ESPR's other lever: requirements that cut across product groups.

Most companies read ESPR one way: find your product group in the working plan, note the indicative date, relax if you are not listed. That reading misses half the regulation. ESPR also empowers the Commission to set horizontal requirements — rules on durability, reparability, recyclability or recycled content that apply across product groups sharing a characteristic, rather than group by group. The first working plan names such measures explicitly. If your group is not listed, a horizontal act can still reach you.

Last updated: 17 July 2026

In one line: ESPR can regulate by characteristic as well as by product group — horizontal measures on durability, repairability and recycled content are under preparation (none adopted yet), and they can reach products whose groups appear nowhere in the working plan.

Two levers, not one

ESPR — Regulation (EU) 2024/1781 — is usually explained through its first lever: delegated acts per product group, sequenced by working plans. The April 2025 working plan names textiles, furniture including mattresses, and tyres among final products, with iron and steel and aluminium as intermediates. The second lever gets less attention: the regulation allows the Commission to set horizontal ecodesign requirements — rules on a specific characteristic, such as durability or recycled content, applying across multiple product groups that share technical similarity. The same working plan flags horizontal measures on repairability and recyclability, with electronics among the areas in view. These measures are under preparation; no horizontal act has been adopted to date, so scope and timing remain to be fixed.

Why this widens the net sooner than the group-by-group reading suggests

The comfortable reading of the working plan — "we are not textiles, furniture, tyres, steel or aluminium, so this is a 2028 problem" — assumes regulation only ever arrives group by group. Horizontal measures break that assumption in three ways:

Coverage by characteristic — a repairability measure attaches to products that share the characteristic, potentially spanning groups no delegated act has named individually.
One act, many sectors — a single horizontal measure can pull whole categories, such as consumer electronics, into ecodesign obligations in one step rather than one group at a time.
Parallel tracks — horizontal preparation runs alongside the group-specific pipeline, so "our group's act is years away" says nothing about when a horizontal measure might apply to you.

None of this is a reason to panic — it is a reason to stop treating absence from the priority-group list as exemption.

What data the horizontal priorities demand

The named priorities telegraph the data homework. Durability asks for evidence of lifetime and reliability: test results, expected-lifespan figures, warranty terms. Reparability asks for disassembly information, spare-part availability and repair documentation — the raw material of repairability scoring. Recyclability asks for material composition, separability of components and the presence of substances that hinder recycling. Recycled content asks for substantiated percentages traced to supplier declarations, not estimates. Under ESPR these information requirements are delivered through the Digital Product Passport, so the practical question for any product owner is: could we populate those fields from documents we can actually produce?

Preparing without a date to aim at

Because no horizontal act is adopted yet, the honest preparation is data-readiness, not deadline-chasing. The pattern from group-specific acts — obligations biting roughly 18 months after an act enters into force — suggests the window between adoption and application will be consumed almost entirely by data collection for anyone starting from zero. Starting from organised evidence is the whole advantage. PassPer builds passport-ready records from the documents you already have — spec sheets, test reports, supplier declarations — using AI extraction with human review, sealed and hosted so they are ready to file when an act lands. The free readiness check shows which of the horizontal data themes your current documentation already covers.

Frequently asked questions

What is a horizontal requirement under ESPR?

A requirement set for a characteristic — such as durability, reparability or recycled content — that applies across multiple product groups sharing technical similarity, rather than to one group at a time. The first ESPR working plan of April 2025 names horizontal measures on repairability and recyclability, with electronics among the areas in view. These measures are under preparation; no horizontal act has been adopted to date.

Our product group is not in the first working plan. Can a horizontal measure still reach us?

Yes — that is exactly the point of the instrument. Horizontal requirements attach to a characteristic across technically similar groups, so a product outside the named priority list (textiles, furniture and mattresses, tyres, iron and steel, aluminium) can still be caught if it shares the targeted characteristic. Which groups any horizontal act covers will only be certain when it is adopted.

Do horizontal requirements come with a Digital Product Passport obligation?

ESPR pairs ecodesign requirements with information requirements delivered through the DPP, and horizontal measures can carry information duties just as group-specific ones do. The precise passport content will be set in the measures themselves, which are still under preparation — but the data themes are already visible: durability, repairability, recyclability and recycled content.

When will the first horizontal act apply?

No horizontal act has been adopted yet, so there is no date to plan against — and we will not invent one. The pattern from group-specific acts is indicative: obligations typically bite around 18 months after a delegated act enters into force. The practical consequence is that the preparation window opens when the act is adopted, not when it starts applying — and the data work takes longest.

See where you stand — three ways, all free.

Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.

Free readiness check → See it in action Get the guide (PDF)