What data on rubber composition must I record?

What you must do concretely

What is expected of you

The rubber composition of a tyre is not standalone information: it forms part of the material information that the ESPR expects in the digital product passport. Article 7 of the ESPR (Regulation (EU) 2024/1781) lists material composition as one of the categories of information that may be relevant to the environmental performance of a product, and article 10 of the ESPR (Regulation (EU) 2024/1781) describes that the passport must contain the data resulting from the delegated act for the product group — in this case tyres. What exactly must be recorded concerning rubber composition is not yet established in a published delegated act at the time of writing. However, a number of recurring obligations can be identified from how the ESPR approaches material information in general.

Recording the materials processed in the tyre

A tyre consists of multiple rubber types, fillers, reinforcement materials and chemical auxiliaries. For a company with 10 to 100 employees, this means in practice that the composition does not only need to remain with the manufacturer, but must be traceable to the level at which that information ends up in the passport. Any party acting as an importer or distributor normally receives this data from the manufacturer and must be able to pass it on without having to reconstruct it themselves.

Demonstrating the proportion of recycled material

Where rubber from recycled sources is processed, the expectation is that this proportion is separately demonstrable, not hidden in a general material description. For companies working with multiple suppliers, this means that it must be clear per batch or per product line which part is recycled and which part is not. How that proportion is demonstrated is described on the page on how I demonstrate the proportion of recycled rubber.

Making a distinction between product variants

Rubber composition often differs between summer and winter tyres, and between versions within the same line. For a company that imports or trades multiple variants, this means that the composition must be recorded not at brand level but at variant level. A winter tyre with a different rubber mix than the summer version requires its own dataset; see also the page on whether winter tyres require different data than summer tyres.

Coherence with the rest of the passport

The rubber composition does not stand alone: it is linked to properties such as rolling resistance, grip and noise, which already have well-known measurement methods. A company collecting this data does well in practice to do so in coherence with the other fields already maintained for the tyre label. A complete overview of which data alongside rubber composition belong in the passport can be found on the page on which data will be in the product passport for tyres.

Where things go wrong in practice

The composition is recorded at brand level, not at product level. An importer records "natural rubber and synthetic rubber" for an entire tyre line, while the exact ratio varies per model or per production batch. Once substantiation is requested, the recorded information proves too general to link to a specific product.

Recycled material is mentioned, but not quantified. A supplier states that "recycled rubber" is processed in the tyre, without a percentage or substantiation. That is insufficient once a concrete proportion must appear in the passport.

Data from the manufacturer is not checked for completeness. A distributor takes over the composition from the manufacturer's technical datasheet, without checking whether that datasheet actually describes the rubber composition or only physical properties such as hardness and density.

Changes in the recipe are not communicated. A manufacturer adjusts the rubber mix to reduce costs or meet new environmental requirements, but the importer continues to work with the old documentation. This is where this topic touches on the question how current the data in the passport must be.

Business-sensitive formulation details are shared without distinction. A manufacturer shares the complete chemical composition with the importer, who then places this unprocessed in an external system, without considering which part of that information is actually intended for public disclosure and which part is not. This distinction is addressed on the page about whether business-sensitive data on tyres must be made public.

What you can record

• An overview per product variant of the rubber types used (natural, synthetic, blends), not only per brand or model line.
• Documentation of the share of recycled material per variant, including the source of that information (manufacturer, certificate, test report).
• A file per supplier with the datasheets or technical specifications in which the composition is described, with a note indicating which part of it is suitable for inclusion in the passport and which part remains internal.
• A log of changes to the rubber formulation per product variant, with the date of implementation, so that it is clear which composition belongs to which production batch.
• A reference to who within the organisation is responsible for keeping this data current, linked to the agreements already in place for updating other passport data.
• An established procedure for when a delegated act for tyres is published, so that the requirements then in force can quickly be compared with what has already been documented.