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# Working Plan

> The Commission plan that sets out which product groups are prioritised for ecodesign requirements, and in what order they will be addressed.

## 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

#### If a product group is in the working plan it is regulated

It is prioritised, not regulated. Obligations begin with an adopted delegated act, according to
the current Working Plan sequence.

## Related Terms

* [Delegated Act](/docs/knowledge-base/glossary/delegated-act)
* [ESPR](/docs/knowledge-base/glossary/espr)
* [Entry into Force](/docs/knowledge-base/glossary/entry-into-force)

## Related Knowledge Base Articles

* [Which Products Will Require a Digital Product Passport?](/docs/knowledge-base/regulations/which-products-will-require-a-digital-product-passport)
* [What Are Delegated Acts?](/docs/knowledge-base/regulations/what-are-delegated-acts)

## Related Articles

* [Entry into Force](/docs/knowledge-base/glossary/entry-into-force)
* [Authorised Representative](/docs/knowledge-base/glossary/authorised-representative)
* [Conformity Assessment](/docs/knowledge-base/glossary/conformity-assessment)
* [Corrective Action](/docs/knowledge-base/glossary/corrective-action)
* [EU Declaration of Conformity](/docs/knowledge-base/glossary/eu-declaration-of-conformity)
* [Harmonised Standard](/docs/knowledge-base/glossary/harmonised-standard)
* [Market Surveillance](/docs/knowledge-base/glossary/market-surveillance)
* [Market Surveillance Authority](/docs/knowledge-base/glossary/market-surveillance-authority)

## See Also

* [Regulations](/docs/knowledge-base/regulations/overview)
* [Governance & Assurance](/docs/knowledge-base/compliance-frameworks/overview)

## References

* Regulation (EU) 2024/1781, Article 18:
  [https://eur-lex.europa.eu/eli/reg/2024/1781/oj](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](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52025DC0187)

## About This Article

About This Article

<dl>
  <dt>
    Last Reviewed
  </dt>

  <dd>
    2026-08-09
  </dd>

  <dt>
    Next Scheduled Review
  </dt>

  <dd>
    2027-08-09
  </dd>

  <dt>
    Article Version
  </dt>

  <dd>
    1.0
  </dd>
</dl>

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.

## Related Docs

* [Regulations](/docs/knowledge-base/regulations/overview)
* [Digital Product Passports](/docs/knowledge-base/digital-product-passports/overview)
* [Glossary](/docs/knowledge-base/glossary/overview)