Does the digital product passport also apply to retreaded tyres and tread renewal?

The answer is not yet fixed for retread tyres

Whether the digital product passport will also apply to retread tyres and tread renewal is currently unclear. The ESPR (Regulation (EU) 2024/1781) is a framework regulation: it governs how the passport works and for which types of products the instrument can be deployed, but does not itself determine which product groups will actually be covered and with what exceptions. This is done per product group in a separate, later regulation (a delegated act). For tyres, that regulation does not yet exist, and therefore it is also not yet clear whether retreaded tyres will be treated separately, included under the same rules as new tyres, or conversely excluded.

What is and is not covered by the ESPR

The ESPR concerns "products": tangible goods placed on the market or put into service (Article 1 and Article 2). This is a broad definition, and on that basis it is in principle not possible to rule out that a retread tyre might eventually fall within the passport requirement — a retreaded tyre is after all placed on the market again. However, the regulation makes no distinction at this general level between a new tyre, a used tyre and a tyre that has undergone a tread renewal process. That distinction — and the question of whether tread renewal is seen as placing a product on the market again, or rather as a form of repair or refurbishment that falls outside the core of the regulation — is precisely the kind of choice that belongs in the product-specific rules for tyres. As long as those do not exist, the definition does not yet apply specifically to retread tyres, nor to new tyres either: there is currently no passport requirement in force for any type of tyre.

No fixed date, but an announced process

There is no fixed date on which the passport for tyres — let alone for retread tyres — becomes mandatory. What is certain is that the European Commission has announced a delegated act in its ESPR work plan 2025-2030; that act still needs to be published. Only in that act will it become clear whether, and if so on what conditions, retreaded tyres will receive their own passport, be linked to the passport of the original tyre (the carcass tyre), or remain outside the scope. Until that publication, there is no passport requirement for retread tyres, and nothing will change in practice for what an importer, wholesaler or fleet manager already documents.

What this means for those working with retread tyres

For those already dealing with tread renewal, the most practical step for now is: do not rush ahead, but do get the basics in order. Concretely, this comes down to the following, in the order it is usually tackled. First: map out what data is already available about the origin of the carcass, the material used for the new tread and the renewal process itself — this is information that could become relevant in a future passport, regardless of how the precise rules turn out. Then: continue to distinguish in your own records between new tyres, used tyres and retreaded tyres, so that a future link to a specific product category does not have to be worked out retroactively. Next: monitor the publication of the delegated act for tyres, because only then will it become clear whether retread tyres will receive their own passport or fall under the passport of the original tyre. And finally: if in doubt about a specific situation, consult the official texts once they are published, rather than relying on assumptions ahead of that publication.

What this is based on: Article 1 and Article 2 of the ESPR

This explanation follows directly from the structure of the regulation itself. Article 1 of the ESPR (Regulation (EU) 2024/1781) describes the subject matter and scope: a framework for ecological sustainability requirements on physical products, with the digital product passport as one of the instruments within it. Article 2 provides the definitions that determine when something counts as a "product" and when something is "placed on the market". Both articles are formulated generically and apply to all product groups in general terms; they contain no specific provision on tyres, retreaded tyres or retread work. That specification must still come, per product group, via a delegated act — and as long as it is not in place, the question about retreaded tyres remains unanswered based on the legal text that is currently available.

Those wishing to keep track of this subject would do well to monitor the publication of the delegated act for tyres and get their own data on carcass origin and retreading process in order in the meantime — not because it is mandatory now, but because it will make the transition easier once the rules are in place.

What this is based on

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

Retreaded tyres (tread renewal) sit at the intersection of two questions: is it a "new" product, and does it fall under the product category for which the delegated act will establish requirements? The ESPR itself does not yet provide a clear answer to this. Article 1 of the ESPR (Regulation (EU) 2024/1781) describes how the regulation creates a framework in which requirements are established per product category through a delegated act — for tyres, that act does not yet exist. Article 2 provides the general definitions of the regulation, but a specific definition of "retreaded tyre" or "tread renewal" is not included. What follows below is therefore a description of the issues that become relevant, not a ruling on how they will be resolved.

Determining whether tread renewal qualifies as a production process

Practically speaking, the first question turns on this: is a retreaded tyre regarded as the same tyre receiving a second life, or as a new product being placed back on the market? That distinction determines whether a new digital product passport is needed, or whether the existing passport of the original tyre (if one exists) continues to apply with an amendment. For a company that carries out tread renewal as a business activity, this means that the administration for incoming and outgoing tyres must account for the fact that this classification is not yet established. A tyre that enters the company with an existing passport and leaves the company as a retreaded tyre may later fall under a different passport obligation than is currently assumed.

Maintaining origin registration of the base tyre

Regardless of how the delegated act regulates this in future, it is administratively sensible to know which base tyre (the "carcass") a retreaded tyre originates from. This aligns with what more generally applies for which data will be in the product passport for tyreswhen data on material origin and production history must be included, this can only be provided for a retreaded tyre if the base tyre is traceable. For a company of this size, this often means an adjustment to the internal registration system, so that the link between base tyre and end product is not lost.

Following the definition of the product category "tyres"

Whether retreaded tyres fall under the product category that the Commission will designate for tyres is a matter of scope-setting that will be established in the delegated act itself. That process is described on the page on what a delegated act is and why it determines what must happenthat act is published, it cannot be said with certainty whether tread renewal falls within or outside the scope. This is not a shortcoming of this article, but the state of the regulation: the general question of which products from the tyre industry fall under the ESPR is addressed on the page on the scope of the ESPR for the tyre industry, and retreaded tyres are one of the outstanding sub-questions there.

Where things go wrong in practice

A few situations in which companies working with tread renewal encounter unclear provisions:

A tyre company takes in rejected tyres with an existing passport, renews the tread, and sells the tyre on without reassessing the passport status — on the assumption that the original passport automatically continues to apply. Whether that is the case depends on how the delegated act classifies tread renewal.

An importer of retreaded tyres assumes that the obligation rests in any case with the manufacturer of the original tyre, and not with the company carrying out the renewal. Who bears responsibility within a supply chain is determined by the definitions and obligations established by the delegated act — these do not yet exist for tyres.

A fleet manager who purchases retreaded tyres for the truck fleet assumes that, because the tyre receives a second life, no passport is needed because it is "not a new product". Here too, this assumption cannot yet be supported by an established rule.

A small tread renewal company thinks that the size of the company justifies an exception. Whether and how company size plays a role is described on the page about the product passport and small businesses — but that concerns company size in general, not specifically about retreaded tyres, and therefore does not provide a direct answer to this doubt.

A company that tests retreaded tyres with a fleet customer before proceeding to regular supply confuses this test phase with the question discussed under trial batches and samples; that concerns a different scenario (unsold test tyres) and is not directly applicable to retreaded tyres that are sold.

What you can record

Even without the delegated act in place, it is worthwhile to get a number of things in order now, so that a company does not have to reconstruct what happened when the act is published:

A record per retreaded tyre of the origin of the base tyre (brand, model, year of production, any existing passport or identification number)
An overview of the company's own tread renewal process: which steps are performed, which materials are added, and which parts of the original tyre are retained
An internal note on the assumption that the company currently applies (for example: "we provisionally assume that the existing passport remains applicable"), so that this assumption can be revised later without losing the underlying practice
Contact details and agreements with base tyre suppliers on sharing passport data, insofar as already available
A reference to the date on which this article was updated, to make clear which information is still based on the current state of the ESPR and which is based on a later delegated act

Anyone who wants to know what the passport will look like in terms of content once it becomes mandatory can read that on the page about what a digital product passport for tyres is exactly. For the broader planning of when the obligation for tyres as a product group comes into effect, the page about when the product passport becomes mandatory for tyres is the designated source. As soon as the delegated act for tyres is published and retreaded tyres are given a place in it, this article will be supplemented with the rules then applicable.

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.