Tyres are on the list of product groups that the European Commission has named as a candidate for requirements under the regulation on ecodesign, including a digital product passport. Whether this will apply to your company depends on two things: whether the Commission actually adopts an implementing measure for this product group, and what role your company plays in the supply chain for tyres.
At present, there is no definitive regulation in force for tyres. The product group is included on the work programme by which the Commission indicates which products are next in line, but the precise requirements, the scope and the date on which they will apply are only established once the corresponding implementing act has been published. For your company, this means that you can already check now whether you fall within the supply chain, without having to comply with concrete obligations yet.
What is already established and what is not
The framework regulation itself establishes how the system works: which roles exist, what a digital product passport must broadly contain, and how the Commission can establish further requirements per product group. Which data must be included in the passport for tyres, which tyre types fall under the regulation and from when this applies, is part of the implementing act that has not yet been adopted. As long as that does not exist, you cannot comply with a concrete obligation for tyres, simply because its content does not yet exist.
This distinction between the framework and the implementation per product group applies to more product groups that are still on the list. In the knowledge bank by subject you will find the current status per product group and the source in the official text, so that you do not have to search yourself when something changes.
Who in the supply chain may be affected
The regulation is aimed at economic operators: manufacturers, importers and, in some cases, distributors who place a product on the market under their own name. For tyres, this can include tyre manufacturers, companies that import tyres from countries outside the EU, and parties that have tyres manufactured under their own brand. Less obvious, but still relevant to check, are companies that process tyres in another end product, such as machines or vehicles, and companies that have tyres re-treaded before they are sold again.
Whether your company falls into one of these roles depends on how the implementing act will eventually define the product group. A garage company that only fits tyres for customers, without placing them on the market themselves, usually plays a different role than an importer that sells tyres under its own label. The difference between these roles determines who will be responsible for the passport, and you can read this difference in more detail on the page about where the information in a passport comes from.
How you can check this for your own company
Because the regulation for tyres has not yet been established, the first step is mainly: to clarify your position in the supply chain, independent of this one product group. Does your company place products on the market under its own name, do you import from countries outside the EU, or do you only supply to a party that is itself the economic operator? That question will apply later to every product group that is added, not just tyres.
A second step is to check which other product groups in your assortment already fall under an established regulation, such as batteries or construction products, and which are still on the candidate list. This way you build up an overview that grows as soon as an implementing act comes into force for tyres or other product groups. If you are unsure about your exact position, then the free quick-scan in a few questions a first indication, specifically tailored to your situation.
What you can do now
It makes little sense to start collecting data now for a passport requirement that does not yet exist. However, it does make sense to know what role you play, which product categories you carry, and where you can follow the current state of affairs. Once the Commission publishes an implementing act on tyres, that changes the situation for some of the companies in this chain, and it is time again to check whether your company falls under it.
For the precise implications for your own business, as with every product category, the official text and the competent supervisory authority are decisive; this article describes the state of affairs, not advice for your specific situation. Frequently asked questions about the regulation in general can be found compiled on the page answers to frequently asked questions.
Would you like to know how your company stands at this moment, across all product categories? Take the free quick-scan or browse through the knowledge base to see which topics are already established and which are not yet for your products.