What does the ESPR change for the tyre sector?

What you must do concretely

What is expected of you

The ESPR (Regulation (EU) 2024/1781) is a framework regulation. This means that the regulation itself primarily sets out the scope and the system, and that the concrete requirements for each product group — including tyres — are worked out separately. Article 1 of the ESPR describes that the regulation applies to physical goods placed on the market or put into service, with requirements in the field of ecodesign. For the tyre industry, this means in practice a number of layers of obligations, each requiring separate attention.

Knowing whether tyres fall under the regulation

The ESPR works with product groups. Not every type of tyre automatically falls under the rules in the same way; this is determined per product group. For a company of any size, this means that finding out which tyres in its own assortment precisely fall under the regulation, and which do not, is a first step that cannot be skipped. Which tyre sector products fall under the ESPR? goes into this further. Also, the question of whether a specific part of its own offering relates to the product passport is something an importer or wholesaler does not automatically have an answer to beforehand; Does the digital product passport apply to my tyres? describes what this is assessed on.

Waiting for the delegated act that applies to tyres

The ESPR itself does not name concrete requirements for tyres — these come in a delegated act that the Commission adopts later. For a company, this means that the actual content of the obligation (which data, which format, which information requirement) is not yet fixed. It is a part of the legislation that few entrepreneurs from other sectors know, and that deserves explanation: What is a delegated act and why does it determine what I must do? explains how these two layers — framework regulation and delegated act — relate to each other.

Being able to provide a digital product passport

Once the delegated act for tyres is in place, a digital product passport is expected to go with it: a dataset about the product that can be requested via a data carrier (such as a QR code). For a tyre importer or wholesaler, this means organisational work: collecting data from the manufacturer, having it assembled into a passport, and affixing a data carrier to or with the product. What exactly goes into such a passport and what it contains in terms of content is described in What is a digital product passport for tyres? and What data goes into the digital product passport for tyres?

Determining who in the chain has which role

For tyres on a new vehicle, for retreaded tyres, and for test batches that are not sold, the question of who is responsible for the passport is less straightforward than for a tyre that is imported and sold separately. A fleet manager who has tyres replaced, an importer who deals in retreaded tyres, or a manufacturer who sends trial batches to customers each get a different position in the chain. This is worked out in Who creates the digital product passport for tyres fitted to a new vehicle?, Does the digital product passport also apply to retreaded tyres and tread renewal? and do I also need to create a product passport for test tyres or samples that I do not sell

Knowing whether the size of the company provides relief

Smaller companies often wonder whether an exception applies to them. The ESPR contains provisions on small and micro-enterprises, but what this concretely means for the obligation to provide a product passport cannot be summed up in one sentence. Does the digital product passport also apply to small businesses? goes into this.

Where things go wrong in practice

A number of patterns recur among companies preparing for the product passport.

Assumption that all tyres are treated the same way. A wholesaler that deals in both new passenger car tyres and retreaded truck tyres sometimes assumes that one approach is sufficient for the entire assortment. Because product groups are worked out separately, this can be different for one segment than for the other.

Waiting until the date is fixed, and then doing no preparation. Because the delegated act for tyres has not yet been published, some companies are postponing all preparation. Data that a manufacturer records now about composition, origin and technical properties will be needed later for the passport — sorting it now is not wasted effort, even if the obligation itself is not yet fixed.

Unclear about who in the chain assembles the passport. When a tyre reaches the end consumer through an importer, a wholesaler and a fitter, it is not always clear in advance who supplies which data and who manages the data carrier. This leads to situations where no one feels responsible, or where two parties do duplicate work.

Overlooking test batches and samples. Tyres sent to a customer as test material are sometimes treated as "not a sale, so no problem", while the question of whether a digital product passport must accompany them is actually rather more nuanced.

Confusion between the ESPR and other legislation on tyres. Tyres have long been subject to obligations, such as the tyre labelling regulation on fuel efficiency and safety. That regulation is different from the digital product passport under the ESPR, and the passport does not automatically replace those other obligations.

What you can record

• An overview of your own product range, broken down by tyre type (new, retreaded, test batch, tyre on new vehicle), so that you can track which rules will apply per category.
• The data that manufacturers and importers already supply on composition, materials and technical specifications, even if there is not yet a digital product passport obligation for them.
• An internal agreement on who in the supply chain (manufacturer, importer, wholesaler) is the point of contact for passport-related questions, so that this is not worked out only at the first deadline.
• A list of customer queries received on the digital product passport, including how they were answered — useful as an internal reference work once the rules become more concrete.
• Agreements with suppliers on when they will supply digital product passport data, so that this does not come as a surprise late in the process.

Anyone wondering who will then have access to all that data — only their own supply chain, or also supervisory authorities and consumers — will find more information in Who is allowed to view which data from the digital product passport? And for anyone who mainly wants to know when all this becomes concrete, When does the product passport become mandatory for tyres? is the starting point.