Tyres Delegated Act Tracker: ESPR Tyres DPP Status
EXPECTED 2026-2027The tyres delegated act will establish Digital Product Passport requirements for tyres placed on the EU market. This tracker covers the current status and what tyre manufacturers need to prepare.
Current Status and Timeline
| Milestone | Expected Date | Status |
|---|---|---|
| ESPR Working Plan identifies Tyres as priority | 2022–2024 | Complete |
| Preparatory study published | 2024–2025 | In Progress |
| Stakeholder consultation | 2026-2027 | Expected |
| Delegated act adopted | 2026-2027 | Expected |
| Tyres DPP mandatory | 2028-2029 | Expected |
Key Facts for Tyres Manufacturers
Tyre DPPs are expected to build on the existing EU Tyre Labelling Regulation (EU 2020/740), which already requires disclosure of rolling resistance, wet grip, and external rolling noise. The tyre DPP will extend these requirements to include: recycled rubber content, carbon footprint per tyre, tyre wear microplastic emissions, end-of-life recyclability, and retreading suitability. Indonesia and Vietnam are major tyre exporters to the EU and will be significantly affected.
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Register Your Digital Product Passport →ESPR Tyres Delegated Act: Current Status
Tyres are already subject to the EU Tyre Labelling Regulation (EU 2020/740), which requires manufacturers to label tyres with information on fuel efficiency, wet grip, and external rolling noise. The ESPR delegated act for tyres is expected to build on the Tyre Labelling Regulation by adding requirements for DPP data disclosure, minimum recycled content requirements, and restrictions on the use of hazardous substances in tyre compounds (particularly polycyclic aromatic hydrocarbons and microplastic-generating substances).
The preparatory study for the ESPR delegated act on tyres was launched in 2023. The study is examining the environmental impact of tyres across the full lifecycle, including the sourcing of natural rubber and synthetic rubber, the manufacturing process, the use phase (including tyre wear and microplastic generation), and the end-of-life phase (including tyre recycling and energy recovery). The study is also examining the feasibility of different policy options, including minimum recycled content requirements, restrictions on hazardous substances, and DPP data disclosure requirements.
Frequently Asked Questions
The ESPR delegated act for tyres is expected to be adopted in 2025–2028. The exact timeline will depend on the outcome of the preparatory study. Tyre manufacturers should plan for compliance by 2027–2030.
The Tyre Labelling Regulation requires manufacturers to label tyres with information on fuel efficiency, wet grip, and external rolling noise. ESPR adds requirements for DPP data disclosure, including material composition, recycled content, and substances of concern. The Commission is working to align the DPP requirements with the Tyre Labelling Regulation to avoid duplication.
Tyre wear is a significant source of microplastic pollution. The ESPR delegated act for tyres is expected to require disclosure of tyre wear rates in the DPP and may set minimum requirements for tyre wear resistance. The Commission is also developing a broader microplastics restriction under REACH that will affect tyre manufacturers.
The ESPR delegated act for tyres is expected to set minimum recycled content requirements, including requirements for recycled rubber content. End-of-life tyre rubber can be recycled into new tyres (devulcanisation), used as a raw material in other rubber products, or used as a fuel substitute in cement kilns. The delegated act may set minimum requirements for the use of recycled tyre rubber in new tyres.
The ESPR delegated act for tyres is expected to cover new tyres. Retreaded tyres may be subject to separate requirements or may be exempted from certain requirements. The preparatory study will examine the feasibility of applying ESPR requirements to retreaded tyres and make recommendations to the Commission.
Tyre Delegated Act: Preparatory Study and Timeline
The EU Commission's preparatory study for the ESPR tyre delegated act is currently underway. The study is examining the environmental impact of tyres across their lifecycle — from raw material extraction (natural rubber, synthetic rubber, carbon black, steel cord) through manufacturing, use (rolling resistance, wear), and end of life (tyre recycling, rubber granulate production). Preliminary findings indicate that the most significant environmental impact of tyres during use is rolling resistance — a tyre with lower rolling resistance reduces vehicle fuel consumption and CO₂ emissions. The existing EU Tyre Labelling Regulation (EU 2020/740) already addresses rolling resistance through the fuel efficiency label (A–E). The ESPR tyre delegated act is expected to build on this by introducing minimum rolling resistance requirements and DPP obligations.
End-of-Life Tyre Management and ESPR
End-of-life tyres (ELTs) are a significant waste stream in the EU — approximately 3.5 million tonnes of ELTs are generated per year. The EU has a well-developed ELT management infrastructure, with recovery rates above 95% in most member states. The main ELT recovery routes are: material recycling (rubber granulate for sports surfaces, playgrounds, and road construction), energy recovery (tyre-derived fuel in cement kilns), and retreading (extending tyre life). The ESPR tyre delegated act is expected to introduce minimum recycled rubber content requirements for new tyres — requiring manufacturers to incorporate a percentage of recycled rubber from ELTs into new tyre compounds. This would create a direct market for ELT rubber granulate and incentivise investment in ELT recycling infrastructure.
Tyre Sector Engagement with ESPR Consultation
The European tyre industry trade association, ETRMA (European Tyre and Rubber Manufacturers' Association), has been actively engaged in the ESPR tyre delegated act consultation process. ETRMA has published position papers on the ESPR preparatory study, highlighting the sector's support for DPP requirements and its concerns about the feasibility of minimum recycled rubber content requirements given the current state of rubber recycling technology. ETRMA has also engaged with the GS1 organisation to develop a tyre-specific implementation guide for GS1 Digital Link, which will provide practical guidance for tyre manufacturers implementing their DPP systems. Tyre manufacturers should engage with ETRMA and their national trade associations to stay informed about the delegated act consultation process.
Tyre Labelling Regulation and ESPR: Building on Existing Requirements
Tyres are already subject to the EU Tyre Labelling Regulation (EU 2020/740), which requires tyres to display a label showing their fuel efficiency class (A–E), wet grip class (A–E), and external rolling noise class (A–C). The ESPR tyre delegated act will build on the Tyre Labelling Regulation framework, adding DPP requirements for recycled rubber content, carbon footprint, and end-of-life recyclability. Tyre manufacturers that are already complying with the Tyre Labelling Regulation will have a foundation for ESPR DPP compliance — the tyre performance data required for the label (rolling resistance, wet grip, noise) overlaps with the data that will be required in the ESPR DPP.
Tyre DPP: Expected Data Requirements
The ESPR tyre DPP is expected to require disclosure of the following data: tyre size and load/speed index, fuel efficiency class (A–E), wet grip class (A–E), external rolling noise class (A–C), recycled rubber content percentage, carbon footprint per tyre (kg CO₂e), chemical substances of concern (PAHs, heavy metals, microplastic shedding rate), expected tyre lifetime (km under defined conditions), and end-of-life recyclability instructions. Tyre manufacturers should begin collecting this data now, as the delegated act is expected to be published in 2027 with a 2-year implementation period.
Microplastic Shedding and ESPR Tyre Requirements
Tyre wear particles (TWPs) are a significant source of microplastic pollution — it is estimated that tyres shed approximately 6 million tonnes of microplastics globally per year. The EU Commission has identified tyre microplastic shedding as a priority issue for ESPR, and the tyre delegated act is expected to include requirements for minimum tyre lifetime (to reduce the total volume of TWPs per km driven) and for disclosure of the tyre's microplastic shedding rate. The EU Commission is funding research into tyre microplastic shedding measurement methodologies, and a standardised measurement method is expected to be published in 2025–2026. Tyre manufacturers should monitor this research and begin assessing the microplastic shedding performance of their tyre portfolio.
Tyre Manufacturers' ESPR Preparation: Key Actions for 2025–2027
Tyre manufacturers should take the following key actions during the 2025–2027 period to prepare for ESPR compliance. First, conduct a material composition audit of the tyre portfolio — identifying the rubber content (natural vs synthetic), carbon black content, steel cord content, textile cord content, and chemical additives (plasticisers, antioxidants, vulcanisation agents) for each tyre model. This audit will identify the substances of concern that must be disclosed in the ESPR DPP and will provide the baseline data for the recycled rubber content calculation. Second, implement a tyre lifetime testing programme — testing each tyre model against the relevant ISO and ETRTO standards to determine the expected tyre lifetime under defined conditions. This data will be required in the ESPR DPP and will also support the tyre's fuel efficiency class calculation under the Tyre Labelling Regulation. Third, engage with the GS1 organisation to obtain a GS1 Company Prefix and to begin implementing GS1 Digital Link for tyre identification. Tyres are currently identified using the ETRTO size designation (e.g., 205/55R16 91V), but ESPR will require a unique product identifier that can be encoded in a QR code or NFC tag. The GS1 Digital Link standard provides a globally interoperable way to link the tyre's physical identifier to its DPP data.
Fourth, assess the feasibility of increasing recycled rubber content in the tyre compound. The ESPR tyre delegated act is expected to introduce minimum recycled rubber content requirements — the expected minimum is 10–15% recycled rubber content by weight. Tyre manufacturers should engage with their rubber suppliers to understand what recycled rubber content levels are achievable without compromising tyre performance (rolling resistance, wet grip, durability). Fifth, monitor the development of the standardised tyre microplastic shedding measurement methodology and begin assessing the microplastic shedding performance of the tyre portfolio. The EU Commission is funding research into tyre microplastic shedding measurement methodologies, and a standardised measurement method is expected to be published in 2025–2026. Tyre manufacturers that begin their microplastic shedding assessment now will be ahead of the curve when the ESPR delegated act is published.
Tyre manufacturers should note that the ESPR tyre delegated act will apply to all tyres placed on the EU market, including tyres imported as part of vehicles. Vehicle manufacturers that import vehicles into the EU will be responsible for ensuring that the tyres fitted to their vehicles comply with the ESPR tyre requirements. Vehicle manufacturers should engage with their tyre suppliers now to understand the ESPR compliance status of the tyres they use, and should include ESPR tyre compliance requirements in their supplier contracts.