Tyres Europe 'strongly opposes' materials restrictions under future ecodesign rules for tires

Brussels – Tyres Europe has strongly opposed the introduction of restrictions on materials or substances under future ecodesign requirements for tires, arguing that such measures should remain within the scope of the EU's REACH chemicals regulation.

The European Commission has identified tires as one of the priority product groups to be regulated under the ESPR framework, with a delegated act expected in 2027.

In a 5 June position paper on the forthcoming Ecodesign for Sustainable Products Regulation (ESPR) delegated act for end-of-life tires (ELTs), the industry association said it "strongly opposes restrictions on materials and/or substances" unless individual impact assessments are carried out and there is "substantive quantified evidence" showing that the materials concerned hinder recycling operations.

“Eliminating materials such as sealants, foams and reinforcement systems would not increase the treatment of ELTs… as is now being proposed in the ongoing work around the preparatory study on ecodesign criteria for tires,” said Tyres Europe.

According to the Brussels association, demand for higher value applications in the waste hierarchy is currently insufficient and must be developed first.

Tyres Europe noted that around half of ELTs are sent to co-incineration, significantly more than the share of sealant or foam tires on the market.

This, it said, shows that these routes are not driven by the presence of such materials.

Such technologies, Tyres Europe pointed out, are developed to ensure fewer premature replacements, longer usable lifespan, and lower material demand overall.

“If any of these technologies create serious problems for recycling, those must be compared to the safety and environmental benefits gained during the use phase,” it added.

Elsewhere, Tyres Europe said future ecodesign criteria should focus on the "overall environmental footprint" of tires, including carbon footprint, while ensuring that sustainability measures do not compromise safety-related performance.

The association argued that tire performance characteristics must be assessed holistically through a "balance of performance" approach.

Focusing on only some attributes, it added, could create unintended consequences for safety and environmental performance.

"Any proposal for ecodesign criteria that addresses only a subset of these characteristics, while disregarding others, may give rise to significant drawbacks," the paper states.

Tyres Europe also called for ecodesign requirements to be based on "quantitative, representative, and reliable data" and urged policymakers to ensure consistency with existing and future tire regulations, including UN Regulation 117 and Euro 7 requirements.

The association noted that tires are already covered by more than 10 EU regulations and up to 13 UNECE performance standards, spanning safety, chemical content, environmental performance, recyclability and product information requirements.

The paper further called for "clear and standardised definitions" for circular economy concepts, arguing that some terminology remains inconsistent across legislation or lacks a legal definition when applied to tires.

Tyres Europe also urged the EU to establish a "practical and enforceable framework" for reporting requirements, supported by "clear methodology, reporting framework and implementation timeline" that can be verified by market surveillance authorities.

While supporting the ESPR objective of increasing transparency on substances of concern throughout product lifecycles, the association said regulatory restrictions on substances should continue to be handled through REACH rather than through ecodesign legislation.