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What changes this year regarding the digital product passport for tyres?

This year, most tyre businesses will see no legal changes yet, but the European process surrounding the digital product passport is moving closer. This article explains exactly what is shifting and for whom this is already relevant.

For most companies that import, trade in, or use tyres in a fleet, nothing will change legally this year. There is no obligation yet to create or display a digital product passport. What is changing is the progress of the process towards it: within its work plan for the Ecodesign Regulation (ESPR) 2025-2030, the European Commission is working on the delegated act that must establish the exact rules specifically for tyres. That act is currently expected in 2027, but that date is not yet final.

For those to whom it matters: particularly for companies that are already taking the first steps, such as mapping which data about their tyres are available and from whom. For companies that simply sell or use tyres without being a manufacturer or importer themselves, little will change in practice this year. It is, however, useful to know where the process currently stands, so that a future obligation does not come as a surprise.

What exactly is shifting

The ESPR is the framework regulation that makes it possible to make a digital product passport mandatory for product groups, including tyres. The regulation itself establishes that such passports can be introduced and how the process towards them proceeds. The specific implementation for tyres, such as which data are mandatory and from what point in time, comes in a separate delegated act. That does not yet exist. The work plan 2025-2030 states when the Commission expects to publish that act, but a work plan is a schedule, not a law. Delays in this type of process are not unusual.

Once the delegated act is in place, there will be clarity on the exact content and the timelines that will actually apply. Until then, every date you come across, including on our own site, is an expectation and not a commitment. We keep track of the situation and update the information as soon as something becomes official.

What remains the same

The core of the passport does not change: the idea remains that data about a tyre, such as material use, origin and performance, become available digitally and traceable via a data carrier, usually a QR code. Who in the supply chain is responsible for providing that data depends on the role a company has, for example as a manufacturer, importer or authorised representative. That division of roles is already established in the broader ESPR framework and does not change with the schedule of the delegated act.

For those to whom this is already relevant

Companies that import tyres or put them on the market under their own brand are well advised to already inventory which technical and origin data they receive from their suppliers and which they do not. That is not a legal obligation, but rather a practical preparation: once the delegated act is in place, the time to request data from a manufacturer is often shorter than expected. Wholesalers and fleet managers generally have less of their own obligation, but will have to deal with suppliers who will start asking questions about data exchange.

Those who want to know which role is likely to apply to their own company will find a preliminary assessment via a short questionnaire with an indication of your situation. That is not a legal opinion, but a tool to determine where further investigation is needed.

What you can do with it now

Because the exact rules are not yet in place, it is too early to set up systems definitively. What is useful: understanding how the regulation works, so that future changes do not come as isolated messages but in a context you are already familiar with. An overview of the concepts and the structure of the regulations can be found in the knowledge base with explanations per topic. It is also useful to know where the data for the passport will come from in the future and how we will process it; that is explained on the page on the origin and processing of the data.

Developments such as the publication of the delegated act are news relevant to everyone in the sector, regardless of role or company size. For your own situation, in particular the question of whether and when a specific obligation will apply, it is advisable to follow the official EU texts or consult a lawyer. We keep the timeline updated and adjust the information on this site as soon as there is an official date.

Would you like to get an idea of where your company roughly stands in this process? Take the free quick-scan or read further in the frequently asked questions about the digital product passport to see which topics are most relevant to you.

This article is general information and not legal advice.