  in  particular 
micro-enterprises  and  small  mid-cap  enterprises,  and  will  provide  tailored  support  in  line  with 
Article 22 ESPR. 

2.  PRODUCTS TO BE PRIORITISED IN THE WORKING PLAN FOR 2025-2030 

2.1.  Legal requirements 

The  ESPR  sets  out  criteria  for  prioritising  products  and  including  them  in  working  plans  that 
cover a minimum of three years. Inclusion in the working plan must be based on their potential 
to  contribute to  the EU’s  climate, environmental and energy efficiency objectives. It  must  also 
consider factors such as any gaps in EU law, range of product performance, volume of sales and 
trade, impacts across the value chain and the need to review existing requirements. 

For this first working plan, the priorities were set in the Regulation (Article 18) itself: iron and 
steel;  aluminium;  textiles,  in  particular  garments  and  footwear;  furniture,  including  mattresses; 

(7)   2024 Ecodesign Impact Accounting, https://europa.eu/!THcmy4 

(8)   ESPR Article 1 (2). 

3 

 
 
 
tyres;  detergents;  paints;  lubricants;  chemicals;  energy-related  products  and  ICT  products  and 
other electronics. However, the Regulation gives the Commission some discretion to omit some 
of these products or to add new products, if it provides a justification. 

The ESPR working plan also includes a list of products to be prioritised for energy labelling, in 
conformity with the Energy Labelling Framework Regulation (9). Under this Regulation, older 
labels are to be rescaled and updated to reflect market and technology developments. 

To mirror the duration of the Commission and Parliament’s mandate and to ensure predictability 
for  businesses,  the  Commission  proposes  a  five-year  ESPR  and  energy  labelling  working 
plan (from 2025 to 2030) with a mid-term review after three years (in 2028). 

2.2.  Evidence-based, inclusive and transparent process for predictable results  

The selection of priority products is underpinned by a thorough technical analysis (10), including 
an extensive consultation process involving stakeholders, including the Member States. 

This process included a wide public consultation (11) in 2023 and presentation and discussion of 
the draft working plan at the first meeting of the Ecodesign Forum on 19 February 2025. Over 
200  participants  attended  (on  site  and  online),  representing  various  sectors  of  industry, 
academics, NGOs and international partners, as well as Member States and EEA  countries (12). 
The consultation feedback was thoroughly examined when finalising this working plan. 

Following the preparatory process described in the previous section, the first working plan will 
include four final products, two intermediate products and two legal acts setting horizontal 
requirements, in  addition to  a list  of  substantial  work prepared  and  carried over from the last 
ecodesign and energy labelling working plan (13). 

2.2.1.  New products to be included in the working plan 

Product/Measure 

Stakeholders’ 
opinion 

JRC 
rankin
g 

Market size (EU) 

Improvement potential 

Indicative 
timeline for 
adoption 

Final products 

(9)   Regulation (EU) 2017/1369 setting a framework for energy labelling and repealing Directive 2010/30/EU. 

(10)  https://publications.jrc.ec.europa.eu/repository/handle/JRC138903 

(11)  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13682-New-product-priorities-for-

Ecodesign-for-Sustainable-Products/public-consultation_en 

(12)  In addition, the ESPR  Member States Expert Group met on 21 February 2025  to  elicit specific views from 
Member  States  and  EEA  countries.  See  related  documents  here:  https://ec.europa.eu/transparency/expert-
groups-register/screen/meetings/consult?lang=en&meetingId=59861&fromExpertGroups=3969 

(13)  https://energy.ec.europa.eu/publications/ecodesign-and-energy-labelling-working-plan-2022-2024_en 

4 

 
 
 
 
Textiles/Apparel 

1st  

High support 

EUR 78  billion  (out 
of  EUR 142  billion 
of  all  textiles  and  
footwear  in  market 
size, 2019) 

Furniture 

2nd  

Support 

EUR 140 
(2021) 

billion 

Tyres 

3rd 

High support 

EUR 45 
(2021) 

billion 

Mattresses 

4th 

High support 

EUR 10 
(2022) 

billion 

High  potential  to  improve  product 
lifetime 
material 
extension, 
efficiency and to reduce impacts on 
water,  waste  generation,  climate 
change  and  energy  consumption. 
Information  requirements  under 
the  ESPR  will  work  in  synergy  with 
the  Textile  Labelling  Regulation, 
currently under review. 

and 

High  potential  to  improve  aspects 
of  resource  use,  with  impacts  of 
production and supply of materials 
often  being  the  main  contributor 
environmental 
across  different 
(e.g.  climate 
impact  categories 
acidification, 
change, 
eutrophication), 
waste 
generation.  Positive 
impact  on 
other  categories  such  as  air,  soil 
and biodiversity. 
Though  already  regulated  by  other 
pieces  of  EU  legislation  (including 
the  Tyre  Labelling  Regulation  (EU) 
improve 
2020/740),  potential  to 
recyclability  and  recycled  content 
and  to  mitigate  risks  related  to 
waste  management  of  end-of-life 
tyres. 
High  potential  to  improve  waste 
generation,  lifetime  extension  and 
material efficiency. 

Intermediate products 

Iron & Steel 

1st 

High support 

EUR 152 
(2023) 

billion 

Aluminium 

4th  

Support 

EUR 40 
(2019) 

billion 

5 

and 

High  potential  to 
improve  the 
impacts  on  climate  change,  energy 
consumption,  water,  air  and  to 
boost  the  EU’s  resilience,  strategic 
autonomy 
technological 
innovation.  Measures  under  the 
ESPR  will  complement  the  green 
steel  label  announced  in  the  Clean 
Industrial  Deal  as  well  as  existing 
environmental 
climate 
measures  on  steel  products  and 
production  such  as  the  ETS  and 
CBAM. 
improve  effects  on 
Potential  to 
energy 
change, 
climate 
consumption, 
water, 
air, 
biodiversity,  soil  pollution  and  raw 

and 

2027 

2028 

2027 

2029 

2026 

2027 

 
 
 
 
 
 
materials.  Incorporating  secondary 
materials during manufacturing can 
reduce  greenhouse  gas  emissions 
by  up  to  11  times.  Aluminium  is 
one of the metals with  the  highest 
potential  for  recyclability  and  for 
increasing  EU  supply  resilience. 
Measures under ESPR are expected 
existing 
to 
environmental 
climate 
measures  on  aluminium  products 
and  production  such  as  ETS  and 
CBAM. 

complement 

and 

Horizontal requirements 

Repairability 
(including scoring) 

N/A 

High support 

N/A 

N/A 

Support 

N/A 

Recycled 
content 
and  recyclability  of 
and 
electrical 
electronic 
equipment 

2027 

2029 

increased 

circularity 

High  potential  for  improvement; 
depending  on  the  scope  of  the 
measure  and  coverage  of  resource 
use, 
for 
(critical)  raw  materials,  climate 
change, and targeted requirements 
on  durability  (reliability)  could  also 
included.  The  scope,  to  be 
be 
refined  during 
the  preparatory 
study,  could  include  products  such 
as  consumer  electronics  and  small 
household appliances. 
High  potential  for 
improvement, 
depending  on  the  exact  scope  of 
the  measure  and  coverage  of 
resource  use,  increased  circularity 
for  (critical)  raw  materials,  climate 
change and waste prevention. 

Information  and  communication  technologies  (ICT  products)  are  not  listed  above  but  they 
are  included  in  the  first  working  plan  as  they  will  be  covered  in  the  work  to  prepare  the  two 
horizontal  requirements.  Some  specific  ICT  products  will  be  covered  in  the  work  on  energy-
related products discussed in the following section. 

The specific situation of intermediate products needs to be considered when setting ecodesign 
requirements. Regulating these products could have consequences not only on the manufacturing 
of  intermediate  products  but  also  on  all  final  products  made  from  these  intermediate  products. 
This  calls  for  a  careful  assessment  of  the  potential  impacts  on  relevant  markets,  including 
impacts on markets for final products, to avoid negative downstream consequences, in particular 
for manufacturers of final products that  contain  regulated intermediate products  as components 

6 

 
 
 
(14) (15).  The  options  being  assessed  to  mitigate  this  risk  will  include  setting  only  information 
requirements.  The  option  to  include in  the scope  of the corresponding  delegated  acts  selected 
final products containing high quantity intermediate products will also be carefully considered. 
The analysis will also look at the reliability and cost of associated verification mechanisms. 

The  definition  of  horizontal  requirements,  valid  for  a  wide  range  of  products  with  similar 
characteristics on specific aspects where this is technically possible, will carefully  consider any 
product-specific aspect that could be affected by the horizontal rules, to identify and address any 
trade-off between product aspects. This new approach to ecodesign rule-setting will be brought 
in progressively, in a gradual approach to build on experience with the first cases. 

2.2.2.  Energy-related products 

In  future,  energy-related  products,  including  those  already  regulated  under  the  Ecodesign 
Directive, will be regulated under the ESPR. The Ecodesign and Energy Labelling working plan 
for  2022-2024  covers  35  products  and  considerable  progress  in  implementing  this  plan  is 
described in the accompanying staff working document (16). For 19 of these products, the ESPR 
sets  a  transition  period  until  31 December  2026  (17)  under  which  the  measures  continue  to  be 
covered by the Ecodesign Directive.  

For the  remaining  16 products,  the Commission considers that  the  analysis of the potential for 
improvement  is  still  valid.  For  most  of  these  products,  the  Commission  has  already  begun  the 
necessary preparations. Therefore, for reasons of efficiency, these 16 products are carried over to 
the 2025-2030 working plan. 

(14)  This  includes  potential  ‘leakage’  effects  leading  to  an  increase  of  the  imports  of  final  products  containing 
concerned intermediate products to circumvent their use regulated only at intermediate level, a study to evaluate 
a similar risk is currently ongoing in relation to CBAM. 

(15)  For  instance,  some  sectors  like  defence  and  security,  the  space  sector,  medical  devices,  require  a  careful 
evaluation  to  ensure  that  performance  of  the  final  products  is  not  compromised  in  view  of  their  specific 
applications (in line with ESPR Recital 19).  

(16)  [SWD(2025)112]. 

(17)  Article 79  lists  these  as:  photovoltaic  panels,  space  and  combination  heaters,  water  heaters,  solid  fuel  local 
space heaters, air conditioners including air-to-air heat pumps and comfort fans, solid fuel boilers, air heating 
and  cooling  products,  ventilation  units,  vacuum  cleaners,  cooking  appliances,  water  pumps,  industrial  fans, 
circulators,  external  power  supplies,  computers,  servers  and  data  storage  products,  power  transformers, 
professional refrigeration equipment and imaging equipment. 

7 

 
 
 
 
 
 
 
 
The following 16 items are carried forward and included in the first ESPR working plan. 

Energy-related products 

Low-temperature emitters  

Displays 

EV chargers  

Household dishwashers 

Household washing machines and household washer-dryers 

Professional laundry appliances 

Professional dishwashers 

Electric motors and variable speed drives 

Refrigerating appliances (including household fridges and freezers) 

Refrigerating appliances with a sales function 

Light sources and (only for ecodesign) separate control gears 

Welding equipment  

Mobile phones and tablets 

Local space heaters 

Tumble dryers 

Standby and off mode consumption 

New 
product 

Ecodesign 
requirements 

Energy label  

Indicative timeline 

Yes 

No 

Yes 

No 

No 

Yes 

Yes 

No 

No 

No 

No 

No 

No 

No 

No 

No 

No 

Yes 

Yes 

Yes 

 To be 
specified 

To be 
specified 

Adoption: 2026 

Adoption: 2027 

Adoption: 2028 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Adoption: 2026  

Adoption: 2026  

To be 
specified 

To be 
specified 

No 

Yes 

Yes 

Yes 

No 

Yes 

Yes  

Yes  

No 

Adoption: 2026  

Adoption: 2026  

Adoption: 2028 

Adoption: 2028 

Adoption: 2028 

Adoption: 2029 

Adoption: end 2030 

Adoption: end 2030 

Energy label: adoption in 2026 
Ecodesign requirements: 
Adoption: mid-2030 

Adoption: end 2030 

Adoption: end 2030 

2.2.3.  Products not included in the first working plan 

Based on the assessment methodology referred to above, on the resources available and on the 
justifications below, the following products listed in Article 18 ESPR are not included in the first 
ESPR working plan. However, it is proposed to initiate work on a few of the products in this list 
by  conducting  studies  and  then  to  use  the  mid-term  review  after  three  years  to  reassess  the 
situation. 

For detergents, paints and lubricants, the JRC study on new product priorities shows that these 
product  groups  have  lower  impacts  and  lower  improvement  potential  than  the  final  products 
selected in this working plan. The open public consultation also showed a relatively lower level 
of support for these products than for the final products prioritised in this working plan. 

8 

 
 
 
 
 
 
 
 
 
 
Footwear  is  in  a  separate  product  category  from  textiles  due  to  the  distinct  use  of  materials, 
product functionality and supply chains.  It also has lower impacts than the list of priority final 
products.  However,  given  the  significance  of  these  impacts  and  the  potential  use  of  ecodesign 
requirements for the eco-modulation of extended producer responsibility fees for footwear under 
the Waste Framework Directive, a study will be commissioned during the implementation of this 
working plan. The study will evaluate the potential to improve the environmental sustainability 
of footwear under the ESPR and will be completed by the end of 2027. 

The product group ‘chemicals’ was highly ranked in the JRC study in terms of high impacts and 
high  improvement  potential.  The  open  public  consultation  also  found  support  to  include 
chemicals in the list, but it is a very complex product group that the JRC study assessed as an 
intermediate product, focusing on large-volume organic and inorganic chemicals. However, the 
scope of the chemicals product group is commonly understood to be much wider, and there is an 
overlap with other segments such as petrochemicals, polymers, specialty chemicals and plastics. 
Given this complexity, a study will be launched by the end of 2025 to define more precisely the 
potential chemicals in scope as well as a potential focus area(s) for product aspect improvements 
for (a) future ESPR delegated act(s) related to chemicals (including polymers & plastics) to be 
considered for inclusion in the review of this or in a following working plan.  

In line with ESPR Article 5(6), the Commission can, at any stage, set ecodesign requirements on 
product  groups  that  are  not  included  in  the  working  plan.  For  example,  for  electrical 
switchgears,  the  Commission  will  monitor  closely  the  developments  under  Regulation  (EU) 
fluorinated  greenhouse  gases (18)  before  considering  setting  ecodesign 
2024/573  on 
requirements.    

3.  KEY ENABLERS 

3.1.  The international dimension – integrated in all stages of the process 

Future  rules  under  the  ESPR  may  have  significant  implications  at  international  level,  since  all 
goods placed on the EU market, including imports, will have to meet the new standards (as they 
do under the Ecodesign  Directive). This is  why the  process to develop ecodesign requirements 
must be based on granular assessment and understanding of the implications on third countries. 

The  Commission  will  ensure  a  proportionate,  systematic  and  high-quality  assessment  of 
international  dimensions in the preparatory studies and impact assessments to ensure that 
the  impact  on  third  country  operators  is  thoroughly  understood  sufficiently  in  advance, 
proportionate,  and  in  line  with  the  Commission’s  Better  Regulation  guidelines (19).  Timely 

(18)  OJ L, 2024/573, 29.2.2024, ELI: http://data.europa.eu/eli/reg/2024/573/oj     

(19)  https://commission.europa.eu/law/law-making-process/better-regulation/better-regulation-guidelines-and-

toolbox_en  

9 

 
 
 
communication and outreach in this regard will be essential in order to explain and engage with 
EU partner countries notably via EU Delegations. Building on this, actions will be envisaged and 
prepared to support EU partners to fulfil the enhanced ecodesign requirements. 

3.2. 

Information on all parts of the value chain: the digital product passport 

A key pillar of the ESPR is  the  digital product passport. Every product  for which ecodesign 
measures  will  be  adopted  will  have  a  digital  product  passport,  except  if  there  is  an  alternative 
digital  system  providing  equivalent  information,  for  example  the  EPREL (20)  database  for 
energy-related  products  carrying  an  energy  label.  This  will  open  up  data  access  on  a  need-to-
know  basis  for  businesses,  consumers  and  public  authorities,  based  on  open,  non-proprietary 
international standards. The Commission has initiated the standardisation process to set rules on 
data  carriers,  infrastructure  and  data  interoperability,  which  are  needed  to  enable  the  product 
passport  system  to  develop.  The  information  to  be  collected  and  made  available  in  the  digital 
product  passport  will  be  specified  in  product-specific  delegated  acts  under  the  ESPR,  and 
possibly  under  other  legislation  where  applicable.  The  digital  product  passport  will  ensure 
traceability  along  the  value  chain  after  the  product  has  been  placed  on  the  market.  This  might 
boost  the  voluntary  deployment  of  traceability  solutions,  which  will  stimulate  market 
development  and  promote  sustainable  trade  beyond  EU  borders.  Information  on  material 
composition  and  any  substances  of  concern  in  the  product  will  be  included,  together  with 
information on how it can be safely used, recycled and disposed of. This will facilitate end-to-
end product life cycle management. 

3.3.  Empowering consumers: clear and informative labels 

The  ESPR  has  a  strong  focus  on  product  information.  Information  requirements  are  needed  to 
help consumers make informed choices and stimulate the behavioural change that can powerfully 
unlock the environmental sustainability benefits of the ESPR beyond the level achievable solely 
by regulating minimum performance. This is clearly demonstrated by the current energy label, 
which  consumers  have  rated  highly  in  providing  robust,  reliable  information  as  an  aid  to 
purchase decisions. It is widely recognised and used, increasingly via QR links from the label to 
the EPREL database with almost two million models registered by over 3 000 verified suppliers. 

The  energy  labels  will  continue  to  be  used  as  the  default  option  for  relevant  energy-related 
products,  unless  after  a  careful  assessment  it  is  concluded  that  they  are  unable  to  provide  the 
most relevant information for consumers. 

For  other  products  in  scope,  information  will  generally  be  provided  in  the  digital  product 
passport. Some products may also carry an ESPR label and/or other labels governed by specific 
EU  legislation,  such  as  the  Textile  Labelling  Regulation,  currently  under  review.  These  labels 

(20)  European Product Registry for Energy Labelling. 

10 

 
 
 
 
will provide clear and trustworthy information on relevant product features or performance such 
as  carbon  footprint,  water  consumption,  durability,  repairability  or  recyclability.  Moreover, 
under  the  Directive  on  Empowering  Consumers  for  the  Green  Transition  (21),  the  Commission 
will  establish  a  harmonised  label  for  commercial  guarantees  of  durability.  This  will  be  a  new 
product label for producers willing to promote the durability of their products and for consumers 
interested to choose for products with a longer lifespan. 

3.4.  Developing lead markets: green public procurement 

The  ESPR  provides  for  the  possibility  to  set  mandatory  minimum  requirements  for  public 
procurement in ad hoc implementing acts, whenever the products regulated by ESPR delegated 
acts  are  relevant  for  public  buyers  and  it  is  economically  feasible  for  them  to  buy  the  best 
environmentally sustainable products. These measures are designed to foster the creation of lead 
markets, stimulate investments and help the EU industry improve its competitiveness in line with 
the  Clean  Industrial  Deal’s  objectives.  The  Commission  will  assess  the  scope  to  set  those 
minimum  public  procurement  requirements  for  the  products  prioritised  in  the  working  plan 
together with the assessment of the specific ecodesign requirements for the same products.  

Despite being two separate legal acts, the  delegated act setting ecodesign requirements  and the 
implementing act setting public procurement requirements are closely linked because the product 
aspects covered in both acts must be the same. Therefore, the Commission will study and assess 
the  measures  jointly  and  run  the  two  adoption  procedures  in  parallel.  For  energy  labelled 
products,  the ELFR and  the Energy  Efficiency Directive together already  specify  requirements 
linking public procurement to the energy label class (22).  

4.  CONDITIONS FOR SUCCESSFUL IMPLEMENTATION 

4.1.  Teaming up with Member States to conduct market surveillance 

Effective market surveillance is key to ensuring that ecodesign and energy label requirements are 
implemented,  the  expected  benefits  materialise,  a  level  playing  field  for  businesses  is  secured, 
reliable product information is supplied to consumers and the framework builds trust. 

Market surveillance is a national competence with the Commission in a support and coordination 
role (23).  The  available  evidence  (24)  indicates  that  the  level  of  non-compliance  is  significant, 
leading to an estimated 10% in foregone benefits. Non-compliance associated with online sales is 

(21)  Directive  (EU)  2024/825  of  the  European  Parliament  and  of  the  Council  of  28 February  2024  amending 
Directives 2005/29/EC  and 2011/83/EU  as  regards  empowering  consumers  for  the  green  transition  through 
better protection against unfair practices and through better information (Text with EEA relevance). 

(22)  See Section 6 in Commission Recommendation (EU) 2024/1716 of 19 June 2024 setting out guidelines for the 
interpretation of Articles 5, 6 and 7 of Directive (EU) 2023/1791 of the European Parliament and of the Council 
as regards energy consumption in the public sector, renovation of public buildings and public procurement. 

(23)  Regulation (EU) 2019/1020 on market surveillance and compliance of products. 

(24)  For example, https://www.eca.europa.eu/en/publications?did=52828 

11 

 
 
 
particularly  pervasive  and  challenging  to  address,  especially  for  sales  on  non-EU  online 
platforms.  New  challenges  will  emerge  as  new  products  and  new  types  of  requirements  are 
embraced.  This  suggests  that  any  additions  to  the  Member  State  resources  spent  on  market 
surveillance would be highly cost-effective. 

The  importance  of  strengthened  enforcement  to  uphold  market  integrity  is  highlighted  in  the 
‘Letta  report’ (25).  The  ‘Draghi  report’ (26)  also  recommends  that  the  EU  should  better  support 
Member States in conducting effective market surveillance and in implementing EU rules and it 
made explicit reference to ecodesign and energy labelling. 

To  respond  to  these  needs,  and  as  announced  in  the  affordable  energy  action  plan (27),  the 
Commission  intends  to  work  with  national  authorities  to  step  up  action  on  this  front.  For 
example,  it  will  regularly  convene  the  Ecodesign  Forum  to  examine  ‘the  effectiveness  of  the 
established  market  surveillance  mechanisms’  and  discuss  any  need  for  adaptation  or 
reinforcement.  It  will  continue  supporting  national  market  surveillance  authorities  through  the 
Ecodesign  Administrative  Cooperation  Group  and  the  European  Product  Compliance  Network 
work  programme,  including  cooperation  with  customs  authorities.  To  facilitate  their  work,  it 
supports IT tools such as  the Information and Communication System for  Market  Surveillance 
and EPREL. 

to 

the  Commission  finances 

these  administrative  support  measures, 

In  addition 
the 
EUR 8 million EEPLIANT4 Concerted Action for Member State authorities covering six product 
groups over 2024-2028. It will also continue to support industry-driven compliance efforts. This 
includes  the  Energy  Efficient  Products  Portal (28),  a  dedicated  mailbox,  FAQs,  guidance 
documents  and  the  EUR 2.4 million  ‘ComplianceServices’  project.  Customs  have  an  essential 
role in supporting policy delivery for imports given the availability of information from DPP in 
the context of customs processes. Moreover, in the context of e-commerce, there is a need for an 
integrated,  data-driven  approach  to  cooperation  between  customs  and  market  surveillance 
authorities, with a focus on strategic action against non-compliant supply chains. 

4.2. 

Preventing the destruction of unsold goods 

The ESPR provides scope for the Commission to update the list of products for which a ban on 
the destruction of unsold products  applies, and to include the products  considered  for  a  ban in 
ESPR working plans. For this first ESPR working plan, the Commission does not intend to 
use this provision. It is premature because the insights gained from implementing the mandatory 
disclosure of information on the destruction of unsold consumer products (that will provide the 
basis for any bans in future working plans) are not yet available. 

(25)  Enrico Letta, Much more than a market, April 2024. 

(26)  Mario Draghi, The future of European competitiveness, September 2024. 

(27)  https://energy.ec.europa.eu/publications/action-plan-affordable-energy-unlocking-true-value-our-energy-union-

secure-affordable-efficient-and_en  

(28)  https://energy-efficient-products.ec.europa.eu/index_en 

12 

 
 
 
 
 
 
 
5. CONCLUSION 

The ESPR was established to improve the environmental sustainability of products placed on the 
EU market by reducing the overall carbon footprint and environmental footprint of products over 
their life cycle, and to enable the free movement of sustainable products in the internal market. 

This working plan is a first important step towards this objective. The new final and intermediate 
products  to  be  regulated  annually  account  for  over  EUR 1  trillion  in  annual  sales  on  the  EU 
market – around EUR 600 billion in energy-related products (29) and nearly EUR 500 billion in 
new  products  in  the  wider  scope  of  ESPR (30).  They  also  represent  a  significant  share  of  the 
environmental  impacts  of  EU  consumption  –  they  account  for  around  31%  of  climate  change 
impacts  and  34%  of  fossil  resources  use  (plus  other  impacts)  of  the  basket  of  products 
representing overall EU consumption (31). Saving energy and other resources, including through 
action to extend product lives, will reduce unnecessary consumer expenditure, saving money for 
other uses. 

By  pitching  the  level  of  ambition  sufficiently  high  and  yet  realistic,  this  working  plan  will 
contribute to the Clean Industrial Deal and the EU Competitiveness Compass, which emphasises 
that manufacturing sectors should successfully combine competitiveness with their transition to 
low-carbon  and  sustainable  production.  It  will  also  enable  stakeholders  to  get  involved  in  the 
rules-setting process, building on the success of the ecodesign and energy labelling framework. 

(29)  See 2024 Ecodesign Impact Accounting status report 

(30)  See table in section 2.2.2. (source: JRC https://publications.jrc.ec.europa.eu/repository/handle/JRC138903) 

(31)  Updated from above mentioned JRC report.  

13