European Commission Releases List of Priority Products for Ecodesign Requirements

On April 16, 2025, the European Commission (Commission) published its first working plan under the Ecodesign for Sustainable Products Regulation (ESPR) for the period 2025 to 2030.

The ESPR itself was adopted in 2024. It aims to introduce ecodesign requirements for virtually all products sold on the EU market. The ecodesign requirements will take the form of (i) performance requirements (in light of a list of 20 potential parameters, such as durability, reusability, repairability, energy efficiency, recyclability, and carbon and environmental footprints) and/or (ii) information requirements (e.g., on product performance and treatment).

The ESPR mandated the Commission to develop ecodesign requirements per specific product group or horizontally across a broader product group (see Sidley Update, here). The ESPR also mandates the Commission to adopt working plans for the implementation of the ESPR, which must cover a minimum three-year period, with the first to be adopted in 2025.

In the first working plan, the Commission identified the priority product groups for which it will develop the first set of ecodesign requirements.

The Commission’s priority list, with indicative timelines for adoption, covers the following:

• four final product groups: (i) textiles/apparel (2027), (ii) tires (2027), (iii) furniture (2028), and (iv) mattresses (2029)
• two intermediate product groups: (i) iron and steel (2026) and (ii) aluminium (2027)
• two horizontal requirements: (i) repairability (2027), with product scope still to be determined, and an indication that it could include consumer electronics and small household appliances; and (ii) recycled content and recyclability of electrical and electronic equipment (2029)
• a list of 16 energy-related products carried over from an earlier working program under the prior Ecodesign Directive, such as dishwashers (2026), EV chargers (2028), fridges and freezers (2028), electric motors (2028), and mobile phones and tablets (2030)

The priority list does not include other product groups, such as, notably, chemicals, footwear, detergents, paints, and lubricants.

For the priority list of products, the Commission will develop ecodesign requirements in delegated acts, based on the indicative timelines set out above. Stakeholders will have opportunities to provide input in the development thereof. As mandated by the ESPR, the Commission established an Ecodesign Forum, composed of experts designated by member states and other interested parties (e.g., industry representatives, importers, consumer organizations, unions, researchers), as well as a Member States Expert Group. The ESPR mandates the Commission to take the views of these groups into account when developing the ecodesign requirements. This approach aims to guarantee that the requirements are shaped by thorough technical analysis and broad stakeholder engagement.

The Commission also recognizes that the new requirements will have “significant implications” on trading partners, as all goods placed on the EU market — including imports — will have to meet the new ESPR standards. The Commission, therefore, promises to assess carefully the implications on third countries. When developing ecodesign requirements, the Commission will also pay attention to the needs of small and midsize enterprises, particularly microenterprises and small mid-cap enterprises.

The Commission has also indicated that every priority product category will need to have a digital product passport (unless an alternative digital system exists), providing need-to-know data access for businesses, consumers and public authorities, and enabling product traceability along the value chain.

The ESRS provides for the possibility to set mandatory minimum requirements for public procurement whenever the products are relevant for public buyers and it is economically feasible for them to buy the best environmentally sustainable product. For each product group, the Commission will, with the specific ecodesign requirements, also assess whether to develop such procurement requirements (they would be developed in separate delegated acts). Finally, while the ESPR bans the destruction of unsold apparel and footwear products, the Commission does not currently intend to use its mandate to expand the list of products subject to this ban.