Frequent readers of Retreading Business will have followed our focus on EU taxonomy recently and the announcement by BIPAVER on the 12th of June that the European Commission confirmed that tyre retreading is taxonomy compliant. However, as we have alluded to in this series, taxonomy does not operate in its own regulatory world. It is entangled in a sprawling, messy web of interconnected regulations that structurally undermines the European retreading industry as well as the very environmental objectives that the European Union wants to achieve through implementing its green policy framework.
The Taxonomy Path: Where Retreading Stands
So where shall we start? It’s worth returning to the well-trodden taxonomy path and understanding how retreaded tyres are compliant within the EU’s taxonomy framework. Those familiar with this series, our deep dive explainer on taxonomy and EU regulations or even EU taxonomy itself, will know that there are two delegated acts (The Climate Delegated Act and The Environmental Delegated Act) which cover six environmental objectives. For an economy activity to be classified as “taxonomy compliant” it only needs to contribute to one or one environmental objective from either act without significantly harming the others.
Tyre retreading complies with the Environmental Delegated Act specifically section 5.4 (sale of second-hand goods) and subsection 5. Here, retreaded tyres are exempt from the requirement to meet external rolling noise thresholds in the highest populated class and rolling resistance coefficient in the highest two populated classes.
This exemption is critical. Retreads are not covered by the EU tyre label and thus cannot comply with those criteria by default. This codified exemption in the legal text therefore removes that major legal barrier.
But What About the Climate Delegated Act?
Here’s where the first contradiction begins and where the role of the EU tyre label starts to come under scrutiny again. As we have al
ready noted, an activity only needs to meet one set of criteria to qualify under the EU Taxonomy framework, meaning that tyre retreading didn’t need to comply with the Climate Delegated Act.
In the Climate Delegated Act and under transport-related sections, tyres are stated to meet performance related-thresholds in the highest rolling resistance classes, external noise limits and tyre abrasion criteria. These criteria rely upon the EU Tyre Labelling Regulation (EU 2020/740) which does not apply to retread tyres.
This exclusion clearly illustrates how the lack of an EU tyre label not only holds the retreading back, but also results in regulations that were intended to provide stamps of recognition to sustainable business activities, and are unintentionally discriminating and potentially damaging an industry. This also reinforces the wider issue of hindering market acceptance of retreads and also creating damaging regulatory inconsistencies.
It seems inconceivable that a framework that was meant to drive funding and investments towards business practices that are environmentally beneficial and save critical resources are actually placing unjust technical barriers on a process that delivers environmental gains.
Early indications from industry insiders suggest that despite taxonomy alignment, transport providers and fleets have not recognised this as relevant to their operations. This is due to the fact that the Climate Delegated Act (Regulation 2023/2485) defines transport-related activities in a way that implicitly excludes retreads—again, due to the tyre label gap.
We will be reporting on the market impact of EU taxonomy alignment for retreading further down the line, but this initial feedback from fleets further stresses the need for the EU to harmonise its policy tools and legislation so that it is consistent across the board and doesn’t provide scope or opportunities for parties to misinterpret them.
That being said, this regulatory misalignment isn’t new. The EU tyre label has been a source of structural disadvantage for retreads in procurement as well. Take for example, the EU Energy Directive 2023/1791, which requires public entities to procure tyres with the highest fuel efficiency class, again as defined by the EU label, which, as we have already pointed out, excludes retreads.
So here we are: we have an Environmental Delegated act that confirms tyre retreading is taxonomy-compliant and in theory helps promote it of strategic sustainable value. Yet on the other hand, retreading is put at a legal disadvantage in public procurement via the EU Energy Directive despite their environmental benefits and taxonomy-compliance. And then a third regulation that casts doubt on its taxonomy alignment due to technicalities.
These inconsistencies stretch even further when we analyse the EU Green Public Procurement Criteria (SWD 2021/296), which clearly support the use of retreaded tyres. So, depending on which regulation is applied—or how it’s interpreted—a fleet or government buyer could either be encouraged or discouraged from choosing retreads.
A Glimmer of Progress: The Label Is Coming
In this article, we have spent some time analysing and criticising the lack of harmonisation that runs through the various EU legislation, but for balance we must underline that work is ongoing to implement a retread tyre label and potentially fix some of these contradictions.
At the Retreading Conference in Madrid—hosted by TNU and AER—Paolo Tosoratti, from the Directorate General for Energy at the European Commission, confirmed that the process is in Phase 3: Impact Assessment, led by consultants Viegand Maagøe. A vote by Member States is expected in 2026, with adoption and publication of the delegated act also likely that year.
During his presentation Tosoratti said, “At this moment, we are in phase 3 (in red), and the next phase is expected by the end of this year. The following phases will be faster, and we hope to have a text adopted next year, in 2026.”
While this progress is encouraging, the question remains: Has the damage already been done?
These inconsistencies haven’t just created confusion—they’ve potentially delayed investment, discouraged procurement, and stunted industry growth.
Hopefully the development of the retread tyre label will assist the EU in delivering policy and regulation that reflects its circular economy priorities and not exclude and penalise tyre retreading unfairly in both green investment and public tenders, when it should be seen and promoted as an instrumental tool in delivering not only our climate goals, but protecting our environment from the proliferation of its resources.
