Does the digital product passport apply to my tyres?

What you must do concretely

What is expected of you

The ESPR (Regulation (EU) 2024/1781) is a framework regulation. Article 1 makes clear that the regulation itself does not designate a product category — this happens per product category via a delegated act. For tyres, this means that the question "does it apply to my tyres" cannot currently be answered with a simple yes or no: the framework rules are in place, but the specific requirements for tyres are not yet. What can already be read from it, however, is the structure within which this will take place.

Determine whether your product type falls within the designated category

Article 1 of the ESPR establishes that the regulation applies to products designated via a delegated act. For a company with 10 to 100 employees, this means in practice: checking which tyre types are in the current assortment (car tyres, light commercial vehicle tyres, heavy commercial vehicle tyres, motorcycle tyres, industrial tyres) and comparing that breakdown against the final designation once it is known. Not every tyre type needs to automatically fall under the same rules. An overview of which products from the tyre sector are under consideration is available at which tyre sector products fall under the ESPR.

Monitor which delegated act will apply

Article 1 links the scope to a delegated act that has yet to be published. For a company, this means that internal planning cannot be based on the ESPR text itself, but on a separate, later publication that appears per product category. Waiting until that act is published is therefore not procrastination but the only way to know exactly what will apply. What a delegated act is precisely and why it determines what you must do is explained at what is a delegated act and why does it determine what I must do.

Distinguish between "falling under the ESPR" and "needing a product passport"

Article 9 of the ESPR regulates the digital product passport itself, but that article only enters into force for a product category after the delegated act for that category has established the passport requirement. For a company, this means that "tyres fall under the ESPR" and "tyres require a product passport" are two separate steps, with a possible time difference between them. What a digital product passport for tyres entails and what it means in practical terms is explained at what is a digital product passport for tyres.

Take your own position in the supply chain into account

Article 1 focuses on products placed on the market, not specifically on a single link in the chain. For an importer, wholesaler or fleet manager, this means that the question "does it apply to my tyres" also depends on the role that the company plays: whoever places tyres on the EU market bears a different responsibility than whoever merely resells them or deploys them in a fleet. This distinction is not worked out in Article 1 itself, but is relevant when assessing your own position.

Where things go wrong in practice

An importer assumes that "tyres" as a whole will receive one designation date, and schedules its entire inventory for the same deadline — while car tyres and heavy commercial vehicle tyres may be assessed separately.

A wholesaler reads reports about "the tyre passport is coming" and assumes that the obligation is already in the ESPR itself, without checking that Article 1 explicitly refers to a delegated act yet to be published.

A fleet manager decides to wait with any preparation until the obligation officially takes effect, and then discovers that their own suppliers already have to provide data — meaning that the connection to their own system still has to happen under time pressure.

A company with fewer than 10 employees assumes it falls completely outside the scope without checking whether a separate provision for small companies might be included in the final delegated act.

An importer of retreaded tyres or remoulded tyres assumes that this product category is automatically included in the same delegated act as new tyres, without confirming this.

What you can record

• An overview of the tyre types that the company places on the market or trades, including EU product code or comparable classification, so that it can be quickly determined which type falls under a future delegated act.
• The date and source of the most recently consulted version of the ESPR (Regulation (EU) 2024/1781), so that it is clear which text version served as the basis for a previous assessment.
• A note on the company's own position in the supply chain (manufacturer, importer, distributor, user) per tyre type, as this position may determine which obligation becomes relevant.
• A standing appointment — for example per quarter — to check whether there is news about the delegated act for tyres, with a reference to the page that updates when the product passport becomes mandatory for tyres.
• A list of questions that remain open once the delegated act is in place, for example regarding retreaded tyres, trial batches or second-hand sales, so that these do not only emerge later.
• Contact details of suppliers and customers that are relevant for providing or receiving passport data, so that this supply chain is mapped out before the obligation comes into effect.