Publication of priority areas for the application of the Eco-design Regulation

In a publication of 16 April 2025, the European Commission established the list of priorities for the years 2025-2030 for the implementation of the Eco-design regulation of 13 June 2024.

Regulation (EU) 2024/1781 of 13 June 2024 establishes a framework for setting requirements for eco-design for sustainable products.
This Regulation amends Directive (EU) 2020/1828 and Regulation (EU) 2023/1542, and is also intended to repeal the Eco-design Directive 2009/125/EC, whose scope was limited to energy-related products.

Unlike this Directive, the new Regulation applies to “any physical goods that are placed on the market or put into service, including components or intermediate products” in accordance with Article 1 thereof

.  These Regulations provide for exclusions such as foodstuffs, medicines or vehicles.

The new Regulation has considerably evolved, in its Article 5 and Annex I, the sustainability andecodesign by setting new criteria, such as the durability, product repairability, the ease of improvement or re-use, the  share recycled content or the fight against planned obsolescence.

The objective of this new Regulation is to set a framework for ecodesign and will require the adoption of delegated acts specific to each product category. Thus, from the publication of the delegated acts, the industry will have a minimum period of 18 months to comply with them (Article 4 (4)). The first delegated act adopted pursuant to this Article shall not enter into force before 19 July 2025.

In this context, the European Commission has defined the priority axes in the implementation of the Regulation in a work plan published on 16 April 2025. As a reminder, Article 18.5 of the Regulation already established a first list of priorities, which the European Commission specified as part of its work plan.

Indeed, the European Commission has decided that priority should be given to four final products:

• Textiles and appliances , due 2027

• Furniture, due 2028

• Tyres, due 2027

• Mattress, due 2029

With regard to the category of intermediate products, the European Commission has given priority to iron and steel, as well as aluminium, for a respective deadline of 2026 and 2027.

Finally, two legal acts will be expected to set horizontal requirements on reparability and on the recycled content and recyclability of electrical and electronic equipment.

It appears that the European Commission has excluded certain products, envisaged in Article 18 of its first work plan, which are detergents, paints and lubricants, footwear and chemicals.

Finally, the Commission focused its work plan on the need to empower consumers by providing clear information through the digital passport but also by affixing an ESPR label to products (as is the case for energy-related products that have an energy label).