Tyres are subject to existing EU Tyre Labelling Regulation (EU 2020/740) and are in scope for ESPR Digital Product Passport requirements. The DPP will extend the existing tyre label data with lifecycle sustainability information including recycled content, carbon footprint, and end-of-life data.
| Key Fact | Detail |
|---|---|
| Product category | Tyres |
| Delegated act expected | 2025–2026 (preparatory study underway) |
| DPP mandatory from | Expected 2027 |
| Key sectors | Automotive, transport, rubber manufacturing |
| Regulatory reference | EU Reg 2020/740; ESPR Annex II |
Tyres are subject to EU Regulation 2020/740 (Tyre Labelling Regulation), which requires a label showing fuel efficiency class (A–E), wet grip class (A–E), and external rolling noise class (A–C). The regulation also requires a QR code on the label linking to the EU product database (EPREL). Under ESPR, the DPP will extend this data with lifecycle sustainability information.
| Data Category | Expected Data Fields | Basis |
|---|---|---|
| Performance | Fuel efficiency class (A–E), wet grip class (A–E), external rolling noise (dB), noise class (A–C) | EU Reg 2020/740 |
| Materials | Recycled rubber content (%), recycled carbon black content (%), recycled steel content (%), natural rubber origin | ESPR Annex III(b) |
| Carbon footprint | Carbon footprint per tyre lifecycle (kg CO2e), manufacturing carbon footprint | ESPR Annex III(c) |
| Hazardous substances | PAH content (polycyclic aromatic hydrocarbons), SVHC declaration | REACH Regulation |
| End-of-life | Recyclability rate, end-of-life recovery instructions, tyre take-back programme | ESPR Annex III(e) |
The ESPR delegated act for tyres will specify the minimum data fields required in the Digital Product Passport. Based on the ESPR framework and the existing EU Tyre Labelling Regulation (EU 2020/740), the DPP for tyres is expected to include: the tyre's unique product identifier, manufacturer identity and contact details, tyre dimensions and load/speed index, fuel efficiency class (A–E), wet grip class (A–E), external rolling noise class and measured value in decibels, snow grip performance if applicable, ice grip performance if applicable, recycled rubber content percentage, end-of-life recyclability rate, carbon footprint per tyre unit, and the identity of the notified body that performed conformity assessment. The data carrier — a QR code or NFC chip — must be physically affixed to the tyre sidewall in a location that remains readable after mounting.
Tyre manufacturers based in China, South Korea, Japan, India, and other non-EU countries that export to the European market face the same ESPR obligations as EU-based manufacturers. The regulation applies at the point of placing on the EU market, not at the point of manufacture. Non-EU manufacturers must appoint an EU Authorised Representative before the tyre delegated act enters into force. The Authorised Representative holds legal responsibility for ESPR compliance on behalf of the manufacturer, signs the EU Declaration of Conformity, and is the contact point for EU market surveillance authorities. Without an appointed Authorised Representative, tyres cannot legally be placed on the EU market after the delegated act deadline.
Retreaded tyres present a specific compliance question under ESPR. A retreaded tyre is a used tyre that has been reconditioned with a new tread layer. The ESPR delegated act for tyres will need to address whether retreaded tyres require a new DPP or whether the original tyre's DPP can be updated to reflect the retreading process. The EU Commission's preparatory study for the tyre delegated act has flagged retreading as a circular economy priority — retreading extends tyre life and reduces raw material consumption, which aligns with ESPR objectives. Retreaders should monitor the delegated act consultation process closely and engage with the European Retreading Manufacturers Association (BIPAVER) for sector-specific guidance.
Market surveillance authorities in each EU member state will be responsible for enforcing the tyre ESPR delegated act. In Germany, this is the Federal Motor Transport Authority (KBA). In France, the DGCCRF. In the Netherlands, the Netherlands Vehicle Authority (RDW). These authorities have the power to request technical documentation, test DPP data carriers, verify that the DPP data matches the physical product, and withdraw non-compliant tyres from the market. The penalties for non-compliance vary by member state but can include product recalls, fines, and import bans. The EU's market surveillance regulation (EU 2019/1020) gives authorities enhanced cross-border cooperation powers, meaning a non-compliant tyre identified in Germany can trigger enforcement action across all EU member states.
| Tyre Type | Expected DPP Requirement | Key Data Fields |
|---|---|---|
| Passenger car tyres (C1) | Mandatory — delegated act expected 2026–2027 | Fuel efficiency, wet grip, noise, recycled content |
| Light truck tyres (C2) | Mandatory — same delegated act as C1 | Load index, fuel efficiency, wet grip |
| Heavy truck tyres (C3) | Mandatory — may have separate delegated act | Rolling resistance, mileage, retreading compatibility |
| Retreaded tyres | Under consultation — DPP update likely required | Original tyre ID, retreading date, new tread specification |
| Agricultural tyres | Likely included — confirmation pending | Load capacity, soil compaction data |
The EU Tyre Labelling Regulation (EU 2020/740) requires tyres to bear a label showing the fuel efficiency rating (A–E), wet grip rating (A–E), and external rolling noise rating. The ESPR tyre DPP will incorporate and extend the tyre labelling data — the DPP will contain the same performance data as the physical label, plus additional data on the tyre's material composition, recycled rubber content, carbon footprint, and end-of-life recycling instructions. The EU Commission has indicated that the ESPR tyre delegated act will align the DPP data format with the existing tyre labelling requirements to minimise the compliance burden for tyre manufacturers that are already complying with the Tyre Labelling Regulation.
Tyres are identified by the DOT (Department of Transportation) code moulded into the tyre sidewall, which includes the manufacturer code, plant code, tyre size code, and date of manufacture. For ESPR DPP purposes, the tyre must also bear a GS1 Digital Link QR code that links to the DPP. The QR code must encode the tyre's GTIN and, for individually serialised tyres, the serial number. The QR code can be applied to the tyre sidewall using a laser-engraved or moulded label, or it can be printed on a label attached to the tyre during the distribution process. Tyre manufacturers should consult with their label suppliers and tyre mould manufacturers to determine the most appropriate QR code application method for their production process.
The ESPR tyre DPP will include end-of-life instructions specifying how the tyre should be disposed of at end of life. In the EU, end-of-life tyres must be collected by tyre dealers and handed over to authorised ELT (end-of-life tyre) collectors. The ESPR tyre DPP will include the contact details of the tyre producer's ELT collection scheme and the collection point locator URL. This information will help consumers and fleet operators to dispose of their end-of-life tyres correctly. The ESPR tyre DPP will also include data on the tyre's recycled rubber content — the percentage of the tyre's rubber that was produced from recycled ELT rubber. This data will be used by EPR scheme operators to calculate the correct EPR fee for the tyre producer.
Yes. Tyres are subject to EU Regulation 2020/740 (Tyre Labelling Regulation), which requires a label showing fuel efficiency, wet grip, and noise class. Under ESPR, the DPP will extend this with lifecycle sustainability data including recycled content and carbon footprint.
The minimum recycled content requirements for tyres have not yet been set in the ESPR delegated act. The preparatory study is expected to recommend minimum recycled rubber and recycled carbon black content percentages. Manufacturers should audit their current recycled content levels now.
The EU DPP Registry goes live on 19 July 2026. Tyres manufacturers must be ready. Register your Digital Product Passport now at Africa's first ESPR-compliant DPP registry.
Register Your Digital Product Passport →Tyres sold in the EU are currently subject to labelling requirements under EU Regulation 2020/740, which requires manufacturers to display information on fuel efficiency, wet grip, and external rolling noise on a standardised EU tyre label. The ESPR delegated act for tyres will build on these existing labelling requirements and add new requirements for DPP data disclosure, recycled content, and end-of-life recyclability. Tyres are a significant source of microplastic pollution — tyre and road wear particles (TRWP) are estimated to be the largest source of microplastic pollution in European waterways — and the ESPR delegated act is expected to address this issue.
The DPP for tyres is expected to include: the tyre's fuel efficiency class; the tyre's wet grip class; the tyre's external rolling noise level; the tyre's carbon footprint across its full lifecycle; the percentage of recycled content (recycled rubber, recycled carbon black, recycled steel); information on substances of concern (particularly polycyclic aromatic hydrocarbons, or PAHs, which are restricted under EU Regulation 1907/2006); the tyre's expected mileage; and instructions for end-of-life disposal. The DPP for tyres will also be linked to the EU tyre label, providing a machine-readable version of the label data.
The ESPR delegated act for tyres is expected to be adopted in 2025–2026. Tyre manufacturers should plan for compliance by 2027–2028. The existing EU tyre labelling regulation (EU 2020/740) remains in force until the ESPR delegated act takes effect.
Retreaded tyres placed on the EU market are subject to the same ESPR requirements as new tyres. Retreaders who place retreaded tyres on the EU market after the compliance date must provide a DPP for each tyre. The DPP for a retreaded tyre should reflect the tyre's current condition and the retreading process used.
The ESPR delegated act for tyres is expected to include requirements related to tyre wear particle emissions. This may include requirements for tyre compounds that produce fewer wear particles, requirements for tyre wear particle collection systems, and requirements for DPP disclosure of tyre wear particle emission rates. The Commission is also developing a separate regulation on microplastics that may complement the ESPR requirements.
The preparatory study for the ESPR delegated act on tyres is expected to assess the feasibility of recycled content requirements for rubber, carbon black, and steel. The tyre industry has been increasing its use of recycled materials — recycled carbon black (rCB) from end-of-life tyres and recycled steel from tyre bead wire are already commercially available. The initial recycled content requirements are likely to be modest, with more stringent requirements phased in over time.
Yes. The DPP data carrier must be affixed to the tyre in a durable location. For tyres, this is expected to be a QR code moulded into the tyre sidewall or an NFC chip embedded in the tyre. The data carrier must remain readable throughout the tyre's lifespan, including after the tyre has been mounted and used.