Early Signals from the EU’s Preparatory Work for Future ESPR Delegated Acts on Electronics, Textiles and Iron & Steel

This blog was originally posted on 29th June, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY CRISTIAN BARROSO, REGULATORY COMPLIANCE SPECIALIST, ADHERENT

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Table of Contents

• Introduction
• A Closer Look at Iron and Steel Products
• What About Textiles?
• Horizontal Measures for Electronics
• Conclusion

Introduction

The Ecodesign for Sustainable Product Regulation (EU) 2024/1781 (ESPR) has a simple but ambitious goal: to make sustainable products across the European Union by imposing a new set of rules known as ecodesign requirements. These requirements will address both product performance and product information aspects, such as durability, recyclability, resource efficiency, recycled content, and disclosure of environmental and carbon impacts, among others.  

These ecodesign requirements will be developed via delegated act on a product-by-product basis over the next years and will be based on preparatory studies and impact assessments.

In April 2025, the European Commission published its ESPR Working Plan for 2025-2030, identifying products that should be prioritised for developing such ecodesign requirements over the next five years. The first batch of products identified are steel and aluminium, textiles (with a focus on apparel), furniture, tyres, mattresses and electronics according to the following timeline:

• 2026: Iron and Steel
• 2027: Textiles (apparel), tyres, aluminium and horizontal measures on the repairability of consumer electronics and small household appliances. 
• 2028: Furniture
• 2029: Mattresses and horizontal measures on recycled content and recyclability of electrical and electronic equipment

Taking the above into consideration, this blog explores the preparatory studies recently published by the EU Joint Research Centre (JRC) on textiles, electronics, iron and steel, which provide valuable insights into the likely direction of future ESPR requirements.

For more on the ESPR, read our blog ‘New Ecodesign for Sustainable Products (ESPR): Implementing Regulations on Disclosure and Destruction of Unsold Consumer Products‘.

A Closer Look at Iron and Steel Products

Iron and steel products have been identified as priority intermediate product groups in the ESPR Working Plan due to the fact that they are considered foundational materials embedded in a wide range of downstream products and infrastructure.

The Delegated Act, which is expected to be adopted in the fourth quarter of this year, will draw, among other sources, from the preparatory studies conducted by the JRC. To date, the JRC has published three draft reports still in process outlining the proposed product scope and definitions, potential ecodesign requirements and environmental performance classes, as well as the key elements of the Digital Product Passport. 

What Products Are Being Considered? 

The preparatory studies focus on five representative products: 

• Hot Rolled Coil;
• Wire Rod;
• Cold Rolled Coil Galvanised;
• Electrical Steel;
• Stainless Steel.

Hot Rolled Coil is a flat steel product produced from semi-finished slabs. It is widely used in the construction and manufacturing industries and serves as a key material for steel pipes, wires, sheets, and other products. 

Wire Rod is a long steel product primarily used in the production of steel wire and, through further processing, bright bars and other wire-based products.

Cold Rolled Coil Galvanised is a flat steel product derived from hot-rolled steel that undergoes further cold rolling and galvanising processes. It is extensively used in construction, automotive manufacturing, shipbuilding, household appliances, consumer durables, and the production of coated steel products.

Electrical Steel is a specialised flat steel product with magnetic properties designed for use in the magnetic circuits of electrical equipment, such as motors, generators, and transformers.

Stainless Steel is a corrosion-resistant steel alloy used across construction, transport, energy, industrial equipment, and consumer appliances.

The term intermediate steel products encompasses both semi-finished and finished intermediate products as understood in the industrial practice. Although certain products are referred to as “finished products” within steel production chains, they are not final products within the ESPR, as they remain inputs for further manufacturing processes. By contrast, final products are end-use goods manufactured by downstream industries, such as vehicles, machinery, appliances, and construction components, into which steel is incorporated. 

What Ecodesign Measures Are Being Considered? 

Of the 16 product aspects listed in Article 5 of the ESPR, the preparatory studies identify 7 that apply to these intermediate products:

• The presence of substances of concern; 
• Energy use and energy efficiency; 
• Water use and water efficiency; 
• Resource use and resource efficiency; 
• Recycled content; 
• Environmental impacts, including carbon footprint and environmental footprint; 
• Expected generation of waste. 

However, at this stage, the preparatory study focuses primarily on: 

• Recycled content;
• Presence of substances of concern;
• Carbon footprint, including associated performance classes.

Proposed Digital Product Passport Content

The JRC limited its analysis to identifying, structuring, and justifying the data elements to be included in the Digital Product Passport (DPP) for intermediate steel products. It emphasised that broader system-level design aspects such as technical architecture, data carriers, registry design, among others, are horizontal elements that need to be addressed in a separate delegated act.

The study proposed the following mandatory data elements:

• Product identification and classification. 

The heat number, in accordance with EN 10168, is proposed as the unique product identifier. For certain groups of products, identification could alternatively be implemented at the item level (eg, through serial numbers). 

• Producer identification and origin. 

The proposal includes reporting on the country of origin, “melt and pour” information and manufacturing date, consistent with information typically included in Mill Test Certificates (MTCs). 

• Substances of concern. 

Chemical composition data, as recorded in Mill Test Certificates (MTCs), are proposed to constitute mandatory fields within the DPP.

• Product environmental and circularity information. 

The proposed methodology for recycled content declarations is based on ISO 14021 and would require disclosure of total recycled content percentages, including a breakdown between pre-consumer and post-consumer recycled material.

The proposed carbon footprint methodology seeks to align greenhouse gas (GHG) accounting with the EU Emissions Trading System (EU ETS) and Carbon Border Adjustment Mechanism (CBAM) reporting frameworks. It is also intended to be fully interoperable with EN 15804 requirements for construction products and Environmental Product Declarations (EPDs).

On the other hand, additional voluntary information could include supplementary data reported in Mill Test Certificates and compliance documentation required under other EU legislation, such as CBAM reporting data, Construction Product Regulation (CPR) and REACH-related documentation. 

EU Call for Evidence

On 20 May 2026, the European Commission launched a public consultation as part of the preparation of the Delegated Act establishing ecodesign requirements for iron and steel products, which is expected to be adopted in the fourth quarter of 2026. The consultation is open for feedback until 12 August 2026.

According to the Commission’s initiative, the forthcoming Delegated Act is expected to introduce requirements relating to carbon footprint, recycled content, and the disclosure of key product sustainability information through the Digital Product Passport, among other measures currently under consideration.

What About Textiles? 

Textile apparel has also been prioritised under the first ESPR Working Plan, with a first delegated act expected in 2027. 

To support its development, the  JRC is carrying out preparatory work. The latest studies were published in December 2025 and May 2026 and are intended to help with the development of ecodesign requirements, including the introduction of a digital product passport. 

What is a Textile Product, and What Products Are Being Considered?

The studies provide some useful definitions for key concepts including textile fibre, textile product, textile apparel and technical textile. The definition of textile product aligns with the Textile Labelling Regulation (EU) No. 1007/2011 and refers to any product composed of textile fibres containing at least 80% textile fibres by weight.

The proposed product scope covers final textile apparel products within any of the following categories: 

• T-shirts, shirts and blouses;
• Sweaters and mid-layers;
• Jackets and coats;
• Pants and shorts;
• Dresses, skirts and jumpsuits;
• Leggings and socks;
• Underwear, 
• Swimwear, and
• Textile accessories such as hats, scarves, belts, and gloves.

Excluded from the scope are smart textiles, electronic textiles, personal protective equipment (PPE), medical devices, and toys, as well as intermediate products such as raw fibres, yarns and fabrics. 

What Product Aspects Are Being Considered? 

Of the 16 product aspects listed in Article 5 of the ESPR, the preparatory studies analyse 15 that are considered relevant for textile products, categorising them as follows:

• Physical durability, which includes physical durability, reliability and reusability;
• Maintenance; 
• Repairability, which includes repairability, upgradability, possibility of refurbishment, and possibility of remanufacturing; 
• Generation of waste; 
• Recyclability and recycled content; 
• Environmental impacts, which include environmental impacts, energy use and energy efficiency, water use and water efficiency, resource use and resource efficiency; and
• Presence of substances of concern. 

Proposed Digital Product Passport Content

The study identifies data elements that could be included in the DPP for textile products. However, it does not provide detailed guidance on IT architecture, data exchange protocols, cybersecurity, hosting models, or integration with existing industry systems. 

According to the draft study, the DPP is intended to function as a digital identity for products linking information required under different EU frameworks, helping to reduce duplication of reporting obligations over time.

The proposed data elements are organised into  four overarching categories:

• Product identification and classification.

This category includes globally recognised identifiers as well as harmonised trade and customs codes, such as the unique product ID, batch ID, model ID, ESPR product category, Product Environmental Footprint Category Rules (PEFCR) category, and commodity codes. 

• Producer information.

Producer identification would require the manufacturer or importer’s name and unique operator identifier, unique facility identifier, as well as address and contact information.  

• Product information.

Product information comprises the technical, material and performance characteristics necessary to describe them and support consumer choices, traceability, safe use and end-of-life management. 

The proposed mandatory data points refer to fiber composition, component specifications, mechanical robustness score, substances of concern, recyclability score, recycled content and origin, organic content, EU ecolabel information, product carbon and environmental footprint, manuals and instructions regarding repair and warranties.

• Compliance documentation. 

The study considers two potential compliance approaches: (i) self-declaration supported by third-party verification or conformity certification; and (ii) self-declaration, whereby the manufacturer provides a declaration of conformity together with a specified set of calculation parameters and technical documentation covering mechanical properties, recyclability, recycled content, organic content, and the product’s environmental footprint.

Horizontal Measures for Electronics

Similar to textiles, the European Commission is expected to develop a Delegated Act introducing horizontal repairability requirements for electronic products by 2027; that is why the JRC is undertaking the preparatory study supporting this initiative, with key reports published in October 2025 and April 2026. The study remains under development, and the final scope and requirements may evolve following stakeholder consultation and further analysis. 

The study is structured into two main phases:

• Phase I – Product screening and scope definition

This phase identifies product groups that may be suitable candidates for horizontal repairability requirements. It assesses products against a range of criteria, including market relevance, environmental impacts, repair potential and existing regulatory coverage. 

• Phase II – Requirement development 

Focuses on the development of design requirements, policy options and environmental assessments. It aims to determine:

• Which products may require product-specific repairability requirements;
• Which products may only be subject to overarching horizontal requirements, and
• Whether a horizontal repairability scoring system could be applied to certain product categories.

According to the JRC, a tiered approach to repairability requirements is proposed:

• Overarching requirements.  

Requirements that can be applied across a broad range of product groups with little or no adaptation to product-specific characteristics. 

• General requirements. 

Requirements that can be applied across multiple product categories, but where thresholds, metrics or performance levels may need to vary depending on the product characteristics.

• Specific requirements. 

Requirements tailored to the functionality or design of a particular product category and therefore not readily transferable to other product groups. 

What Product Groups Are Under Assessment?

The preparatory study focuses on three broad product families: consumer electronics, light means of transport and small household appliances. 

Consumer electronics are electronic products used for communication, computing, entertainment, recreation or information purposes and include:

• Audio and video equipment, such as televisions, monitors, digital signage displays, interactive whiteboards, video projectors, videoconferencing systems, speakers, amplifiers and radios;
• Wearables, including smartwatches, fitness trackers, earbuds and headphones;
• Imaging equipment, such as printers, scanners, copiers, fax machines and 3D printers;
• Home and office network equipment, including routers, gateways, switches and network-attached storage (NAS);
• Computers and related devices, including desktop PCs, laptops, smartphones, game consoles, e-readers, note-taking tablets and smart-home devices.

Light means of transport are wheeled vehicles powered by an electric motor alone or in combination with human power and equipped with batteries weighing 25 kg or less. These include:

• Electric scooters;
• Self-balancing boards;
• Monowheels; and
• Electric bicycles.

Small household appliances are portable or semi-portable electrical machines used to assist household tasks like cooking, cleaning, and food preservation. They include:

• Small kitchen appliances like microwave ovens, electric steamers, electric grills, air fryers, rice cookers, deep fryers, multi-cookers, pressure cookers, sous-vide, raclette makers, waffle makers, coffee machines, electric kettles, toasters, blenders, mixers, juice makers and food processors, electric knives, equipment for opening/sealing containers or packages.
• Personal care devices like hair dryers, hair stylers, hand dryers, electric shavers, clippers, epilators, electric toothbrushes, and skin care devices.
• Other small household appliances like electric irons, sewing machines, vacuum cleaners, air purifiers, digital scales (including smart scales), smart thermometers, and paper shredders. 

The draft study proposes excluding several products from the horizontal measure, including: 

• Products that do not fall within any of the product families, such as electronic sports equipment, garden equipment, power tools, electric and electronic toys, drones, electrical musical instruments, smart textiles, and electronic textiles.
• Products intended for professional and/or industrial use.
• Products already covered by ecodesign requirements under Directive 2009/125/EC;
• Electronic cigarettes;
• External drives;
• Power banks;
• Complex set-top boxes;
• Home and office network equipment;
• Home network-attached storage. 

It is important to note that the product analysis remains ongoing, with further findings and recommendations expected to be presented in the next iteration of the preparatory study, scheduled for publication in Q4 2026. 

Proposed Horizontal Repairability Requirements

At this stage, the study primarily focuses on developing high-level horizontal repairability requirements that could apply across all products within the scope. The proposed requirements include: 

• Spare part availability.

Manufacturers would be required to make specified spare parts available to end users and/or professional repairers for at least five years after the end of product placement on the market. Spare parts would need to be delivered within seven working days of an order being placed. 

• Spare part pricing. 

The most expensive spare part covered by the requirement should not exceed 30% of the indicative product pre-tax price. 

• Software/Firmware updates availability.

 Where relevant, manufacturers would be required to provide security, corrective and functionality updates for software and operating systems. 

• Access to repair information.

Repair and maintenance information would need to remain available for at least five years after the end of placement on the market and be accessible to end-users and/or professional repairers.

• Disassembly requirements.

Products should be designed so that specified parts can be replaced using commonly available or commercially available tools. 

• Data management. 

For products that store user data, manufacturers would be required to ensure that user data is encrypted by default using a randomly generated encryption key. 

• Factory reset functionality.

Products storing user data should include a factory reset function capable of securely deleting encryption keys and generating new ones. 

• Software barriers (pairing).

Manufacturers would be prohibited from using software mechanisms, including parts pairing practices, that prevent the replacement of components with compatible spare parts. 

Additional medium-level repairability requirements for specific products will be addressed at a later stage.

Repairability Scoring Index 

The study is also exploring the feasibility of a horizontal repairability scoring system for selected products. Product categories currently under consideration include: 

• Smart watches
• Wireless earbuds
• Headphones
• Handheld game consoles
• Speakers
• E-scooters
• E-bicycles
• Coffee machines
• Food preparation appliances
• Toothbrushers 
• Toasters; and
• Kettles.

Conclusion

The JRC’s preparatory work provides an initial assessment of the product groups and ecodesign requirements being considered under the ESPR framework for textiles, iron and steel, and certain electronic products. These studies are intended to support the development of future delegated acts by identifying potential policy options and technical requirements.

While the studies offer an early indication of the possible scope and content of future measures, the final requirements and product coverage will be determined by the European Commission through the legislative process, taking into account feedback from stakeholders, Member States, and the outcomes of further technical assessments.

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