The European Commission today unveiled its first Working Plan under the Ecodesign for Sustainable Products Regulation (ESPR), an important first step towards making products sustainable by design – but the plan does not live up to the hard-won promises within the regulation, warns the European Environmental Bureau (EEB). 

Adopted last year, the ESPR mandates minimum requirements on efficiency, durability, recyclability, and other environmental criteria for most products sold in the EU. The newly published Ecodesign Working Plan outlines which product categories will be prioritised for ecodesign measures over the next five years. However, the plan falls short of expectations, say environmental NGOs.

The Working Plan includes several product categories prioritised under article 18 in the final text of the ESPR (textiles, furniture, tyres, steel aluminium) and horizontal requirements for repairability, recycled content and recyclability of electrical and electronic equipment. However, it omits key categories such as chemicals, footwear, paints, and lubricants – despite strong calls from civil society to include them. It also fails to address other high-impact sectors such as plastics, cement, and renewable energy infrastructure. As Europe scales up renewable energy under the Clean Industrial Deal, this is a missed opportunity to ensure these installations meet the highest ecodesign standards, regrets the EEB.

Moreover, the Ecodesign Working Plan does not address further product types such as plastics, cement, and renewable energy installation. According to the EEB, this is a missed opportunity: as the EU plans to ramp up renewable energy under the Clean Industrial Deal, this would be the right time to set Ecodesign standards and avoid suboptimal technology lock-in.

Eva Bille, Head of Circular Economy at the EEB, said: “By leaving out entire product groups like footwear, paints, or chemicals, the Commission risks weakening the potential of the Ecodesign framework. If the Ecodesign Working Plan only covers a limited set of products, then at the very least it must set the highest possible standards – and close loopholes that let low-quality goods flood the EU market through online platforms.” 

Low-quality consumer goods entering the European market via online platforms and evading EU rules is another major concern for NGOs and industries alike. These products often breach pollutant limits, lack proper labelling, and are not designed to be reused, repaired, or recycled.

“The EU must crack down on rogue traders and strengthen enforcement,” Bille added. “Without proper oversight, online marketplaces become a backdoor for environmental dumping.”