Working Plan
Definition
A working plan is the multi-annual plan adopted by the European Commission under the Ecodesign for Sustainable Products Regulation setting out the product groups it intends to prioritise for ecodesign requirements, including Digital Product Passport requirements.
Expanded Explanation
The working plan is a prioritisation instrument, not a source of obligation. Being listed means a product group is queued for study, consultation and, eventually, a delegated act. It does not mean any requirement applies to that group.
The first ESPR working plan, published as COM(2025) 187, sets out the initial priorities and the indicative sequence in which they will be addressed. Product-specific duties only arise once a delegated act is adopted, enters into force and reaches its application date.
Working plans are revised. A group can move, and the indicative timing in a plan is not a legal deadline.
Why It Matters
For planning purposes the working plan is the earliest reliable signal about which portfolios are exposed and roughly when. Treating it as an obligation, however, leads organisations to build against requirements that have not been written.
Legal and Regulatory Context
Regulation (EU) 2024/1781, Article 18, provides for the adoption of working plans. This is a Commission prioritisation instrument, not yet a product obligation.
Relationship to Adjacent Concepts
The working plan feeds the delegated act pipeline, which is where obligations are actually created.
Common Misconceptions
It is prioritised, not regulated. Obligations begin with an adopted delegated act, according to the current Working Plan sequence.
Related Terms
Related Knowledge Base Articles
Related Articles
- Entry into Force
- Authorised Representative
- Conformity Assessment
- Corrective Action
- EU Declaration of Conformity
- Harmonised Standard
- Market Surveillance
- Market Surveillance Authority
See Also
References
- Regulation (EU) 2024/1781, Article 18: https://eur-lex.europa.eu/eli/reg/2024/1781/oj
- European Commission, Ecodesign for Sustainable Products Regulation working plan 2025-2030, COM(2025) 187: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52025DC0187
About This Article
tieback Knowledge is a continuously maintained reference library covering Digital Product Passports, product traceability, product compliance and related regulations. Articles are reviewed regularly as legislation, standards and implementation guidance evolve.