Tyres — ESPR Digital Product Passport
This documentation is informational only and does not constitute legal advice. The ESPR delegated act for tyres is under development and specific mandatory fields, timelines, and enforcement dates are subject to change. Consult qualified legal counsel for compliance decisions specific to your products.
The ESPR delegated act for tyres is expected between 2026 and 2027. This page documents anticipated requirements based on current Commission work programme communications and existing tyre labelling regulation (EU 2020/740). Traceable will release a tyre-specific DPP template when the delegated act is published.
Regulatory Context
Tyres are subject to overlapping EU requirements:
Existing regulation: EU Regulation 2020/740 on the labelling of tyres with respect to fuel efficiency, wet grip, and external rolling noise is already in force. Tyres sold in the EU must display an EU tyre label.
ESPR extension: The ESPR delegated act for tyres is expected to extend beyond the current energy label to mandate a full Digital Product Passport covering lifecycle sustainability data — material composition, recycled content, durability, and end-of-life information — that is not currently required.
The two frameworks are complementary, not competing. The DPP under ESPR will link to and include the existing performance label data while adding environmental lifecycle information.
Who Is In Scope
The delegated act is expected to cover tyres placed on the EU market for:
| Vehicle type | In scope | Notes |
|---|---|---|
| Passenger cars (C1 tyres) | Yes | Highest priority; largest market segment |
| Light commercial vehicles (C2 tyres) | Yes | |
| Heavy trucks and buses (C3 tyres) | Yes | May follow C1/C2 on a delayed timeline |
| Agricultural and off-road tyres | Uncertain | Likely addressed in a separate category or later delegated act |
| Retreaded tyres | Uncertain | Strong circularity arguments for inclusion; timeline uncertain |
| Two-wheel vehicle tyres (motorcycles, bicycles) | Uncertain |
Tyres manufactured exclusively for military use are excluded.
Expected DPP Data Requirements
Based on the Commission preparatory studies and the existing EU Tyre Label Regulation, the following data categories are anticipated:
Product Identity
| Field | Requirement | Description |
|---|---|---|
| Tyre designation | Mandatory | Size designation as per ISO/ETRTO standards (e.g. 205/55 R16) |
| Brand and commercial name | Mandatory | |
| GTIN / EAN | Recommended | GS1 identifier |
| Manufacturer and country of manufacture | Mandatory | |
| DOT / ECE type approval number | Mandatory | Regulatory type approval reference |
Performance (From Existing Label Regulation)
| Field | Requirement | Description |
|---|---|---|
| Fuel efficiency class | Mandatory | A–E rating (rolling resistance) as per EU 2020/740 |
| Wet grip class | Mandatory | A–E rating |
| External rolling noise class | Mandatory | Decibel value and A/B/C class |
| Snow grip (3PMSF) | Mandatory if applicable | Three-peak mountain snowflake marking |
| Ice grip | Mandatory if applicable | Nordic winter marking |
Material Composition
| Field | Requirement | Description |
|---|---|---|
| Rubber content by weight | Likely mandatory | Natural vs. synthetic rubber percentages |
| Steel content by weight | Likely mandatory | Steel cord reinforcement |
| Recycled rubber content | Likely mandatory | Percentage from reclaimed rubber (e.g. crumb rubber from end-of-life tyres) |
| Carbon black source | Likely recommended | Virgin vs. recovered carbon black |
| Substances of concern | Mandatory | Hazardous substances above REACH threshold concentrations |
| PAH (polycyclic aromatic hydrocarbons) | Mandatory | Compliance with REACH Annex XVII Entry 50 restrictions on PAHs |
Environmental Performance
| Field | Requirement | Description |
|---|---|---|
| Carbon footprint (cradle-to-gate) | Likely mandatory | kg CO₂e per tyre |
| Mileage / durability rating | Likely mandatory | Based on standardised wear testing |
| Microplastic loss per kilometre | Likely recommended | Road-wear particulate emissions |
| Recyclability | Likely mandatory | Material recovery rate at end of life |
End of Life
| Field | Requirement | Description |
|---|---|---|
| End-of-life instructions | Mandatory | Disposal instructions; ban on landfill disposal already applies in most Member States |
| Take-back scheme reference | Recommended | Extended Producer Responsibility scheme registration (where required by Member State) |
| Recycling process compatibility | Likely recommended | Material recovery route |
Supply Chain
| Field | Requirement | Description |
|---|---|---|
| Natural rubber sourcing country | Likely mandatory | Country-level traceability for natural rubber (deforestation due diligence link) |
| Due diligence policy reference | Likely mandatory | Reference to EUDR-compliant sourcing policy (natural rubber is an EUDR-regulated commodity) |
Natural rubber is a commodity regulated by the EU Deforestation Regulation (EUDR). Tyre manufacturers sourcing natural rubber will need to demonstrate that rubber is not associated with deforestation. The tyre DPP may reference EUDR due diligence statements.
Using Traceable for Tyre DPPs
Traceable's platform supports tyre DPPs through its generic product passport infrastructure. The core features — structured data forms, QR code generation, document management, supply chain data collection, and PoLI access — apply to tyre products.
How to set up a tyre product DPP:
- Navigate to Products → Create product in the Company Portal.
- Select Tyres as the product category (or use the generic category if a dedicated tyre template is not yet available — contact support@traceable.digital for early access).
- Complete available fields. Use the data categories above as a guide for what to collect from your supply chain.
- Upload EU tyre label data, type approval certificates, and any sustainability declarations in the Documents tab.
- Use the Suppliers section to send data requests to rubber and compound suppliers for composition and sourcing data.
- Publish when the DPP is sufficiently complete.
Timeline Reference
| Milestone | Expected date | Notes |
|---|---|---|
| ESPR entered into force | 18 July 2024 | Framework applies; delegated acts pending |
| Commission work plan — tyres listed | 2024 | Priority 2 category |
| Delegated act drafting | 2025–2026 | Industry consultation under way |
| Delegated act published | 2026–2027 (estimated) | |
| DPP mandatory | 12–18 months post publication | Transition period to be set in the act |
Further Reading
| Page | Contents |
|---|---|
| ESPR Overview | Full summary of EU Regulation 2024/1781 |
| Textiles & Footwear | ESPR DPP requirements for clothing and footwear |
| ESPR and Battery Regulation Intersection | How the two regulations coexist |
| Compliance Overview | EU regulatory landscape overview |