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You are at:Home»Environment»The EU’s ESPR and Working Plan update: Ensuring businesses are ready

The EU’s ESPR and Working Plan update: Ensuring businesses are ready

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Posted By Editorial Team on May 14, 2026 Environment, Features

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

Matthew Ekholm, Digital Product Passport and Circularity Specialist at Provenant
Matthew Ekholm, Digital Product Passport and Circularity Specialist at Provenant

Businesses in the EU generate approximately 166 million tonnes of waste every year, demonstrating just how much urgency there is to prioritise sustainability and protect the future of the planet.

In today’s marketplace, embracing sustainable practices is no longer optional; it’s becoming a defining factor for business success in the new era of consumerism. Customers are increasingly becoming more eco-conscious and looking for evidence of sustainable practices behind the products they’re buying. At the same time governments are also stepping in to accelerate change with initiatives such as the EU’s Ecodesign for Sustainable Products Regulation (ESPR) and its recently published Energy Labelling Working Plan, with the new measures being introduced to push businesses toward more circular practices.

The ESPR: EU’s Eco-Movement

The ESPR – part of the European Commission’s broader Circular Economy Action Plan – came into force in the summer of 2024 and applies to any business placing products within the applicable groups on the EU marketplace, regardless of where they are produced. As part of this, the use of Digital Product Passports (DPPs) will be mandated to hold product data pertaining to its sustainability, to encourage circular business practices. The regulation outlines the ambition for products to last longer, use less energy, be easier to repair and recycle, contain fewer harmful substances, and include more recycled content. Businesses will therefore need to start thinking ‘sustainability-first’ across all aspects of their processes and supply chain management to keep aligned with these evolving priorities.

Businesses Must Prepare: The Working Plan Update

Although the ESPR itself was announced in 2024, the 2025 Working Plan update officially listed the product groups that can expect to be prioritised by the EU movement. The updated Working Plan provides a timeline for the delegated acts (a set of requirements concerning each product group) to be announced, heightening compliance urgency for the industries it impacts, starting with iron and steel, and followed by furniture and textiles sectors, among others.

This update and its focus on the timeline for the delegated acts provides businesses with another reminder that the compliance clock is ticking. The Working Plan’s horizontal requirements, like repairability, were also highlighted in this update. This means that recycled content and recyclability of electronic equipment is an expectation from 2027 onwards, so the clock is also ticking for electronics businesses.

DPPs in the EU Action Plan

The integration of DPPs into a business’s ESPR compliance journey will be essential for those aiming to tackle the EU’s eco-demands successfully.  A digital record of a physical product, DPPs can be used to securely capture key information across a product’s lifecycle – from the materials used in production and the environmental impact of manufacturing, to authenticity information and end-of-life handling guidance. Consumers will be able to access this via a scannable QR code or barcode embedded on the product itself.

For businesses, DPPs represent more than just a compliance requirement under the EU’s ESPR: they provide a new avenue to build trust and transparency with customers. By offering visibility into the full lifecycle of a product, DPPs give consumers the necessary information to make more sustainable choices while the transparency of this data enables brands to ‘verify’ claims of sustainability, creating more trust. They also open doors for innovation in retail services. For instance, it could become easier for retailers to offer take-back programmes, resale initiatives, and other circular customer processes.

With this in mind, DPPs don’t just support compliance; they can help businesses position themselves as leaders in the move towards a circular economy.

The First Step Towards Compliance – A DPP Strategy

Most businesses selling in the EU have a big task ahead of them with the upcoming regulation and its DPP mandate.

To plan strategically for the journey ahead and prepare effectively, a recommended first step would be to assign an employee or team to be at the forefront of upcoming compliance efforts. This holds a designated team accountable for keeping the business updated on legislation, helping businesses to remain on top of industry-specific updates. Bringing in a DPP advisor would also help this team to gain a deeper understanding of the mandate’s industry-specific impact. This helps in carving out a bespoke and coherent strategy accordingly.

To ensure a smooth regulatory journey, businesses should also start mapping where critical product data currently resides – both within their own operations and across their supply chains. This process can also help identify which partner is best positioned to support the rollout of DPPs.

Once a solution has been put in place, piloting is the next logical step. Running a pilot helps businesses to test how new processes flow across supply chains and customer touchpoints. This also helps to understand operational gaps, train staff, and collect valuable insights into the scale and timing of a full rollout. With this groundwork, businesses will be ready to move quickly as new requirements take effect in the near future.

The way companies approach this legislation will shape the future of their brand. Those who view it as more than a tick-box compliance exercise, and instead see it as a chance to strengthen sustainability credentials and customer trust, will stand out against competitors.

 

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