TYRES Β· ESPR PRIORITY PRODUCT GROUP

Digital Product Passports for Tyres

Tyres are an ESPR priority product group. The Commission DPP roadmap currently places adoption of a tyres delegated act in Q3–Q4 2027, an indicative target rather than a compliance deadline. Existing EU tyre labelling rules under Regulation (EU) 2020/740 are separate from the future DPP layer; product-specific DPP requirements and their application date are still pending.

Current position

Regulatory status at a glance

EU tyre labelling already applies under separate rules. ESPR provides a framework for future product-specific DPP requirements, not a replacement for the existing label.

Existing rules

EU tyre labelling

Regulation (EU) 2020/740 establishes the existing tyre-label framework; it does not itself set the future ESPR DPP dataset.

Priority

ESPR priority product group

The 2025–2030 ESPR Working Plan prioritises tyres for product-specific work.

Indicative timing

Q3–Q4 2027 adoption target

The Commission DPP roadmap places the tyres delegated act in Q3–Q4 2027. This is indicative adoption timing, not a company compliance deadline.

Uncertainty

DPP requirements are not final

Covered tyre products and classes, DPP fields, transition arrangements and application date remain pending.

Potential scope

Who may be affected

Potentially affected actors placing covered tyres on the EU market include manufacturers, importers, distributors and other economic operators. Retreading or remanufacturing actors may be affected where ultimately included. Do not assume all tyre classes or retreaded tyres will share the same DPP obligations; final applicability depends on the delegated act and each operator’s role.

Economic operators

  • Tyre manufacturers
  • Importers of potentially covered tyres
  • Retreading and remanufacturing actors where included
  • Distributors and other operators placing covered tyres on the EU market

Regulatory sequence

Tyres DPP timeline

Existing labelling obligations and the future ESPR DPP process are distinct. The delegated act will determine the product-specific DPP details.

  1. 2020

    EU tyre-label framework

    Regulation (EU) 2020/740 establishes existing EU tyre labelling requirements, separate from a future ESPR Digital Product Passport.

  2. 2024

    ESPR establishes the framework

    Regulation (EU) 2024/1781 establishes the framework for product-specific ecodesign requirements and Digital Product Passports.

  3. April 2025

    Tyres prioritised

    The ESPR Working Plan 2025–2030 identifies tyres as a priority product group.

  4. 2026

    Horizontal DPP infrastructure operational

    The Commission DPP Registry is operational as a horizontal infrastructure component; tyre-specific delegated-act requirements, fields and application date remain pending.

  5. Q3–Q4 2027Indicative

    ESPR delegated act planned

    The Commission DPP roadmap gives an indicative adoption window. This is not a company compliance or application deadline.

  6. Application dateNot yet defined

    DPP application date pending

    The DPP application date for covered tyres has not been defined.

Confirmed framework

What is already known about the DPP framework?

The ESPR framework applies where a product-specific delegated act requires a DPP. The existing EU tyre label remains a separate framework and should not be assumed to define the DPP fields.

  • Unique product identity

    A passport is linked to a persistent unique product identifier. The required identifier level for tyres will depend on product-specific rules.

  • Physical data carrier

    A DPP is accessed via a physical data carrier; its placement for tyres is not yet defined.

  • Interoperable data

    DPP data uses open standards and interoperable formats and, where appropriate, is machine-readable, structured, searchable and transferable.

  • Reliable information

    Passport information must be accurate, complete and kept up to date.

  • Product-specific rules

    Any binding tyre DPP fields and obligations will depend on the future ESPR delegated act, not on assumptions about existing labels or policy studies.

Pending delegated act

What is still to be defined for tyres?

The final relationship with existing tyre labels and systems, as well as the DPP obligations, depends on the product-specific rules.

  • Product scope

    Which tyre products, classes and exclusions are covered, including whether and how retreaded tyres are included.

  • Required DPP data

    The final fields are not defined; existing tyre-label parameters and policy proposals are not automatically DPP fields.

  • Passport granularity

    Whether the passport applies at model, batch or individual-item level.

  • Data-carrier placement

    Whether the carrier belongs on the tyre, packaging or accompanying documents.

  • Access rights

    Which information will be public or restricted to defined actors.

  • Existing labels and systems

    How future DPP requirements will relate to existing labelling and product-data systems without assuming replacement or duplication.

  • Not yet defined

    Application date

    The DPP compliance start has not been defined.

  • Responsibilities

    Specific obligations for manufacturers, importers, distributors and other economic operators remain to be set.

Provisional only

Possible data categories to prepare for

These categories are provisional preparation areas, not a final or mandatory DPP field list. Current tyre-label parameters and policy proposals must not be treated as settled DPP requirements:

  1. 01Product identification and tyre classification
  2. 02Technical and product characteristics
  3. 03Material and composition information
  4. 04Recycled-content and recyclability information where required
  5. 05Durability, mileage and abrasion-related information where required
  6. 06Sustainability and environmental information
  7. 07Compliance and value-chain traceability evidence

Readiness pathway

Five steps to start now

Prepare reusable product-data foundations while the product-specific DPP rules remain open; these steps are not a compliance determination.

  1. Map tyre ranges and identifiers

    Inventory ranges, classes and product identifiers without assuming which will be covered.

  2. Locate existing evidence

    Identify existing labelling and technical data, product records and supporting evidence.

  3. Map supplier dependencies

    Trace material, recycled-content and supplier data dependencies and evidence owners.

  4. Define cross-team governance

    Connect regulatory, engineering, sustainability and product-data teams for review, access and updates.

  5. Prepare interoperable records

    Structure product records and evidence links without duplicating existing source-of-truth systems.

Ease your transition with Circlepass

Want help working through this list? We can support your team step by step.

Get help from Circlepass

How Circlepass helps

Build on existing tyre product information

Circlepass helps teams organise product records, supplier inputs, evidence, ownership and controlled updates across existing systems. This supports DPP readiness as requirements evolve; it does not replace EU tyre labelling or guarantee compliance.

Check your DPP readiness

Tyre DPP questions

Is a tyre DPP mandatory already?

No product-specific ESPR tyre DPP obligation is final at the review date. Existing EU tyre labelling requirements are separate; a future delegated act will set any covered DPP scope, requirements and timing.

How does DPP relate to the existing EU tyre label?

Regulation (EU) 2020/740 sets the existing tyre-label framework. A future ESPR DPP would be a separate layer, not an assumed replacement. The precise relationship with labels and existing systems remains pending.

Is Q3–Q4 2027 the compliance deadline?

No. Q3–Q4 2027 is the Commission DPP roadmap’s indicative delegated-act adoption window, not a company compliance deadline. The application date is not yet defined.

Which tyre products and classes will be covered?

Final scope is pending. Do not assume all tyre classes or retreaded tyres have the same future DPP obligations; the delegated act will define covered products and exclusions.

What information could a tyre DPP include?

Potential preparation areas include identification, technical and material information, recycled content and recyclability, durability-related information where required, environmental information and traceability evidence. These are provisional categories, not mandatory fields; existing label parameters are not automatically DPP fields.

Are imports affected?

Potentially. Requirements for covered products placed on the EU market can apply to imports. Specific duties will depend on the delegated act and the importer’s role and circumstances.