What can I already do while the rules are not yet final?

It pays to start now, even without a fixed date

You can already begin organizing the data that will need to be included in a digital product passport, even though the precise obligation for tyres is not yet established. The ESPR (Regulation (EU) 2024/1781) already sets out the general rules for the product passport, and describes in Article 18 how the European Commission prioritizes product groups and draws up a work plan. Tyres are on the radar of that work plan. Waiting until the delegated act is in place means you will then have to collect data retroactively that may no longer be available — a supplier that no longer exists, a composition that was not recorded, a test report that has gone missing. Organizing things now is therefore not a down payment on an obligation, but a way to avoid time pressure later.

For whom this work is relevant now, and for whom it is not

This is particularly relevant for tyre importers, wholesalers and fleet managers who place tyres on the European market or manage large volumes and depend on data from manufacturers or other links in the chain. For these parties, the information needs will largely be the same later, regardless of the precise date of application: material composition, origin, test results, repair and recycling information. This is not relevant for those who purchase tyres exclusively as end users without trading them further in the chain — there is no role for them in compiling a passport. Also note: as long as no delegated act for tyres has been published, there is no concrete legal obligation to a passport. What does already exist is the general information obligation between actors in the supply chain described in Article 38 of the ESPR, which is separate from the question of whether tyres have already been specifically designated.

The date is not yet fixed, but this is already fixed

There is no fixed date yet for when the digital product passport for tyres will become mandatory. What is fixed: the Commission is working according to a work plan for the period 2025-2030, and the delegated act that will set out the requirements for tyres specifically is foreseen in 2027. Once that act is published, the precise date and content of the obligation will be posted on this page. Until then, the general framework of the ESPR applies: the Commission's power to designate and prioritize product groups (Article 18), and the obligation for actors in the supply chain to share relevant information with each other (Article 38). So there is no legal vacuum, but also no product-specific obligation for tyres yet. Both things are true at the same time, and that is precisely why preparing now is worthwhile without a clock already running.

What you can do now, in the order that works

Start by mapping out which data you already have and which you are missing: material composition, origin of raw materials, test results, repair or refilling information, and data on recyclability. Next, establish who in your chain actually possesses that information — often it is the manufacturer, but with imports through multiple channels, that knowledge can be fragmented. Lock in agreements on sharing that data, even if there is no legal obligation to do so yet; that will save work once the obligation is in place. Then choose a way to store this data in a structured manner, preferably in a form that can later be transferred to a digital passport — a separate Excel file per product works for now, but does not scale. Finally: keep an eye on the Commission's work plan so you know when tyres are formally designated and what requirements come with it. Those who complete these steps in this order will not have to start from scratch when the delegated act is published.

The legal basis: Article 18 and Article 38 of the ESPR

This approach follows directly from the ESPR (Regulation (EU) 2024/1781). Article 18 describes how the Commission prioritises product groups and establishes a work plan for the period in which delegated acts are prepared — this is the basis for the fact that tyres are on the agenda, but have not yet been formally designated. Article 38 sets out which information obligations apply between actors in the supply chain, regardless of whether a product group has already been specifically developed. Together, these articles are the reason why there is already a framework to work within, while the product-specific details for tyres must still follow from a separate delegated act.

What you can do today is therefore not to wait for that act but to put your own data management in order: know what you have, know what you are missing, and make agreements with the links in your chain that provide that information. As soon as the delegated act for tyres has been published, we will update the date and the content of the obligation here immediately.

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

The delegated act for tyres is not yet in place, but the ESPR (Regulation (EU) 2024/1781) itself is already in force and indicates how the Commission prioritises and prepares product groups. This does not mean that a tyre company must already comply with concrete product passport requirements, but it does mean that the direction is set. There are a few things that can be done practically in the meantime.

Gaining insight into your own data chain

Article 18 of the ESPR (prioritisation and planning) shows that the Commission works with a work plan in which product groups are developed one after another, on the basis of environmental impact and market volume. For tyres, there is already an expectation within that work plan. In practical terms, for a company with 10 to 100 employees, this means it makes sense to map out which data about a tyre is actually available: material composition, origin, test results, production date. Not because it is already mandatory, but because those data will form the basis of the passport in future and finding them takes time.

Knowing who in the chain delivers what

Article 38 of the ESPR (requirements for actors in the supply chain) describes that parties in the chain - manufacturer, importer, distributor - will have a role in keeping product information available. For an importer or wholesaler, this means it is useful to already inventory which supplier can provide which data, and which suppliers are not yet prepared for this. This is not a legal obligation today, but it is a practical preparation for the moment when the obligation does exist.

Assigning internal responsibility

There is no legal obligation yet to designate a responsible person within the company, but experience with other CE and compliance processes shows that companies that do not assign this subject to anyone in particular only pick it up when the deadline is already near. For a company of this size, it is practically manageable to give one person - often someone from quality, procurement or compliance - the task of monitoring developments and coordinating internal preparation.

Inventorying existing processes

Anyone who wants to go a step further now can look at how the product passport will fit in with existing business processes: inventory management, procurement, complaint handling. How do I approach the digital product passport for tyres step by step? provides an overview of the order in which to tackle it, so that preparation does not remain stuck in a vague intention.

Where things go wrong in practice

A number of situations come up regularly in practice at companies preparing for regulations that are not yet final.

Waiting until the date is set. Companies postpone all preparation until the delegated act is published, and then discover that collecting historical product data takes more time than expected, because suppliers no longer have that data readily available.

No point of contact at the supplier. An importer requests data from a manufacturer abroad, but there is no fixed contact who knows which information will be relevant. This leads to delays once the request becomes concrete.

Assumptions about what is already mandatory. Some companies think that Article 38 of the ESPR now already entails a direct obligation to supply passport data, and communicate this to customers. This is premature as long as the delegated act for tyres is not in place.

No distinction between current and future inventory. Inventory that is already in the warehouse raises questions about what should happen to it later. This subject is dealt with separately in What do I do with tyre stock already in place when the rules come into effect?and it is wise not to confuse this question with the question of what there is to do today.

Platform choice locked in too early. A single company already definitively chooses an IT solution without considering whether that solution can keep up with a delegated act that has not yet been published. This is a risk, because the precise data requirements may still change. When choosing, it is advisable to pay attention to flexibility; what should I pay attention to when choosing a platform for the product passport goes into more detail on this.

What you can record

Even without definitive rules, it is possible now to already document a number of matters in writing, so that the actual implementation later takes less time.

An overview of your own product lines and what data about them is already available (material, origin, test certificates).
A list of suppliers and importers with a contact person for data exchange, including agreements on what information will be needed in the long term.
An internal note about who within the company is monitoring developments around the ESPR and when that will be reassessed.
An initial estimate of the costs associated with implementation, as a basis for budgeting; a reference for this is provided in What does a digital product passport for tyres cost?.
Agreements on whether and how multiple sites will use the same product passport data in the future, which can be mapped out now via can multiple locations of my company manage the same product passport.
Your own archive or back-up of product data that is already being collected, independent of which platform is eventually chosen; see also must I keep a copy myself of the data contained in the product passport.

This preparation takes little time, but saves time when the delegated act for tyres is published and the actual obligations become concrete.

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.