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ESPR Working Plan Opens Consultation On First Six Product Groups

Genoa: The Commission has set the first Working Plan under the Ecodesign for Sustainable Products Regulation out for consultation, naming six priority groups that will move into delegated act drafting between now and 2030. Textiles, furniture, mattresses, iron and steel, aluminium, and tyres carry the front-loaded weight. The consultation opens an eight-week window for industry, member states, and civil society to push back on scope, timelines, and the level of ambition.

The Working Plan is the next operational step under Regulation 2024/1781, which entered into force in July 2024 and gave the Commission a four-year runway to populate the product-specific architecture. The flagship instrument inside that architecture is the delegated act setting performance and information requirements per product group, paired with the Digital Product Passport that follows each item across the supply chain. Apparel sits on a separate track already triggered by the unsold-goods destruction ban, and the Working Plan was specifically asked to avoid duplicating that path.

Each of the six groups arrived on the priority list through a published criteria set: environmental footprint, scale of placing-on-market value, improvement potential, and contribution to the climate and circularity targets in the 2024 baseline study. Textiles top the list on consumer exposure and waste volume. Iron and steel rank for upstream emissions. Tyres earn the slot through microplastic release and rolling-resistance gains. Furniture and mattresses combine durability and repair score gains with a fragmented internal market that the regulation can level. Aluminium reflects the energy-intensity case and the circularity gain from secondary content thresholds.

Liguria’s port-side scrap clusters and the Italian steel sector have already flagged the iron and steel and aluminium files as priorities. Federacciai is pressing for a carbon intensity definition that anchors on the EU ETS Phase IV baseline rather than the global figures circulating in voluntary schemes. Eurometaux wants the aluminium requirements drafted around recycled content shares that match smelter capacity in the bloc, with a phase-in that reflects the energy supply contracts in the heaviest-using plants. EuroFurniture associations are pressing for repair scoring that does not penalise modular assembly. The European Tyre and Rubber Manufacturers Association is asking that any rolling-resistance class be aligned with the existing tyre label rules to avoid a parallel grading system.

The Digital Product Passport sits across all six groups. The Commission is drafting a single horizontal delegated act that fixes the data architecture, with each product-specific act layering on the information fields. Industry consultation already flagged the cost of standing up parallel passports if the horizontal piece lags. The Joint Research Centre is publishing companion technical assessments through the autumn, starting with the tyres file in September and textiles in October. Each technical assessment seeds the next round of impact analysis on the product-specific act.

Member states have asked the Commission to keep the Working Plan’s adoption timeline conservative. Capitals need time to align national procurement criteria with the new requirements, which the regulation pulls in through a Green Public Procurement annex. The current Cypriot watch is expected to keep that line, with adoption likely in early 2027 if consultation lands on schedule. The Polish presidency in 2025 had already flagged the same point.

What the consultation actually moves is the level of ambition. The Commission has set out indicative thresholds for each group, with three options of high, medium, and low ambition. The high option implies a 2030 trigger; the medium and low options stretch to 2032. The decision will shape billions of euros of compliance investment for European producers, and the consultation outcome will set the tone for the next Working Plan cycle that follows in 2030. SMEs are watching the threshold debate closely; their share of the affected market sits above 35 percent across furniture and textiles, and the cost of the Digital Product Passport per product line is the single most sensitive parameter in their consultation responses.

The political optics of the Working Plan also matter for the broader Clean Industrial Deal narrative. The Commission has placed the Ecodesign file inside the wider circularity agenda that runs alongside the upcoming Circular Economy Act, and the linkage means that the Working Plan’s ambition decision will partly set expectations for the Act when its proposal lands later in the term.