The digital product passport is first and foremost linked to the moment when a tyre is placed on the EU market for the first time. For tyres that have already been sold previously and are now changing ownership again as a used tyre, the situation is different than for a tyre that a manufacturer or importer is offering for the first time. With retreading, an additional question arises: is that a processing of an existing product, or does something emerge that is being placed back on the market.
At this moment, this distinction in the delegated act has not yet been worked out in detail. The regulation itself lays down the framework; the precise criteria for product groups such as tyres follow from a delegated act that is expected in 2027 according to the ESPR Work Plan 2025-2030. Until that text is available, describing sharp boundaries between 'new', 'used' and 'renewed' would be premature. What can be said is what questions will become relevant for your business in the coming years.
What exactly does 'placing on the market' mean
The regulation works with the moment when a product becomes available on the EU market for the first time. That moment usually lies with the manufacturer or the importer, not with every subsequent link in the chain. A wholesaler who purchases a batch of tyres and resells them to a garage does not as a rule place a product on the market again — that tyre has already done so at the moment it entered the EU.
This distinction is the core of why 'used' and 'new to market' are two different questions. A tyre that has been on a vehicle for ten years and is now being sold separately is not 'placed on the market' again in the sense the regulation uses that term — even though it changes ownership. For fleet managers who resell used tyres to a third party, this is precisely the kind of situation where their own role in the chain matters. look up the concepts by situation provides an overview of how those roles are divided.
Tyre retreading: a different question than resale
Tyre retreading is not straightforward resale. Processing is performed on the tyre after which the product re-enters the market with a new lifespan. This raises the question of whether a company that performs retreading thereby takes on the role of someone placing a product on the market, with the obligations that come with it, or whether it is seen as maintenance of an existing product.
This question has not yet been answered for tyres in a published delegated act. For other product groups within the broader Ecodesign Regulation, this type of distinction has already been the subject of discussion, which indicates that it is not an edge case but a question that supervisory authorities and market participants will need to work through seriously. Companies for which retreading is a core activity are well advised to monitor this development once the text for tyres becomes concrete.
What this means in practice
For an installation company that occasionally resells a batch of used tyres, the likelihood that this falls within the scope of the passport as currently set up is small — those tyres have already been placed on the market previously, after all. For a company that systematically produces and sells retreaded tyres, the situation is different and deserves attention once the delegated act is in place.
Between these two extremes lies a grey area: importing used tyres from outside the EU, for example, may bring a tyre onto the EU market for the first time, even though it is not new. If you find yourself in such a position, it is advisable to map out your own supply chains before the rules are final, so there are no surprises once the date is set.
What is not yet determined, and where you should keep following up
The core of this article is that the boundary between what falls under the passport and what does not, for used and retreaded tyres, has not yet been established in a published text. What is already in place is the logic of the regulation: the moment of placing on the market, and the role a company plays in that. That logic will not change; the application to specific situations such as retreading follows later.
Whether your company falls into one of these categories cannot be answered by a general rule — it depends on exactly what you do with the tyres that pass through your company. For a first impression, you can see how your situation looks in a few questions. For the underlying text and the current status of the delegated act, we refer you to the official publication on EUR-Lex and, for your own situation, to a lawyer or the competent supervisory authority.
If you want to know how we compile the information on this platform and where it comes from, read that on the page about how we work. Frequently asked questions from other tyre companies, including on borderline cases such as this one, are compiled on the overview of frequently asked questions.
Do you have doubt whether your company falls under one of these categories? Do the free quick-scan or browse through the knowledge base to see which situation is closest to yours.