Anyone who hears that a digital product passport for tyres is coming soon will quickly wonder whether it applies to every tyre, or only to certain types. The short answer: the Regulation on which the passport is based identifies tyres as a product group, but which specific tyre types within that group will fall within it — car tyres, van tyres, truck tyres, motorcycle tyres, agricultural tyres or bicycle tyres — will be laid down in a delegated act that has not yet been published.
This means that there is currently clarity on the principle (tyres are on the list of product groups that may fall under the Ecodesign Regulation for sustainable products, in short ESPR), but not yet on the precise scope. That scope is precisely what the delegated act is for: it determines which product categories, which sizes or which uses fall within the scope and which do not.
What the work plan does say
The European Commission is working with a work plan for the period 2025-2030 which lists product groups that it intends to work on first. Tyres are on it. This is an indication that legislation for tyres is coming, but a work plan is not law: it is a planning of what the Commission intends to work on, in which order and within which timeframe. Only the delegated act itself will have legal force, and for tyres it is expected around 2027.
As long as that act does not exist, no one can say with certainty whether, for example, an agricultural tyre or a motorcycle tyre falls under the same rules as a car tyre, or whether the Commission chooses a separate line for those categories, a later date, or no passport obligation at all. Claims that already definitively specify which tyre types are or are not included are jumping the gun.
Why the scope is determined so late
This is no accident or delay, but is part of how the ESPR is set up. The Regulation itself is a framework: it describes the process and powers, but only specifies in detail per product group through a delegated act. For some product groups that detailed work is already complete, for tyres it is not yet. This also explains why you encounter formulations such as "expected" and "not yet determined" everywhere at this time — that is not careless language use, but the current state of affairs.
Anyone who wants to follow the process itself does well to keep the distinction between the framework Regulation and the delegated act sharp. Once someone understands that difference, they will also find it much easier to read future announcements. the structure of the Regulation step by step shows how these two layers relate to each other.
What this means for your company
If your company imports, trades or supplies tyres to vehicle fleets, it is worthwhile to already map out which tyre types you work with and via which link in the chain. Not because the obligation is already determined, but because that inventory will help you to quickly assess whether, and at what point, the passport requirement affects your assortment once it comes. Companies that only start looking once the delegated act is published will lose valuable time in setting up data flows and aligning with suppliers.
A good starting point is a brief inventory of your own situation: which tyre types do you carry, who supplies the source data, and what role does your company play in the chain. With get clarity on your situation with a few questions gives an initial direction for that, without this already being a legal assessment of your specific case.
Determined versus provisional
It is advisable to distinguish two columns for yourself. In one column is what is established: the ESPR exists, tyres are designated as a product category for which implementation is forthcoming, and the digital product passport is mentioned as an instrument for that implementation. In the other column is what still needs to follow: the exact scope per tyre type, the entry into force date, and the precise obligations per market participant. That second column will only be filled in with the publication of the delegated act.
The official text of the regulation and the work plan are and remain the place where you can read this. On where our information comes from you will see how we maintain those sources and where we will refer to them as soon as new texts are published.
Would you like to already clarify for yourself whether your tyre types and your role in the supply chain will be relevant later on, and what you need to watch out for? Do the free quick-scan or browse through the topics in the most frequently asked questions about the tyre passport. For an assessment of your own situation, a lawyer or the competent supervisory authority remains the appropriate point of contact.