The Ecodesign for Sustainable Products Regulation (ESPR) sets a framework for improving the sustainability of products by establishing performance and information requirements. Tyres are among the priority products to be regulated, and the tyre delegated act is expected to be published in 2027, as defined in the ESPR working plan published by the European Commission.

To allow for a successful implementation of ecodesign criteria for tyres the framework must consider the following elements and concepts:

• Ecodesign criteria should focus on the overall environmental footprint (including carbon footprint) of tyres, providing a holistic vision of the sustainability of tyres, especially without compromising safety-related performances (i.e. a tyre’s ability to maintain grip, control, and structural integrity under varying driving and weather conditions).
• The assessment of ecodesign criteria should be grounded in quantitative, representative, and reliable data and information.
• Given the inherent trade-offs amongst them, tyre performance characteristics should be assessed holistically, in accordance with a Balance of Performance approach. Any proposal for ecodesign criteria that addresses only a subset of these characteristics, while disregarding others, may give rise to significant drawbacks that could ultimately undermine the EU’s overall approach to tyre performance compromising safety and other environmental performances.
• Potential ESPR provisions should ensure consistency and create synergies with the current and future regulations on tyres (e.g. UN R117, Euro 7 etc) and contribute to setting the regulatory ambition for the longer term. This is key to driving innovation and supporting long-term investments across Europe.
• It needs to be considered that tyres are governed by more than 10 EU regulations and up to 13 UNECE performance standards (depending on the tyre type), covering safety (e.g., UN R117, UN R30), chemical content (REACH, CLP), environmental performance (Euro 7, restriction on chemicals), recyclability (ELV, Waste Framework Directive), and product information (e.g., tyre labelling regulation).
• Clear and standardised definitions are vital for the success of the ESPR as they ensure consistency and applicability. Currently, some key circular economy terminology is not consistent across legislation or appears to be ambiguous when applied to tyres. Moreover, there are some key concepts that are still lacking legal definition. ESPR offers an opportunity to set industry-specific definitions that will support its policy implementation and allow for alignment with all stakeholders along the supply chain.
• Establish a practical and enforceable framework for reporting that ensures fair competition across the tyre industry. When introducing ecodesign criteria for tyres, the Regulation also needs to set a reporting framework. Any performance criteria being introduced need to be supported by a clear methodology, reporting framework and implementation timeline that balances administrative efforts as well as financial burdens. Industrial tyre development and manufacturing is a complex process that includes multiple steps and changes may result in numerous unforeseen side effects. Therefore, implementation needs a pragmatic with a feasible timeline based on criteria verifiable by market surveillance authorities.
• Tyres Europe fully supports the ambition of the ESPR regulation in fostering greater transparency throughout product lifecycles by communicating and reporting on the presence of Substances of Concern (SoC) through the supply chain. At the same time, Tyres Europe strongly believes that only the REACH regulation is in place to propose regulatory measures such as restrictions on substances. Tyres Europe, therefore, strongly opposes restrictions on materials and/or substances unless an impact assessment for each material or substance category is performed and unless there is substantive quantified evidence that these materials hinder recycling operations.

Read the full position paper below.