Insights / ESPR (Ecodesign)
The ESPR Working Plan: Which Product Groups, and When
Which product groups does the ESPR working plan cover, and in which years?
The Commission's first working plan under Article 18 of Regulation (EU) 2024/1781, COM(2025) 187 of 16 April 2025, gives indicative years for adopting delegated acts: iron and steel 2026, aluminium 2027, textiles and apparel 2027, tyres 2027, furniture 2028, mattresses 2029, repairability (horizontal) 2027, recycled content and recyclability of electrical and electronic equipment (horizontal) 2029, and among the energy-related products carried over, electric motors and variable speed drives 2028 and EV chargers 2028. These are adoption years, not dates the requirements apply; the plan itself imposes nothing.
What the act says
- Article 18(3): The working plan lists priorities and estimated timelines; it creates no requirement.
- Article 4(4): A delegated act applies no earlier than 18 months after its entry into force, save in duly justified cases.
- Power transformers and PV: The plan sets no new adoption year for them; Regulation (EU) No 548/2014 keeps applying to power transformers.
What to do
- Treat the year as the earliest point a rule could be adopted, then add at least 18 months for it to apply.
Sources
- Regulation (EU) 2024/1781 (ESPR) (CELEX 32024R1781)
- COM(2025) 187 final, ESPR working plan 2025 to 2030
Last checked against the act text on 2026-10-20. For information only, not legal advice.