The EU tire label and the digital product passport are two different obligations that will continue to exist alongside each other. The tire label has existed for some time and provides information via a sticker or QR code about fuel efficiency, wet grip and noise level, intended to allow a buyer to compare quickly at the point of sale. The digital product passport is new, stems from the European Ecodesign Regulation (ESPR) and covers a broader set of data throughout the entire life of the tire: from materials and origin to repair and recycling information.
The two therefore overlap in form — both use a QR code — but not in purpose or content. The tire label is a comparison tool for the consumer at the moment of purchase. The product passport is an information file that must remain accessible throughout the entire supply chain and life of the tire, also for supervisory authorities, repairers and recyclers. For businesses, this means that labeling a tire does not automatically mean that the passport requirement is also met, and vice versa.
The tire label: what it has been regulating for some time
The European tire label is part of existing product legislation and focuses on a limited number of measurable properties. Suppliers and distributors have long been required to make this information visible at the point of sale, including online. The data is largely static: it does not change during the life of the tire and is determined on the basis of standardized test methods. For businesses selling tires, this is an established obligation, with its own system of classes and symbols.
The digital product passport: a different scope
The product passport under the ESPR is set up more broadly. It is not only about performance indicators, but also about composition, origin of raw materials, repair possibilities and end of life. Where the tire label is a snapshot for the sales situation, the passport is intended to remain accessible throughout the entire life of the tire — hence also the requirement that the data must be accessible for ten years. The precise content of the passport is laid down in a delegated act which is expected to be published in 2027; the regulation itself refers to that elaboration for such details. As long as it has not been published, it is not clear when the obligation for tires will become concrete.
Where the two meet
Because both systems use a QR code, it is natural for businesses to wonder whether there will eventually be one code for both the label and the passport. The regulation leaves that possibility open, but does not require it. In practice, this means that a tire may receive two separate data carriers, or one code that refers to two different information sources. For administrative purposes, it is advisable to already make a distinction between label data and passport data, so that a later linking does not require a complete reorganization. how we document the origin and timeliness of data provides a picture of how such a linking works in practice.
What this means for existing labeling obligations
The introduction of the product passport does not change the existing labelling requirement: it remains in force, even after the passport becomes mandatory. Companies that already supply labelling data correctly often have access to some of the source data that is also relevant for the passport, such as product identification and technical specifications. This will help with later submission, but is no guarantee that all required passport fields are already covered — the scope of the passport is in fact broader than that of the label.
How you can prepare for this
Because the delegated act for tyres has not yet been published, it is not yet possible to compile a complete dataset for the passport. However, it is useful to already map out which data you already have via the labelling requirement, which party in your chain acts as a supplier, and how your current systems handle QR codes and product data. With a few questions that map out your situation you will receive an indication of where your company currently stands. For background on concepts such as supplier and economic operator, and how they relate to your role in the tyre chain, the knowledge base with topics per situation further explanation.
It is advisable to submit questions about the precise interaction between labelling obligations and the product passport, and about what this means for your specific business situation, to a lawyer or the competent supervisory authority. If you would first like to get an idea of where you stand, you can do the free quick-scan or read through the topics in the most frequently asked questions about the tyre passport read through.