I Have Heard About ESPR Delegated Acts: What Do They Mean for My Sector?
Persona: Product Development Manager, manufacturing company, Europe
It depends on your sector.
The DPP does not have a single entry-into-force date. It works through three legislative layers that are activated sequentially.
Only the third layer — the sector-specific delegated act for your product category — establishes the concrete deadline that applies to your business.
The First Level: The Framework Regulation
The ESPR Regulation (EU) 2024/1781, which entered into force on 18 July 2024, does not say: “the DPP for furniture becomes mandatory in 2028.”
Instead, it establishes the framework:
- what a DPP must contain;
- how it must function from a technical perspective;
- who is responsible;
- what market surveillance authorities and customs authorities must verify.
It defines the architecture — not the timeline.
The Second Level: The Working Plan
The European Commission publishes a multiannual Working Plan that identifies which product categories will be addressed first.
The 2025–2030 Working Plan (COM(2025) 187 final) identifies the priority areas for this phase, including:
- iron and steel;
- textiles and apparel;
- furniture;
- tyres;
- construction products;
- and other product groups.
The first formal review is expected in 2028, when additional sectors may be included.
The Working Plan establishes the timeframe within which the Commission commits to adopting sector-specific delegated acts.
These are not compliance deadlines. They are deadlines for the start of the regulatory process.
The Third Level: The ESPR Delegated Act
The delegated act is the actual regulatory trigger.
It is a Commission delegated regulation specific to a product category.
It defines:
- which information the DPP for that product must contain;
- which Ecodesign requirements apply;
- which parameters must be declared and verified.
Once the delegated act enters into force, and after a transitional period of at least 18 months, the DPP becomes mandatory for those products.
Before that point, there is no formal legal obligation.
So, Can I Wait Until My Delegated Act Is Published?
No.
And this is the part that matters most.
The delegated act establishes the legal obligation. But the market moves earlier.
Large retail groups, tier-one manufacturers, and international purchasing organizations are already asking suppliers for structured product data:
- composition;
- carbon footprint;
- material traceability.
Not only because of their own ESG commitments.
Often, they need this information because their own customers — who are subject to ESPR requirements — must include these data points in their DPPs and are requesting them upstream throughout the supply chain.
Companies unable to provide this information risk losing business before their sector’s delegated act is even published.
I refer to this phenomenon as “silent deselection”: suppliers are not excluded through a formal notification. They simply stop receiving requests for quotation.
The three-level structure exists to determine when the legal obligation will arrive. The window to build a competitive advantage is now, before the regulatory switch is activated. The ESPR delegated act mechanism is not a bureaucratic complication. It is the way the European Union ensures that each sector receives rules calibrated to its own value chain.
Understanding this mechanism means knowing what to expect — and, more importantly, how much time is actually left.
