How do I demonstrate the share of recycled rubber?
The calculation method for the share of recycled rubber is not yet established
There is currently no established method to calculate or verify the share of recycled rubber in a tyre for the digital product passport. The ESPR (Regulation (EU) 2024/1781) does require that a product passport contains information on, among other things, material composition and recycled content, but the exact test, measurement and calculation method per product group will be established separately. For tyres, this step has not yet been taken. This does not mean that the subject is irrelevant — it means that an importer or manufacturer currently has no fixed calculation rule to check against, and therefore no way to substantiate a figure with certainty as the regulations will require.
This applies to tyres within the ESPR, not to voluntary claims outside it
This lack of clarity concerns only the mandatory, standardised method that will have to be used via the digital product passport. It is not about whether a tyre manufacturer may now already say something about recycled rubber in advertising, in a technical data sheet, or in its own sustainability report — such claims fall under other rules, such as those on misleading environmental claims, and not under ESPR data requirements. Nor is it about whether tyres will fall within the ESPR: this choice will be made in a separate delegated act that designates the product group "tyres" and sets out the concrete requirements. As long as that act does not exist, there is no legal obligation to demonstrate a share of recycled rubber via a passport. What is therefore missing here is not the idea that recycled rubber plays a role, but the harmonised method to calculate and prove that share in a way that means the same thing throughout the EU.
No fixed date yet: the method will come with the delegated act
No date has been set for when the calculation method for recycled rubber in tyres will come into force. What is certain is the way in which this will come about: the ESPR gives the European Commission the power to establish test, measurement and calculation methods per product group, and this is done via a delegated act. For tyres, that act does not yet exist. Until the moment it is published, there is no official method to fall back on, and a figure on recycled rubber therefore cannot be substantiated in the way the digital product passport will later require. As soon as the delegated act for tyres is published, the date and method will appear here.
What this means for those already working with recycled rubber
If you are already processing recycled rubber in tyres, or plan to do so, it is wise to put your own administration in order in advance, even without the definitive method being known. In practice, this amounts to a few logically sequential steps. First: document where the recycled rubber comes from, in what proportion it is processed, and via which supplier or process this happened — these source data will in any case form the basis for any calculation later, regardless of which formula is ultimately chosen. Next: keep internal test results and certificates from suppliers, even if there is currently no legally prescribed format for these, so that this data does not have to be reconstructed later. Then: arrange your own production data so that a share per batch or per tyre type can be traced, rather than only an average across the entire production line — more detailed data are easier to combine into a rougher figure than the other way around. Finally: follow the development of the delegated act for tyres, so that you know which method is chosen as soon as it is published. If you have this basis in order, you do not have to start from scratch when the method is published, but can arrange existing data according to the rules then in force.
This follows from: Article 10 and Article 39 of the ESPR
Article 10 of the ESPR (Regulation (EU) 2024/1781) describes what kind of information a digital product passport may or must contain, including data on material composition and recycled content. Article 39 of the same regulation provides that the Commission establishes the corresponding test, measurement and calculation methods for each product group via delegated acts. These two articles together explain why there is now a principled obligation to be able to say something about recycled content, but not yet a concrete, enforceable method to calculate the share of recycled rubber in tyres: that method still has to be developed and published per product group.
Those who wish to continue following this subject should best keep an eye on the publication of the delegated act for tyres and, until then, put their own source and production data on recycled rubber in order, so that a connection to the definitive method can be made later without delay.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 39 (test, measurement and calculation methods)
The regulation itself is available on EUR-Lex. We provide references per statement; you do not have to take our word for it.
What you must do concretely
What is expected of you
The share of recycled rubber in a tyre is the type of data where the question "how do we demonstrate this" is at least as important as the question "what do we enter". The ESPR requires that data in the digital product passport are reliable, verifiable and substantiated. For a figure such as a recycling percentage, this means in practice a number of separate obligations.
Calculate the percentage correctly
A share of recycled rubber is a ratio: the quantity of recycled material in relation to the total rubber composition of the tyre. Article 39 of the ESPR (Regulation (EU) 2024/1781) provides for test, measurement and calculation methods to be established via delegated or implementing acts for each product group. For tyres, that specific method is not yet established. For a company with 10 to 100 employees, this means above all that the current internal calculation model — often a proprietary Excel-based approach based on the recipe — may later need to be adapted to a prescribed calculation method. Those who now establish how the percentage is derived are in a better position than those who only retain the figure as a final result.
Substantiate the origin of the recycled material
A percentage without proof of origin is difficult to defend. If suppliers deliver recycled rubber, crumb rubber or devulcanised material, it is practically relevant to know per batch where that material comes from and what share it represents in the end product. For a mid-sized company, this often runs through the purchasing department, while the person compiling the passport has no direct visibility of it. That gap between purchasing documentation and passport data is precisely where problems arise.
Alignment with the rest of the rubber composition
The share of recycled rubber does not stand alone; it is part of the broader rubber composition included in the passport. On which data on rubber composition must I record? is explained which other elements of the composition are relevant. A recycling percentage that does not align with the rest of the composition — for example because the percentages of different material streams do not add up to a logical whole — stands out to anyone consulting the passport, whether that is a supervisory authority or a business customer.
Keep the figure up to date
A recycling percentage is not a fixed figure for the entire lifetime of a product line. If a supplier of recycled material changes, or if the recipe is adjusted, the share changes. On how often must I update the data in the product passport? is described when updating is necessary. For a recycling percentage this is relevant because the figure is directly linked to production changes that are not always immediately known to the passport responsible party.
Where things go wrong in practice
A first recurring situation: the percentage is calculated centrally by the manufacturer, but the importer who has the passport compiled has no insight into the underlying calculation method. When asked "how did you arrive at this figure" there is then no answer at hand, only the figure itself.
A second situation: the recycled material comes from multiple sources — for example partly from own return flows, partly from an external supplier of crumb rubber — and those flows are combined in the calculation without establishing which source provides which share. Once one of the two sources disappears or changes, it is no longer possible to reconstruct what the effect on the total percentage was.
A third situation: the percentage is rounded or marketed as "rounded up" to a rounder or more favourable-looking figure before it enters the passport, without the underlying calculation justifying that rounding.
A fourth situation: the share of recycled rubber is presented separately from the rest of the rubber composition, preventing a reader of the passport from verifying whether the percentage matches the total material composition stated elsewhere in the passport.
A fifth situation occurs with seasonal product lines: winter tyres and summer tyres often use different rubber compounds, and a recycling percentage calculated for one seasonal type is incorrectly carried over to the other. On must I enter different data in the passport for winter tyres than for summer tyres is explained which specifications can differ per seasonal type.
What you can record
- A calculation report per product line: how the percentage of recycled rubber has been calculated, with which input data and at what point in time.
- Source documentation of the recycled material per supplier or batch, including the share that batch represents in the total rubber composition.
- A link between purchasing administration and the person or department that compiles the passport, so that changes in material flows are communicated in a timely manner.
- An overview of the complete rubber composition per product line, in which the share of recycled material has a verifiable place alongside the other components — see also which data on rubber composition must I record?.
- A dating agreement: at what point a change in the recycling percentage warrants an update to the passport, and who is responsible for it.
- An internal agreement on rounding: what degree of rounding still aligns with the underlying calculation, so that the published figure remains defensible.
Once the specific calculation method for tyres is established via a delegated or implementing act pursuant to Article 39 of the ESPR (Regulation (EU) 2024/1781), it will be reflected here. Until then, it is primarily the substantiation — not just the figure — that makes the difference between a passport that withstands scrutiny and a passport that raises questions.
This is not legal advice. This page provides general information about the legislation that this platform concerns. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections are given priority.