How does the tyre label relate to the digital product passport?
The tyre label and the product passport exist separately from each other
The tyre label and the digital product passport are two different obligations that exist alongside each other. The tyre label stems from Regulation (EU) 2020/740 and concerns three measurable properties of a tyre: fuel efficiency, wet grip and noise emission. That label already exists, is mandatory when tyres are sold to end-users, and will not change due to the introduction of the product passport. The product passport stems from a completely different framework, the ESPR (Regulation (EU) 2024/1781), and does not concern performance but rather information on origin, composition, repair and recycling information of a product throughout its entire lifespan. For tyres, that passport does not yet exist: we are waiting for a delegated act that establishes the precise requirements for this product category.
Who is subject to what, and where is the boundary
The tyre label applies to anyone placing tyres on the EU market for end-users: manufacturers, importers and sellers are already dealing with this, regardless of what happens with the product passport. The label concerns only the three performance characteristics mentioned and says nothing about where rubber or steel comes from, whether a tyre can be repaired, or how the material can be processed at the end of its lifespan. That latter aspect is precisely the domain of the product passport once it becomes applicable to tyres. The two instruments therefore do not overlap in content: the label is and remains a performance label, the passport will become an information file on the tyre as a product. For those already working with the tyre label, there is currently no change to that obligation; the passport will be added in the future, not in place of it.
There is no established date for the passport for tyres
For the tyre label, no separate deadline applies anymore: it is already in force under Regulation (EU) 2020/740. For the product passport for tyres, the situation is different. In the work plan of the European Commission for the ESPR (2025-2030), a delegated act for tyres is scheduled, with an expectation around 2027 for that act. When the passport actually becomes mandatory depends on when that act is adopted and what transition period it contains; a concrete implementation date is therefore not yet established. As long as that delegated act is not in place, the tyre label remains the only mandatory product information in this area. Once the act is published, the date and content of the obligation will be added here.
What this means in practice
Anyone who now imports tyres, trades in them or manages a vehicle fleet can initially assume that the tyre label will remain unchanged in its application: that obligation is separate from the passport and will not disappear. Furthermore, it is useful to know that the data that will soon be needed for the product passport - origin, material composition, repair data - is partly already present within your own organisation, just not yet in the form that the ESPR requires. It is useful to check which of that data the manufacturer or supplier already provides as standard, and which will still need to be requested separately once the obligation becomes concrete. Finally, it is prudent not to mix up the tyre label and the future passport in internal communication or on the webshop: these are two separate labels with their own legal basis, and Article 17 of the ESPR explicitly warns against labels that could be confused with an official label. Those who will display both side by side should ensure they are clearly distinguished.
The legal basis: 2020/740 and Articles 16 and 17 of the ESPR
The tyre label itself is regulated in Regulation (EU) 2020/740, which establishes mandatory labelling requirements for fuel efficiency, grip and noise for tyres. The relationship between such existing labels and the broader ESPR framework is addressed in Article 16 of the ESPR (Regulation (EU) 2024/1781), which describes the conditions under which labels can be introduced or recognised within this framework. Article 17 of the same regulation addresses the prevention of counterfeit labels: labels that in their form or appearance could cause confusion with an official label under the ESPR. For tyres specifically, the ESPR work plan provides for a delegated act for this product category, without this establishing a definitive date or content at this stage.
What to do
For now, the tyre label is the obligation to comply with; the digital product passport is something to keep an eye on, not something to prepare for already. This page will be updated once the delegated act for tyres has been published and a concrete date and content are known.
What this is based on
- Regulation (EU) 2020/740 (labelling of tyres)
- Regulation (EU) 2024/1781 (ESPR), Article 16 (labels) and Article 17 (counterfeit labels)
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 tyre label and the digital product passport are two separate obligations that exist alongside each other. The label comes from Regulation (EU) 2020/740 and already exists; the passport comes from the ESPR (Regulation (EU) 2024/1781) and must become applicable for tyres once the delegated act is in place. For a company that imports or trades in tyres, this means that shortly there will be two obligations running in parallel, with some overlapping and some different content.
The tyre label remains in place
Regulation (EU) 2020/740 mandates a label with information on fuel efficiency (rolling resistance), wet grip and noise emissions, plus optional snow and ice grip symbols. That label does not change due to the arrival of the product passport. In practice, this means that the systems and processes already in place to generate and display the label at the point of sale continue to function as they are. There is no moment at which the label is "replaced" by the passport — these are two separate obligations with their own legal basis.
The product passport arrives as a separate requirement
The ESPR provides in Article 16 that products falling under a delegated act shall have a digital passport with a QR data carrier. For tyres, this has not yet been determined — the delegated act for tyres is currently expected, but the date is not fixed. Once that act is in place, it will specify which data must be included in the passport. Some of that data is expected to overlap with what already appears on the label, such as rolling resistance and noise emissions, but the passport is intended to be broader than the label: think of data on material composition, repair and end-of-life that do not fit on a label. What exactly goes in is described on the page about which data will be in the product passport for tyres.
Preventing confusion between labels and passport
Article 17 of the ESPR addresses counterfeit labels: labels or markings that could create confusion with official labelling, or that give the impression that a product complies with requirements when it does not. For a company that places both a tyre label and a product passport QR code on or with the product, this means that the two data carriers must remain visually and substantively distinct. A QR code that unlocks the passport must not be formatted in such a way that it is confused with the official label, and conversely, a label must not give the impression that it performs the function of the passport.
Managing two carriers, two information flows
In practical terms, the combination of label and passport means that a company with 10 to 100 employees must maintain two information flows in parallel: the label data (which are fixed per tyre type according to the test method in 2020/740) and the passport data (which are broader and determined according to a method still to be established). Both flows must remain current, but not necessarily at the same time or via the same process. How often passport data must be updated is explained on the page about how up to date the data in the digital product passport must be.
Where things go wrong in practice
A first common scenario: a company believes that the passport makes the label "redundant" once the passport is available, and stops updating the label data too early. As long as Regulation (EU) 2020/740 is not amended or repealed, that obligation continues to exist separately.
A second scenario: the QR code for the passport is placed on the tyre or packaging in such a way that it visually coincides with the label, so that a buyer can no longer see which information comes from which source. This relates to what Article 17 of the ESPR seeks to prevent.
A third situation: data on the label and in the passport contradict each other, for instance because the rolling resistance class on the label has been determined according to the test method from 2020/740, whilst the passport shows a different value that was established at a different time or via a different method. How the measurement method for the passport works is explained on the page about the method for measuring the values for the passport; the rolling resistance class specifically is addressed on the page about determining the rolling resistance class of a tyre.
A fourth situation: for seasonal tyres (winter tyres versus summer tyres), it is assumed that the label and the passport follow the same classification, whilst the requirements may differ per tyre type. This is further elaborated on the page about seasonal tires and specifications.
A fifth situation: a company publishes the passport and believes the content is then fixed, whilst data must actually be able to be corrected if the underlying test results change. How that process works is explained on the page about data changes after publication of the product passport.
What you can record
- An overview per tyre type of which data appear on the label (in accordance with Regulation (EU) 2020/740) and which data will be in the passport once the delegated act for tyres has been published.
- The test reports and measurement methods underlying the label data, including date and testing body.
- A documented procedure for placing the QR data carrier next to the existing label, so that both remain clearly distinguishable.
- Agreements with the manufacturer or supplier about which party supplies which data, with a reference to the page about who may view which data from the product passport for the division of roles thereafter.
- An internal control point at which to verify that label data and passport data are mutually consistent, especially for rolling resistance, wet grip and rolling noise — the latter two are further elaborated on the pages about grip on wet road surfaces and the recording of rolling noise in decibels.
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.