What Are ESPR Delegated Acts, and Why Do They Matter?
ESPR delegated acts are product-specific legal instruments issued by the European Commission under the Ecodesign for Sustainable Products Regulation. They translate the ESPR's broad framework into concrete, enforceable rules for individual product categories — covering durability, repairability, recycled content, energy use, and Digital Product Passport requirements. If you manufacture or sell physical goods in the EU, a delegated act is what actually tells you what you must do and by when.
The European Commission adopted the first ESPR Working Plan (COM(2025) 187) on 16 April 2025. It identifies six priority product groups — textiles, furniture, mattresses, tyres, iron & steel, and aluminium — for delegated acts between 2025 and 2030. Iron and steel is first (indicative adoption 2026), followed by textiles, tyres, and aluminium (2027). A mid-term review is scheduled for 2028.
How Delegated Acts Fit Into the ESPR Architecture
The ESPR itself — Regulation (EU) 2024/1781 — is intentionally general. It creates the legal basis, the governance structures, and the overarching principles. The detail lives in the delegated acts, which the Commission can adopt without going back through the full legislative process. That's what makes them powerful and fast-moving.
Each delegated act focuses on a specific product group. It defines:
- Which performance parameters apply (durability, repairability, recyclability, carbon footprint, chemical content)
- Minimum threshold values manufacturers must meet
- Information requirements, including what data must appear in the Digital Product Passport
- Conformity assessment procedures
- Transition timelines — usually 18 to 36 months after publication
Once a delegated act enters into force, it has direct legal effect across all 27 member states. No additional national transposition is required.
The ESPR First Working Plan 2025-2030
On 16 April 2025, the European Commission adopted the first Ecodesign and Energy Labelling Working Plan under the ESPR framework (COM(2025) 187 final). This document maps the five-year roadmap for delegated act development — which product groups the Commission will regulate first, what horizontal requirements it will introduce, and when businesses should expect binding obligations.
The Working Plan identifies six priority product groups, split into final and intermediate products:
| Category | Product Group | Delegated Act (Indicative) |
|---|---|---|
| Final product | Textiles and apparel | 2027 |
| Final product | Furniture and mattresses | 2027–2028 |
| Final product | Tyres | 2027 |
| Intermediate product | Iron and steel | 2026 |
| Intermediate product | Aluminium | 2027 |
Beyond product-specific acts, the plan introduces horizontal measures that cut across categories: a repairability score framework, recyclability requirements for electrical and electronic equipment, and minimum recycled content rules. These horizontal acts are particularly significant because they apply broadly rather than to a single sector.
The plan also maintains continuity with 14 energy-related products carried over from the previous Ecodesign Directive (2009/125/EC). These products — including lighting, motors, heaters, and displays — remain under existing measures during a transition period ending 31 December 2026, after which they will be governed by the ESPR framework.
A mid-term review is scheduled for 2028, at which point the Commission may add new product groups or adjust timelines based on preparatory study outcomes and stakeholder feedback.
Which Product Categories Are Coming First?
The sequencing in the Working Plan reflects both environmental impact (products with the largest footprint go first) and market readiness (where data infrastructures and standards are most advanced).
Iron and Steel (Intermediate Products)
Iron and steel is the first product group targeted for a delegated act under the ESPR, with indicative adoption in 2026. This prioritisation reflects the sector's enormous carbon footprint — steel production accounts for roughly 7% of global CO2 emissions. The delegated act is expected to focus on embodied carbon disclosure, recycled content thresholds, and information on substances of concern. For steel producers and importers, this means building data infrastructure to track carbon intensity per tonne and recycled content ratios across the supply chain.
Textiles and Apparel
Textiles ranked among the top priorities in the Commission's impact assessment. Fast fashion generates enormous volumes of waste and relies on complex global supply chains with limited traceability. The delegated act is expected to require recycled fibre content minimums, durability benchmarks, and a full textile product passport covering fibre composition, chemical use, and end-of-life instructions. The preparatory study concluded in 2024; the delegated act is targeted for adoption in 2027. Footwear is currently excluded, pending a separate study.
Tyres
Tyres are included in the first Working Plan as a priority final product group. Tyre wear is a significant source of microplastic pollution, and the sector has well-established testing standards that can be leveraged for ecodesign requirements. Expected requirements include durability benchmarks, rolling resistance thresholds, abrasion rates, and material composition disclosure. The delegated act is targeted for 2027.
Aluminium (Intermediate Products)
Aluminium joins iron and steel as a priority intermediate product. Primary aluminium production is energy-intensive, but secondary (recycled) aluminium uses roughly 5% of the energy. The delegated act will likely focus on recycled content verification, embodied carbon per kilogram, and traceability through the value chain. Indicative adoption is 2027.
Furniture and Mattresses
Furniture and mattresses are included together in the Working Plan, with emphasis on recycled and bio-based material content, durability claims, disassembly instructions, and chemical substance disclosure. Preparatory studies are ongoing. The delegated act timeline is less defined than for steel or textiles, with adoption likely in the 2027-2028 window.
Batteries (Complementary Framework)
Batteries are not part of the ESPR Working Plan. They are covered by the separate EU Battery Regulation (Regulation (EU) 2023/1542), which already mandates a battery passport for industrial and EV batteries above 2 kWh from February 2027. The two frameworks are complementary — the Battery Regulation handles batteries specifically, while the ESPR may extend requirements to battery categories not covered by that regulation in future working plans.
Energy-Related Products (Transition from Ecodesign Directive)
The Working Plan continues work on 14 energy-related products — including lighting, electric motors, space heaters, and electronic displays — that were prioritised under the previous Ecodesign and Energy Labelling Working Plan 2022-2024. These products operate under existing Ecodesign Directive measures during a transition period until 31 December 2026. After that date, they fall under the ESPR framework, and the Commission may adopt updated delegated acts with expanded requirements including Digital Product Passport obligations.
Timeline: What to Expect and When
The Working Plan (COM(2025) 187) provides indicative dates. Here is a realistic view of the key milestones, based on the plan and published preparatory study timelines:
| Product Group | Working Plan Status | Delegated Act (Indicative) | Estimated Compliance |
|---|---|---|---|
| Iron and Steel | Priority — preparatory work ongoing | 2026 | 2028 |
| Textiles (Apparel) | Priority — preparatory study completed | 2027 | 2029 |
| Tyres | Priority — preparatory work ongoing | 2027 | 2029 |
| Aluminium | Priority — preparatory work ongoing | 2027 | 2029 |
| Furniture & Mattresses | Priority — preparatory work ongoing | 2027–2028 | 2029–2030 |
| Batteries | Separate regulation (2023/1542) | Already adopted | February 2027 |
These dates are indicative and can shift. The Commission has delayed several preparatory studies due to resource constraints and stakeholder consultation requirements. But "shifting" does not mean "disappearing" — the regulatory direction is clearly set, and the Working Plan creates institutional momentum that is difficult to reverse.
How Digital Product Passport Requirements Appear in Delegated Acts
The ESPR establishes the DPP concept at the framework level. Each delegated act then specifies the data model for that product category: which data fields are mandatory, what formats are accepted, how the passport must be accessed (typically via a QR code or GS1 Digital Link), and what verification is required.
This means your DPP infrastructure needs to be flexible. A textile DPP will look different from a steel DPP. If you manufacture across categories, you need a system that can handle multiple data models without requiring a complete rebuild for each delegated act. See our DPP requirements checklist for a cross-category overview.
How to Prepare Before a Delegated Act Is Finalized
Waiting for the official publication date is the wrong strategy. Delegated acts rarely surprise anyone who is paying attention — the preparatory studies, stakeholder consultations, and draft texts circulate for 12 to 24 months before adoption. Here is what manufacturers should be doing now:
- Track the preparatory studies for your product categories. These are public documents on the Commission's website and signal what requirements are coming with reasonable accuracy.
- Engage in stakeholder consultations. The Commission actively solicits industry input. Participation can shape requirements and gives you advance notice of what "compliance" will mean.
- Audit your data availability. Most DPP requirements will demand data you probably don't have in structured form today — recycled content percentages, carbon footprint figures by lifecycle stage, substance information from suppliers.
- Select your technology platform early. Building a compliant DPP infrastructure takes time. Explore DPP platform features and compare options using our software comparison guide.
- Map your supply chain for data collection. Much of the information required will come from upstream suppliers. Starting those conversations now — rather than 6 months before a compliance deadline — is essential.
The Role of Standards Bodies in Delegated Acts
Delegated acts frequently reference harmonised standards developed by CEN, CENELEC, or ETSI. Meeting these standards creates a presumption of conformity — a legal shortcut that avoids the need to demonstrate compliance through more burdensome means.
Standards bodies have been commissioned to develop DPP-related standards, including data models and interoperability protocols. The work is ongoing, and early drafts are available for comment. Manufacturers who engage with this process gain a competitive advantage: they help shape what "standard" looks like, and they get to implementation faster than those waiting for the final published version.
Frequently Asked Questions
What is the ESPR First Working Plan 2025-2030?
The ESPR First Working Plan (COM(2025) 187) was adopted by the European Commission on 16 April 2025. It identifies six priority product groups — textiles, furniture, mattresses, tyres, iron and steel, and aluminium — for which delegated acts setting ecodesign requirements and Digital Product Passport obligations will be developed between 2025 and 2030, with a mid-term review planned for 2028.
Which product groups are in the first ESPR Working Plan?
The six priority product groups are: textiles and apparel (footwear excluded pending further study), furniture and mattresses, tyres (final products), and iron and steel plus aluminium (intermediate products). The plan also continues work on 14 energy-related products from the previous Ecodesign Directive and introduces horizontal measures for repairability and recyclability.
What is the difference between the ESPR and a delegated act?
The ESPR is the framework regulation that establishes legal authority, governance structures, and general principles for sustainable product requirements. Delegated acts are product-specific legal instruments adopted by the Commission under the ESPR's authority. They set the concrete, enforceable requirements for individual product categories — the numbers, the data fields, the timelines.
When do ESPR delegated acts come into effect?
Delegated acts typically provide 18 to 36 months between publication and the compliance deadline. Iron and steel is first, with a delegated act targeted for 2026 and compliance around 2028. Textiles, tyres, and aluminium follow with delegated acts targeted for 2027 and compliance around 2029. Timelines can shift depending on preparatory study completion and stakeholder consultation processes.
Are electronics covered by the ESPR First Working Plan?
Electronics are not listed as a priority product group in the first ESPR Working Plan 2025-2030. However, electronic displays and other energy-related electronics are covered under existing Ecodesign Directive measures that continue during a transition period until 31 December 2026. The Commission may add electronics as a new ESPR product group in a future working plan or during the 2028 mid-term review.
Do all ESPR delegated acts require a Digital Product Passport?
Not necessarily all delegated acts will require a full DPP from day one. The ESPR allows delegated acts to phase in requirements, potentially starting with information labels before moving to full DPPs. However, the Commission's direction is clearly towards DPP adoption for most priority product categories. Manufacturers should assume a DPP requirement and plan accordingly.
How can I track when a delegated act for my product category will be published?
Monitor the European Commission's Ecodesign and Energy Labelling Working Plan on the EC website. Preparatory studies — which precede delegated acts — are also public. Industry associations in your sector typically track these developments and provide alerts. The Commission also publishes open stakeholder consultations before adopting delegated acts.
Getting Started With ESPR Delegated Act Compliance
The Working Plan sets a clear direction. For manufacturers of steel, textiles, or tyres, the clock is already running. The practical steps are clear: understand the ESPR framework that governs all delegated acts, assess your product portfolio against the priority list, and start building the data infrastructure you will need regardless of which specific acts apply to you.
If you want to understand how to build a compliant passport from the ground up, read our guide on how to create a Digital Product Passport. And if you are ready to evaluate technology options, our pricing page outlines what a scalable DPP platform looks like in practice.