Which Tyre Label and EPREL Data Can You Reuse for a Future Tyre DPP?

What tyre data is already regulated

Regulation (EU) 2020/740 already creates a substantial structured product-information regime for tyres.²

For tyres covered by the Regulation, suppliers have obligations around the tyre label, the product information sheet and the product database. The Regulation also sets rules for information shown in technical promotional material and online or distance selling.

This is important because a future tyre DPP project does not start with an empty data model.

It starts with an existing regulated record.

The current tyre label

Annex II of Regulation (EU) 2020/740 sets the label content.² The label includes or represents, depending on the tyre and applicable conditions:

• a QR code
• supplier trade name or trademark
• tyre type identifier
• tyre size designation
• load-capacity index
• speed category symbol
• tyre class, C1, C2 or C3
• fuel-efficiency class
• wet-grip class
• external rolling-noise class and measured value in dB
• severe-snow pictogram where the tyre satisfies the relevant criteria
• ice-grip pictogram where the tyre is within the relevant scope and meets the criteria.

Those are current tyre-law requirements. They are not predictions about the future DPP.

The product information sheet

The Regulation also requires a product information sheet for the tyre type. This gives suppliers another structured publication asset tied to the regulated product record.²

The practical point is not that every future DPP field will be copied from the sheet.

It is that the supplier already has a controlled set of product identity and performance values that must stay consistent across:

• the physical or printed label
• online presentation
• the product information sheet
• the EPREL record
• supporting compliance evidence.

That consistency requirement is exactly the kind of data-governance foundation a future DPP will need.

EPREL is already part of the tyre information architecture

EPREL is the European Product Registry for Energy Labelling.

For tyres, Regulation (EU) 2020/740 requires suppliers to enter specified information into the product database before placing relevant new tyre types on the market.²

The public EPREL website exposes tyre model information such as:

• tyre class
• tyre size designation
• load-capacity index
• speed category
• load version where recorded
• fuel-efficiency performance
• wet-grip performance
• external rolling noise
• severe-snow status where relevant
• additional tyre characteristics where recorded
• supplier contact information
• downloadable label assets
• downloadable product information sheets
• market-placement or record-status information.³

The exact public display can evolve, so the legal source remains Regulation (EU) 2020/740 and its database annexes. The current public site is useful evidence of how that structured record is operationalised.

EPREL also has a compliance layer

Annex VII of the tyre Regulation separates information for the public part of the database from information for the compliance part.²

The compliance information includes material such as:

• identifiers for equivalent tyre types where applicable
• a general description of the tyre type, including relevant dimensions and classifications
• references to test, grading and measurement protocols
• precautions relevant to assembly, installation, maintenance or testing
• measured technical parameters
• calculations supporting the declared values where relevant.

This is especially useful from a readiness perspective.

A future DPP may need public data, restricted data, evidence references or some combination. Current tyre law already demonstrates that one product-data system can have different publication and compliance views.

It still does not prove what the future tyre DPP access model will be.

Is EPREL already the tyre DPP?

No.

EPREL is an existing EU product database used for regulated product information, including tyre information under Regulation (EU) 2020/740.

The future ESPR tyre DPP is still under development.

Those systems may interact. The future delegated act may reuse existing data, reference EPREL, avoid duplication or choose another relationship. ESPR itself provides mechanisms intended to avoid unnecessary duplication where other Union digital information systems achieve relevant objectives.⁴

But current primary evidence does not establish:

EPREL = the final tyre DPP

That equation should not be used.

A better statement is:

EPREL gives tyre manufacturers a valuable existing structured-data foundation and a live example of regulated digital product information. The final ESPR tyre DPP architecture is not yet adopted.

Which current tyre information is reusable?

The table below separates readiness value from future legal status.

The phrase likely reusable is deliberate.

It means the information already has a governed business and regulatory purpose, so rebuilding it from scratch later would be wasteful.

It does not mean the Commission has adopted it as a future tyre DPP field.

Existing law and future DPP law are different layers

The safest way to design a tyre DPP readiness programme is to keep the legal basis attached to every field.

For example:

Fuel-efficiency class Current status: required under tyre labelling law. Future DPP status: not yet final.

Wet-grip class Current status: required under tyre labelling law. Future DPP status: not yet final.

Tyre type identifier Current status: used in current tyre label/database architecture. Future DPP role: not yet final.

Future circularity field proposed through ESPR work Current status: development evidence only unless another law already requires it. Future DPP status: wait for the tyre delegated act.

That one discipline prevents a readiness dataset from becoming an invented legal checklist.

What is currently known about tyre DPP development

Tyres are a priority product group under the ESPR work programme.⁵

The Commission's current DPP implementation page gives Q3-Q4 2027 as the indicative period for adoption of sector-specific ESPR delegated acts for textiles, aluminium and tyres.¹

The Commission's DPP FAQ also makes the broader legal mechanism clear: ESPR does not impose a general DPP on every product automatically. Product-specific rules determine whether and how the DPP applies.⁶

For tyres, the final delegated act is therefore expected to be the critical source for matters such as:

• final DPP information requirements
• final model, batch or item granularity
• unique product identifier arrangements
• data carrier arrangements
• access rights
• relationship with existing tyre information systems
• final legal timing.

Until that measure is adopted, current tyre-label and EPREL data should be described as existing regulated information and readiness assets.

What should not be treated as final tyre DPP data

Do not turn the following into final requirements without an adopted source:

Every current tyre-label field will be a DPP field

Possible. Not established.

EPREL will simply become the tyre DPP

Not established.

The current EPREL registration number will be the DPP identifier

Not established.

The existing tyre-label QR code will be the DPP carrier

Not established.

Tyre DPPs will be item-level

Not established.

A future tyre passport will require one record per physical tyre

Not established.

All circularity, material or environmental fields discussed around ESPR are already mandatory

False as a statement of current tyre DPP law.

The right status is in official development until the applicable requirements are adopted.

A readiness architecture that avoids rebuilding the same truth

Tyre manufacturers can get practical value now without guessing the future schema.

1. Keep one canonical product identity layer

Create a governed record for each tyre type and the identifiers used around it.

Store:

• tyre type identifier
• internal product identifier
• EPREL registration reference where applicable
• brand/trademark
• size and classification
• commercial identifiers where used
• status and effective dates.

Do not let the label file become the master record.

The label should be an output from governed data.

2. Keep regulated performance values as controlled facts

For each regulated performance value, store:

• value
• class where applicable
• unit
• applicable tyre type
• test or calculation basis
• evidence reference
• effective date
• status
• source system
• last verification.

This allows the same truth to serve EPREL, the label, the product information sheet, ecommerce, dealer feeds and later a DPP mapping.

3. Preserve evidence separately from the public value

The published value is not the entire evidence chain.

Keep test reports, measurement protocols, calculation records and supporting documents linked to the fact they prove.

That becomes more important if future DPP access rights distinguish public information from authority or compliance information.

4. Treat labels and product sheets as versioned assets

Store:

• asset type
• language
• product/tyre type
• generated version
• effective date
• source data version
• superseded status.

Do not overwrite the old file with the new one and lose the history.

5. Keep a change history

EPREL public records can show that supplier information has been corrected or that a model is no longer placed on the EU market.³

Internally, preserve the reason and evidence for material changes.

A future passport will be easier to govern if the source system already knows:

• what changed
• when
• why
• who approved it
• which outputs were affected.

6. Add a DPP mapping layer later

Do not rename every current field "DPP field".

Instead, maintain a mapping table:

canonical tyre fact
→ current legal basis
→ current outputs
→ future DPP mapping: pending / confirmed / not applicable

When the delegated act arrives, the business can map adopted requirements onto an existing governed product model.

That is much safer than building a second tyre database called "DPP".

What tyre manufacturers should prepare now

PREPARE

• canonical tyre type identity
• clean supplier/operator records
• regulated dimensions and classifications
• controlled fuel-efficiency data
• controlled wet-grip data
• controlled rolling-noise data
• snow and ice performance where applicable
• EPREL record references
• label assets
• product information sheets
• evidence provenance
• technical measurement and calculation references
• effective dates
• change history
• machine-readable product records.

KEEP FLEXIBLE

• future unique-product-identifier rules
• future DPP granularity
• DPP carrier
• access model
• EPREL/DPP integration pattern
• new ESPR information fields
• final application date.

WAIT FOR ADOPTED RULES BEFORE CALLING THESE MANDATORY DPP REQUIREMENTS

• new tyre-specific ESPR fields
• item-level identity
• individual tyre lifecycle data
• new material or circularity disclosures
• any new environmental metrics not already required under current law
• a mandatory architecture replacing or merging EPREL.

What would change this page

Recheck this page when:

1. a tyre ESPR delegated act is published in draft with material detail
2. the tyre delegated act is adopted
3. the Commission formally defines the relationship between tyre DPP records and EPREL
4. new tyre-label legislation changes the current data architecture
5. DPP identifier, carrier or access rules become tyre-specific and binding.

The existing-data reuse argument is likely to remain useful. The classification of individual fields may change.

Direct questions

Do tyres already have Digital Product Passports?

Not under an adopted tyre-specific ESPR DPP measure as at 1 September 2026. Tyres already have a regulated label, product information sheet and EPREL database architecture under Regulation (EU) 2020/740.²

Is EPREL the tyre DPP?

No. EPREL is an existing EU product database. It is highly relevant to tyre DPP readiness, but current law does not establish it as the completed future ESPR tyre DPP.

What tyre data is already in EPREL?

Current public records include core tyre identity and classification, regulated performance information, supplier details, label assets and product information sheets. Regulation 2020/740 also specifies information for the compliance part of the database.²³

Can tyre-label information be reused in a DPP?

It is a strong reuse candidate because it is already structured and regulated. Final DPP inclusion must still be confirmed by the future tyre-specific rules.

When will tyre DPP requirements be final?

The Commission currently places the tyre delegated act on the Q3-Q4 2027 indicative track.¹ That is a planned adoption period, not a final compliance date.

Will tyre DPPs need item-level data?

Not established. ESPR allows product-specific delegated acts to select model, batch or item level. The tyre-specific choice is not yet final.⁴

Should manufacturers collect new data now?

Collect and govern data that already has a legal, operational or strong evidence purpose. Avoid creating speculative mandatory fields solely because they might appear in a future DPP.

Related ActivateDigital Knowledge

• Digital Product Passport Requirements by Product Category
• Tyre Digital Product Passport Requirements (P1 canonical dossier, wire when published)
• EPREL: What a Mandatory EU Product Register Produced
• How to Prepare for a Digital Product Passport
• Is Your Product Data Ready for a DPP?
• Barcodes and Product Identifiers
• Passport Evidence: How We Know, and What a Blank Means

This is a regulatory information resource, not personalised legal advice. Product scope and applicable obligations should be checked against the law applying to the specific tyre and operator.

Sources

• European Commission, Digital Product Passport. Current implementation timeline, including Q3-Q4 2027 indicative sector-specific delegated acts for textiles, aluminium and tyres.

  View official source

• Regulation (EU) 2020/740 on the labelling of tyres with respect to fuel efficiency and other parameters. Especially Articles 4-5 and Annexes II, III and VII.

  View official source

• EPREL Public website, tyres. Current public product records demonstrate the live structured publication of tyre classification, performance, supplier data, labels and product information sheets.

  View official source

• Regulation (EU) 2024/1781, Ecodesign for Sustainable Products Regulation (ESPR). Especially Article 9 and Annex III.

  View official source

• ESPR and Energy Labelling Working Plan 2025-2030, COM(2025) 187 final. Tyres are on the ESPR priority development track.

  View official source

• European Commission, DPP FAQs. Explains that ESPR does not create a general passport obligation for every product and that requirements are developed product by product.

  View official source

• European Commission, EPREL. General official explanation of the European Product Registry for Energy Labelling and public product information.

  View official source

https://energy-efficient-products.ec.europa.eu/eprel_en