ESPR delegated acts, decoded for manufacturers
The EU’s Ecodesign for Sustainable Products Regulation is live and the real action now shifts to its delegated acts. These product‑specific rules will define what data you must share, how your Digital Product Passport works, and which performance thresholds apply. If you make construction materials or supply their inputs, this is the roadmap to watch.
ESPR in one minute
The ESPR is the EU’s framework law for making sustainable products the norm. It sets the stage for product rules, a Digital Product Passport (DPP), minimum Green Public Procurement criteria, and limits on destroying unsold consumer goods. The regulation entered into force on 18 July 2024, following its publication on 28 June 2024 (Publications Office of the EU, 2024) (Publications Office of the EU, 2024).
What a delegated act actually does
Think of each delegated act as the rulebook for a product group. It can set durability or reparability requirements, cap or disclose recycled content, and prescribe which datasets must sit inside the DPP. Once drafted, it faces parliamentary scrutiny for three months, extendable to six if needed, before taking effect (European Parliament, 2025).
Who is first in line
The Commission adopted the first ESPR and Energy Labelling Working Plan on 16 April 2025. It prioritises iron and steel, aluminium, textiles and apparel, furniture, tyres, and mattresses, and it flags horizontal measures like repairability scoring and information rules that cut across groups (European Commission, 2025) (European Commission, 2025). Underpinning this, the EU Joint Research Centre recommended 18 high‑impact categories for early action, a list that also includes paints and varnishes, detergents, and lubricants, which matters for building product supply chains (JRC, 2024) (JRC, 2024).
Digital Product Passport, in brief
The DPP is a scannable product identity that holds provenance, composition, environmental performance, and end‑of‑life information. The Commission is preparing a delegated act to set requirements for DPP service providers and the core data architecture, with consultations running since late 2024 (European Commission, 2024).
Why construction manufacturers should care
Steel and aluminium are priority “intermediate products,” so upstream DPP and ecodesign rules will ripple into your downstream EPDs, specs, and buyer questions. JRC’s priority set also touches coatings, which could pull architectural paints and finishes into scope later, aligning with how project teams already evaluate VOCs, durability, and embodied carbon (JRC, 2024).
ESPR, LCAs and EPDs, together
ESPR is not an EPD regulation. Yet the overlaps are obvious. Delegated acts will ask for product‑level environmental data that you likely already collect for LCAs and EPDs. A solid EPD program becomes your data spine for DPP fields, carbon results, and future comparability. It also supports public procurement criteria and LEED v5 pathways that keep your products in play when carbon targets are tight.
Timelines manufacturers actually track
- 18 July 2024, ESPR enters into force, starting the clock on work plans and implementing steps (Publications Office of the EU, 2024) (Publications Office of the EU, 2024).
- 19–20 February 2025, first Ecodesign Forum meeting to discuss priorities and study plans (European Commission, 2025).
- 16 April 2025, first ESPR and Energy Labelling Working Plan adopted, five‑year horizon with a 2028 review point (European Commission, 2025) (European Commission, 2025).
- July 2025, acts addressing the destruction of unsold consumer products planned for adoption, with reporting starting soon after in line with ESPR provisions (European Commission, 2025).
- From 2026, delegated acts begin to land for priority groups. After adoption, most will include a transition period, then parliamentary scrutiny windows apply before obligations bite (European Parliament, 2025; European Commission, 2025).
If you see headlines about “ESPR delegated acts timeline,” check the exact product group and the current stage, since preparatory studies, impact assessments, and forum discussions can shift dates.
What data to start assembling now
Map your bill of materials, recycled content, and supplier declarations. Pull verified utility, waste, and yield data for a recent reference year. For repairability and spare parts, capture SKU‑level availability and instructions. For coatings or composites, document chemical constituents and any substances of concern. Much of this feeds both EPDs and pending DPP fields, so you only collect once and reuse many times.
Avoid delays with the right workflow
Delegated acts will ask for granular evidence that crosses functions, from procurement to quality to plant managers. Teams that try to tackle this as a side‑project stall. A partner who can actually wrangle factory data, align it with the right PCR, and publish through your chosen program operator will cut calender time and rework. Speed here is not about shortcuts, it is about orchestration and audit‑ready files that stand up when rules tighten.
A note on market impact
The existing ecodesign and energy labelling framework already delivered a 12 percent reduction in EU final energy use by 2023, with an estimated 346,000 jobs linked to the transition. ESPR aims to scale that playbook to more product groups, which is why scrutiny and timelines are strict (European Commission, 2025).
Bringing it home
If you make materials or components that flow into buildings, treat ESPR delegated acts as the next chapter in product data. Get your EPD portfolio current, decide how your DPP will reference those LCAs, and assign owners for supplier outreach now. When the first acts for your category arrive, you will not scramble, you will simply plug your verified datasets into the new format and move.
Frequently Asked Questions
What is the legal status and timing of ESPR delegated acts?
They are secondary EU laws that set binding, product‑specific rules under ESPR. A delegated act enters into force unless Parliament or Council objects within three months, extendable to six (European Parliament, 2025).
Which product groups are prioritised in the 2025–2030 Working Plan?
Iron and steel, aluminium, textiles and apparel, furniture, tyres, and mattresses, plus horizontal measures like repairability scoring and cross‑cutting information rules (European Commission, 2025).
How do ESPR and the Digital Product Passport affect EPDs?
EPDs remain the recognised, third‑party verified way to communicate life‑cycle impacts. ESPR’s DPP and information rules will likely reuse LCA results and documentation you already have for EPDs, reducing duplicate work if your data is organised.
Are paints and varnishes included?
They appear in the JRC’s list of 18 categories with high potential for ESPR action, which informs Commission priorities even if not all groups appear in the first Working Plan (JRC, 2024).
What measurable results justify the effort?
EU ecodesign and labelling rules have already cut final energy use by about 12% in 2023, and supported an estimated 346,000 jobs, signalling why ESPR will be enforced tightly (European Commission, 2025).
About the Author
With a passion for sustainability and a love for complex data, Toby helps manufacturers efficiently collect data from across their organization and get their EPDs done right. He’s especially interested in how AI can support human expertise, helping R&D and factory teams work faster, smarter, and with less friction.
