which environmental data must be in the passport that are not on the tyre label

What you must do concretely

What is expected of you

The tyre label that consumers see in the shop shows three things: rolling resistance, grip on wet road surface and rolling noise. This is established in Regulation (EU) 2020/740. The digital product passport introduced via the ESPR is explicitly not a digital copy of that label — it is a broader information file. Article 10 of the ESPR (Regulation (EU) 2024/1781) provides that the passport contains information on, inter alia, sustainability, materials, repair and end of life of a product, and for tyres this is a considerably broader set than the three label values.

Environmental information on materials and composition

Where the label says nothing about what the tyre is made of, the passport expects data on material composition. For rubber compounds, this means that an importer or manufacturer must be able to provide what is in it, including any recycled material. For a company of 10 to 100 employees that imports tyres and does not manufacture itself, this mainly means: request the correct documentation from the manufacturer and be able to pass it on to the passport file. What exactly must be recorded on rubber composition and on the proportion of recycled rubber is set out on the corresponding pages.

Environmental information on origin and service life

The label says nothing about where a tyre comes from, how long it lasts under normal use, or what happens to the tyre after the end of its service life. Article 10 is focused precisely on that kind of data: information relevant to circularity, such as repair, reuse and recycling. For a wholesale distributor or fleet manager, this means that the passport does not only replace a technical label, but also contains information that was previously not available in a structured form anywhere.

Consistency between label and passport

Article 16 of the ESPR governs how labels relate to the passport, and Article 17 prohibits counterfeit labels that give the impression that they are an official label without being one. For practical purposes, this means that the label values already known from Regulation (EU) 2020/740 will be included in the passport, but that no second, divergent version of those same values may arise. Anyone who places their own summary label on the packaging that does not match the passport data runs foul of this provision. How the official label relates precisely to the passport is set out on the page on tyre label and product passport.

Measurement methods for the additional data

For the three label values, test methods are already established under Regulation (EU) 2020/740. For the additional environmental information in the digital product passport, Article 39 of the ESPR provides for test, measurement and calculation methods to be determined in more detail per product group. For tyres, this has not yet been detailed at the level of a delegated act for the supplementary environmental information. This means for a company that the obligation to provide data is already fixed in the basic regulation, but the precise way of measuring and calculating per data point still needs to be established or published. What is known about this so far is available on the page on the measurement method for the passport values.

Where things go wrong in practice

An importer sends the test report from the tyre label through as "environmental information" for the digital product passport, while the passport also expects data on material composition and end-of-life. The label alone is therefore not sufficient.

A wholesaler takes data from the manufacturer one-to-one without checking whether it concerns the correct tyre-type variant. For tyres that are supplied in summer and winter versions, underlying specifications may differ, and that is something different from just a different label. What specifically applies to that is described on the page on seasonal tyres and specifications.

A manufacturer places its own "environmentally friendly" symbol on the packaging, alongside the official label, without this symbol being substantiated anywhere in the digital product passport. This conflicts with the prohibition on misleading or counterfeit labels in Article 17 of the ESPR.

A company collects the environmental data once at first import and assumes that it will remain valid for the entire life of the product, while the composition or origin of a later production batch may differ. How often data must be updated is a question that is addressed separately on the page on the currency of digital product passport data.

An importer who prefers not to share sensitive production information simply leaves a field in the digital product passport blank without investigating whether there is a way to include the information without disclosing trade secrets. This assessment should not happen silently; see the page on business-sensitive data.

What you can record

• The test report and the underlying measurement data from the official tyre label, stored separately from the supplementary environmental information for the digital product passport.
• Manufacturer documentation on material composition, including any indication of recycled material per tyre type or production batch.
• An overview per tyre type (and per seasonal variant, where applicable) of which environmental data are already available and which are still missing.
• Correspondence with the manufacturer or importer recording who provides which data and at what point in time.
• An internal overview of which data are considered business-sensitive and what substantiation has been used for this.
• A fixed procedure for updating data when there are changes in composition, origin or manufacturing process.

A complete overview of which data belong in the digital product passport of a tyre, regardless of what is already on the label, can be found on the page on the data in the digital product passport for tyres.