Whether the tyre passport applies to a tyre that the car manufacturer has already mounted before the car reaches the dealer depends on how that tyre was placed on the market. The regulation that governs the digital product passport, the ESPR, focuses on products placed on the market as such. A tyre sold separately as a replacement tyre generally falls under this. A tyre that is already on the car when that car itself is placed on the market is governed by the legislation applicable to the vehicle as a whole, which is a different legal framework than the tyre passport.
This distinction may seem clear-cut, but in the practice of a tyre wholesale business or a fleet manager it is not always so. If you purchase tyres that a car manufacturer orders in stock to mount on new vehicles, you may be a supplier to the vehicle manufacturer and not the party placing the tyre on the market as a separate product. If you later sell that same tyre as a replacement tyre to a garage or end user, that role changes. Who is responsible for the passport at each stage depends on who actually offers the tyre as an independent product.
What the regulation broadly governs
The ESPR is a framework regulation: it establishes the system, but the precise requirements for each product group are set out in a delegated act per category. For tyres, that act does not yet exist; the European Commission's work plan mentions 2027 as the expected period for publication, and the date on this site will be updated once that act is actually published. This means that the precise demarcation between 'tyre as a separate product' and 'tyre as part of a vehicle' is not yet detailed. What is established is the underlying principle: the passport belongs to the product that is traded separately, not to every component that is incorporated into another product at some point.
Two situations often confused
The first situation is the tyre you purchase and resell as a replacement tyre, for example to garages, tyre specialists or for your own fleet. There is a good chance that you or your supplier play a role for which the passport is relevant. The second situation is the tyre that goes directly to a vehicle manufacturer for mounting on a new car, bus or commercial vehicle. That tyre reaches the end user as part of the vehicle, not as a separately purchased product. For that second situation, responsibility for product information typically lies with other, existing regulations on vehicles, and not automatically with the tyre passport.
Between these two extremes there are mixed forms. If you supply tyres to a vehicle manufacturer and also sell part of the same production line separately as a replacement tyre, the same tyre model may fall under the passport in one stream but not in the other. This is not a flaw in the system, but a consequence of how the regulation views 'placing on the market': it concerns the action, not the physical product in itself.
What is not yet fixed
Because the delegated act for tyres has not yet been published, it is not yet possible to say with certainty how specifically the demarcation will be drawn for borderline cases such as OEM supply (tyres that a vehicle manufacturer sources directly for assembly on new vehicles), supplies to bodywork manufacturers, or tyres that are subsequently resold separately via an intermediary. Supervisory authorities will assess these questions on the basis of the final text of the act, not on the basis of assumptions that are currently circulating. Anyone who needs certainty on this matter now for an ongoing contract would be well advised to discuss it with a lawyer or the competent supervisory authority rather than relying on an estimate.
What this means in practice for your procurement
For companies that supply both vehicle manufacturers and the replacement market, it is advisable to establish now which stream of a tyre model goes where. This is not an additional obligation under the ESPR, but it is something that will make it easier later to determine which role applies to which delivery. review the concepts around roles in the supply chain carefully helps to get that distinction clear before the delegated act is published. If you are uncertain whether your situation leans more towards one side or the other of this distinction, then a few questions with an initial indication provides a starting point, without this being a legal opinion.
It is also worthwhile to know where the information on this platform comes from, especially on a topic where the regulations are still in flux. how we manage sources and updates shows how changes, such as the publication of the delegated act, are processed. Many of the questions raised above also appear in the most frequently asked questions about the tyre passport, each with a reference to the source in the official text.
If you want to know how this demarcation works out for your own procurement flows, a non-binding initial check is a logical next step. The quick scan and the knowledge base are free to consult and provide per topic the short answer, the risk indication and the source in the official text, so you can assess yourself whether further investigation is needed for your company.