The EU’s ESPR roadmap: The milestones businesses need to be aware of now

By Matthew Ekholm, Digital Product Passport and Circularity Specialist at Protokol

Over the last three years, the EU’s Ecodesign for Sustainable Products Regulation (ESPR) has developed from an uncertain legislative exercise to a clear and imminent directive for businesses across the electronics, business and furniture sectors.

Having initially come into force over the summer of 2024 in the hope of making sustainable products the norm in the EU, businesses globally are having to get to grips with the intricacies of the regulation. So far, we know who the regulation is set to affect, that being any business placing products from the priority groups into the EU marketplace. A clear requirement of the regulation is also the EU’’s mandating of Digital Product Passports (DPPs) which is being regulated across product groups.

The EU’s ESPR roadmap

As the regulation sets a range of complex requirements, which differ depending on the product group targeted, businesses looking to stay ahead of this shifting regulation should keep the following three milestones on their radar over the coming years.

Action 1: The announcement of the ESPR and its subsequent  Energy Labelling Working Plan 2025-2030 (Released in April 2025)

After the ESPR came into force in July 2024, there has been a long wait for more clarity on the task for businesses across priority sectors. Finally, in April this year, the Working Plan was published.

This has outlined a range of requirements (across vertical and horizontal categories) pertinent to businesses in each sector impacted. For example, for electronics businesses, horizontal requirements such as repairability scoring (which likely includes consumer electronics), recycled content, and the recyclability of electronic equipment will be a key focus.

At the same time, for businesses in named vertical industries, such as the textile sector, the Working Plan outlines expectations for material efficiency while reducing the impact on water and waste generation, as well as energy consumption. There are just two examples of how this regulatory update is set to advise and impact different sectors accordingly.

The Working Plan says that every product for which ecodesign measures will have to be adopted will have a Digital Product Passport (a digital record of information about the product), to open up data access for businesses, consumers, and public authorities.

Knowing early on that this will be mandatory allows businesses to start developing strategies for deploying DPPs, identifying where the necessary data resides, and engaging with DPP solution providers.

Action 2: Release of Delegated Acts (Expected 2026–2028 or later, varying by industry)

By 2027, the EU is expected to publish its first delegated acts – formal guidelines that will define the specific data requirements for DPPs across priority sectors. In some industries, however, these detailed rules may not be available until 2028 or later. Each delegated act is expected to set out what information must be collected and disclosed for the relevant product groups.

Because timelines will vary by sector, well-prepared businesses should already know where the necessary data sits within their operations and supply chains, have a clear implementation roadmap, and be ready to begin pilot initiatives with trusted partners.

Knowing early on that this will be mandatory allows businesses to start developing strategies for deploying DPPs, identifying where the necessary data resides and engaging with DPP solution providers.

Action 3: Compliance (18 months post the delegated acts being released)

The timeline for compliance is expected to be up to 18 months from the publication of each of the delegated acts; however the EU can shorten this period if it is well justified, for example, through environmental urgency or alignment with other policies.

Following the release of the delegated acts,  businesses supplying to or operating within the EU should leverage pilot learnings to strengthen their DPP implementation strategies. Those in industries with later deadlines can monitor early-priority sectors, such as iron and steel, expected to have delegated acts in 2026, to identify best practices and anticipate likely requirements for their product categories.

Even if compliance deadlines appear distant, each milestone represents a strategic checkpoint. For businesses globally, early action is especially important to align operations and supply chains with EU expectations, minimise disruption, and maintain market access.

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