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Energy Efficient Products

What happens if a vehicle is imported fitted with tyres not already placed on the EU market?

For tyres not placed on the EU market as replacement tyres and only delivered mounted on a new car imported in the EU,  who should be responsible for registration of the tyre in the product registration system  EPREL? 

Vehicle manufacturers or vehicle importers placing on the EU market vehicles equipped with tyres not already placed on the market, act as importers of those tyres, with all related obligations.

In other terms, the vehicle importer acts as tyre importer as well.

Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.