Digital product passport for tyres: when does it apply, and what applies today?
As of · sourced from primary law · not legal advice · Auf Deutsch lesen
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This English version was prepared with AI from the German page. No native speaker or lawyer has read it. Found a mistake? Write to office@proofpass.eu.
The short answer
Not yet. For tyres, the working plan under the ESPR, Regulation (EU) 2024/1781, gives 2027 as the provisional year of adoption of a delegated act. Only that act can require a passport (Art. 9(1)), as a rule 18 months or more after entry into force. Today the tyre label and product database apply (Art. 4, 5 Regulation (EU) 2020/740).
Art. 9(1) ESPR; Art. 4 and 5 Regulation (EU) 2020/740
Legal basis: ecodesign and tyre labelling
Article 18(5)(e) ESPR names tyres as a priority. The working plan COM(2025) 187 includes them as a final product. It notes that tyres are already regulated by other EU legislation, including Regulation (EU) 2020/740, and sees potential in recyclability, recycled content and the management of end-of-life tyres.
There is no act yet. On 11 November 2026 we found no delegated act under Article 4 ESPR for any product group on EUR-Lex. The basics are in the guide Digital product passport: deadlines and product groups.
What applies already
Suppliers of C1, C2 and C3 tyres accompany each tyre or each batch with a tyre label under Annex II and a product information sheet (Art. 4(1) Regulation (EU) 2020/740). The label contains a QR code. In distance selling, the label is shown close to the price and the product information sheet can be accessed (Art. 4(2)).
Since 1 May 2021, suppliers enter the information in Annex VII into the product database under Regulation (EU) 2017/1369 before placing on the market a tyre produced after that date (Art. 5(1)). So tyres already have a digital system. Whether it replaces a passport is for the act to decide: Article 9(4)(b) ESPR allows an exemption where other Union law includes an equivalent system.
Timeline with status
| Step | Date | Status | Provision |
|---|---|---|---|
| Tyre label and product database | 1 May 2021 | binding | Art. 4, 5 Regulation (EU) 2020/740 |
| Commission’s digital product passport registry (deadline) | 19 July 2026 | binding | Art. 13(1) ESPR, Implementing Regulation (EU) 2026/1778 |
| Delegated act for tyres | 2027 | indicative | COM(2025) 187 |
| Euro 7 for new C1 tyre types | 1 July 2028 | binding | Art. 21 Regulation (EU) 2024/1257 |
| Passport duty for tyres | as a rule no earlier than 18 months after the act enters into force | planned | Art. 4(4) ESPR |
Which data is fixed
For a tyre passport, none yet. The act selects from Annex III ESPR, for example product identifier, GTIN, compliance documentation and details of the manufacturer. Euro 7 brings its own requirements for tyres from 1 July 2028 (new C1 types), 1 April 2030 (C2) and 1 April 2032 (C3) (Art. 21 Regulation (EU) 2024/1257). That is not a product passport.
What you can do today
- Check that all your tyre types are complete in the product database.
- Keep the tyre label and the product information sheet per type, with versions, in one place.
- Collect data on materials and recycled content per type. The working plan names both as starting points.
- Watch the 2027 act and whether it uses the product database.
- For vehicle manufacturers and suppliers: see product passport in the automotive sector.
Further reading
- The product passport module: permanent address, QR code and documents per product
- The basics in the guide Digital product passport: deadlines and product groups
- Every date per product group in the deadline tracker
- All industries at a glance: product passport by industry
Frequently asked questions
Is the QR code on the tyre label already a product passport?
No. It belongs to the tyre label under Annex II Regulation (EU) 2020/740. A product passport under the ESPR needs its own delegated act.
Will I have to maintain tyre data twice, in the database and in the passport?
That is open. Art. 9(4)(b) ESPR allows a product group to be exempted from the passport where another digital system achieves the objectives. Whether that applies to tyres is for the act to decide.
Does this apply to retreaded tyres too?
For a passport, the future act will decide. For the tyre label, the requirements for retreaded tyres only apply once a testing method under Art. 13 Regulation (EU) 2020/740 has been set (Art. 2(1)).
With ProofPass
ProofPass does not provide a product passport under an ESPR act today, because there is none yet for this group. You get a permanent address per product, a QR code, a GS1 Digital Link address from your GTIN if you want one, and an archive of every document version. That is the groundwork a later passport needs. Which fields it requires is decided by the act alone.
The terms and legal notices are in German, and the German version is binding.
Sources
- Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR), Official Journal (read on 11 November 2026)
- European Commission: Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187 of 16 April 2025 (read on 11 November 2026)
- Regulation (EU) 2020/740 (labelling of tyres), OJ of 5 June 2020 (read on 11 November 2026)
- Regulation (EU) 2024/1257 (Euro 7), OJ of 8 May 2024 (read on 11 November 2026)
- Implementing Regulation (EU) 2026/1778 (digital product passport registry), OJ of 17 July 2026
As of 11 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.