When does the product passport become mandatory for tyres?

What you must do concretely

What is expected of you

Waiting for the delegated act on tyres

The ESPR itself does not directly oblige anyone to provide a product passport. The regulation gives the European Commission the authority to establish a delegated act for each product group, and only that act determines whether, when and how the passport for tyres will apply (Article 4 and Article 8 of the ESPR). For those wondering what a delegated act is exactly and why it is the place where requirements for tyres are made concrete: it is not a side matter, it is where the requirements for tyres become concrete. For a company with 10 to 100 employees, this means above all that there is currently nothing to deliver or sign. What is practical: to map out in advance which products in the range could fall under the definition, so that no time is lost once the act is in place.

Prioritisation according to the work plan

Article 18 of the ESPR regulates how the Commission prioritises and schedules product groups. Tyres are named in the work plan 2025-2030, with a delegated act expected under that plan in 2027. That is a planning date, not a legal deadline, and schedules in Brussels slip backwards more often than forwards. For an importer or wholesaler, this means that 2027 is a moment to watch for in announcements, not a date to already tie concrete actions to. Anyone who now adjusts supplier agreements or contracts to a date that has not yet been set risks doing so too early.

Checking whether your own range will be relevant

Even without a fixed date, it is useful to already determine which product categories in the company relate to what the ESPR is intended to regulate. Not every rubber product on four wheels is automatically "a tyre" within the meaning of this regulation, and the definition is more precise than most entrepreneurs expect. An overview of which products from the tyre sector fall under the ESPR helps to separate in advance what will become relevant and what is likely to remain out of sight. For companies with a broad range — new tyres, retreaded tyres, second-hand batches — this is a matter of organisation, not panic.

Making a distinction between "does it apply to me" and "when does it apply"

These two questions are often asked in one breath, but they are different questions with different answers. Whether the product passport will later apply to a specific company depends on what is traded and in what role, and this is independent of the date on which the obligation comes into force. Anyone who wants to find out for their own situation can read further about whether the digital product passport will apply to your tyres. Smaller players often ask themselves a separate question, namely whether there is an exception for limited business size; for this too there is a separate explanation about whether the product passport also applies to small businesses.

Where things go wrong in practice

A number of recurring situations stand out among companies that are already preparing for the product passport for tyres.

A date is treated as a deadline. 2027 is listed in the work plan as the expected date for the delegated act, not as the date on which the passport becomes mandatory. There is usually a transition period between the delegated act and the actual obligation. Anyone who now communicates internally that "from 2027 the passport is mandatory" sets an expectation that is incorrect and difficult to reverse if colleagues or customers later refer to it.

Contracts with suppliers refer to an obligation that does not exist. Some companies want to build in certainty and have a supplier undertake now that "the passport will be delivered according to ESPR requirements". As long as the delegated act is not in place, there is no fixed content to refer to — the requirements for data, method of submission and QR data carrier are not yet established.

Investments in IT systems are locked in too early. A fleet manager or distributor who sets up a system now based on a format that has not yet been published runs the risk that the system will need to be adjusted once the actual technical requirements become known. Waiting until the outlines become clearer is often wiser than starting early.

Cover tyres and tread renewal are forgotten in the planning. Companies that focus on new tyres sometimes forget that the covered or renewed part of the assortment must also receive attention once there is more clarity. A separate explanation exists about how the product passport relates to cover tyres and tread renewal, and it is useful to have that distinction clear now already.

Test batches and samples are included or conversely ignored without justification. When drawing up an assortment overview, confusion regularly arises about how batches that are not sold — test shipments, samples for inspection — should be included. Those who look into this now already will find an explanation in the question whether a product passport is also needed for test tyres or samples that are not sold.

What you can record

Even without a fixed obligation date, it is worthwhile to put a number of things in order now, so that the transition later does not cause delays:

• An overview of your own assortment, broken down by product category (new, covered, tread renewed, second-hand), so that it is quickly clear which part will be relevant later.
• A list of suppliers and manufacturers per product line, with contact details for whoever will need to supply the underlying data later.
• An internal contact point or role that follows the announcements about the delegated act, so that the information does not remain with one person who happened to read it.
• An overview of which data are already available about the products, as preparation for what will need to come in the passport later; an indication of the expected content is in the question which data will be in the product passport for tyres.
• Agreements about who in the chain fulfils which role, especially for tyres that are fitted to a new vehicle, where the question arises who is responsible for drawing up the passport; see the explanation about who draws up the product passport for tyres on a new vehicle.

Once the delegated act for tyres has been published, this page will be updated with the established date and the actual content of the obligation.