European Commission's ESPR 2025-2030 action plan

On April 16, 2025, the European Commission officially adopted the 2025-2030 work plan for the Ecodesign for Sustainable Products Regulation (ESPR). This roadmap defines the priority product categories that will be subject to new regulatory requirements in the coming years.

With this text, the Commission confirms its ambition to make Europe the world leader in the circular economy by 2030, while strengthening the competitiveness of European businesses, creating lead markets for sustainable products, and facilitating consumer choice.

At Waro, we're keeping a close eye on these developments, which are profoundly redefining the expectations placed on companies in terms of product design, traceability, environmental communication and data management. Here's what you need to know.

A clear ambition: to make the European market a global driving force for sustainable products

The ESPR regulation, adopted in 2024, is part of the European Green Deal and Clean Industrial Deal. It extends the scope of ecodesign requirements to all products, far beyond just energy products (refrigerators, lamps, etc.).

Its aim is twofold:

• Reducing the environmental impact of products throughout their life cycle,
• Extended product life.
• Development of a more circular economy, focused on reparability, reuse and recyclability.

Priority products identified for 2025-2030

The plan classifies products into three categories: end products, intermediate products and horizontal requirements.

End products :

The following four categories will be subject to new specific requirements:

• Textiles (clothing): market estimated at €78 billion, very high potential for improvement in lifespan, recyclability and water/climate impact. Adoption scheduled for 2027.
• Furniture (including mattresses): a €140 billion market, with a strong focus on raw materials and waste. Adoption: 2028-2029.
• Mattresses: issues similar to furniture, focus on sorting and recycling. Adoption: 2029.

Intermediate products :

Two high-impact sectors are targeted:

• Steel/iron: a strategic issue for the EU's industrial autonomy, complementary to ETS and CBAM. Adoption: 2026.
• Aluminium: high recyclability potential and reduced emissions. Adoption: 2027.

Cross-functional requirements :

Two major areas will be covered by delegated acts applicable to several product categories:

• Repairability and durability (in particular via a reparability score).
• Recycled content and recyclability for electrical and electronic equipment.

These products account for nearly €1,000 billion in annual sales in the EU, and are responsible for around 31% of the climatic impact of European consumption.

A structuring impact on textiles and furnishings

The textile and furniture sectors are clearly highlighted in this plan. For brands, this means :

• Future eco-design obligations on sustainability, reparability, material traceability and circularity.
• Alignment with other regulations (textile labeling regulation, ESPR, CSRD).
• The arrival of the Digital Product Passport (DPP ): every regulated product will have to include a digital passport with verifiable data on its composition, recyclability, reparability and environmental performance.

The Digital Product Passport

One of the major levers of the ESPR regulation is the introduction of a Digital Product Passport (DPP). It will contain verifiable and standardized information on :

• Product composition (including substances of concern)
• Repairability, durability, recyclability
• Its environmental footprint, especially its carbon footprint
• Instructions for reuse, reconditioning and recycling

The PLR will enable companies to structure and trace their product data throughout the value chain - a major change in product information management.

What brands need to anticipate today

Structuring product data

The digital passport will require end-to-end transparency on materials, manufacturing, subcontractors and end-of-life instructions. This means structuring and collecting data at every level of the value chain.

Preparing for delegated acts

The requirements will be specified product by product through delegated acts. Brands therefore have an interest in :

• Participate in public consultations.
• Keep a close eye on the regulatory calendar.
• Identify the products concerned internally and start assessing their environmental performance.

At Waro, we already support brands in the textile and furniture sectors in :

• Measure the environmental impact of their products
• Prepare for ESPR and PLR compliance today
• Structuring the data needed for end-to-end traceability
• Co-construct a realistic compliance roadmap aligned with upcoming obligations

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