What obligations does a distributor or dealer of tyres have?
Distributors and dealers check, do not themselves comply with the rules
Under the ESPR (Regulation (EU) 2024/1781), a distributor or dealer of tyres has no obligation to compile a digital product passport themselves — that is the responsibility of the manufacturer or importer. What is expected of a distributor or dealer, however, is that they verify whether this work has already been completed before the tyre is offered or sold. In concrete terms, this means checking whether the required marking is present, whether the digital product passport exists and can be consulted via the data carrier (usually a QR code), and whether the accompanying documentation is correct. If this is missing, the responsibility to rectify it rests initially with the manufacturer or importer — the distributor or dealer reports and acts accordingly, for example by not placing the tyre on the market until the issue is resolved.
Who this applies to, and who it does not
These obligations apply to every party in the supply chain that offers tyres without being a manufacturer, importer or authorised representative themselves: wholesalers, resellers and other traders who resell tyres to subsequent links in the chain or to end-users. They therefore apply in addition to, and not instead of, the obligations of manufacturers (who actually compile the passport) and importers (who, upon importation from outside the EU, have a similar verification role as the manufacturer themselves if not established in the EU). A party that only mounts or maintains tyres without placing them on the market themselves does not automatically fall under this distributor role — the regulation looks at who offers the product on the market, not who mounts it. It is also important to note that these rules only take concrete form once a product-specific delegated act has been established for tyres; until then, the general obligation from the ESPR exists as a framework, but without the tyre-specific requirements against which compliance can be assessed.
Date not yet fixed, only the process
There is no fixed date yet on which these obligations for tyres will actually come into force. What is certain: tyres are included in the ESPR work plan for 2025-2030, with a delegated act expected by 2027. Only after publication of that delegated act will it become clear from which date distributors and dealers of tyres must actually verify compliance with a digital product passport, and which data must be included in it. Until then, the general provisions of the ESPR apply as a framework, but without creating a concrete obligation to specifically verify a passport for tyres. Once the delegated act is published, the date will be added to this page.
What a distributor or dealer can prepare now
The sequence in which this topic is usually tackled starts on the procurement side: checking with which suppliers and manufacturers work on a digital product passport for the tyres being purchased is already underway, and whether those parties already have visibility of the QR data carrier that goes with it. After that, it is useful to look internally at your own range and your own administration: what data is already recorded about the origin, composition and certification of tyres, and is it stored in a way that can easily be linked to a passport later on. A third step is to agree with suppliers on who provides and hosts the passport, and who is responsible if the QR code does not work or the data proves to be incorrect — this is exactly the type of arrangement that a service like tyrepas.eu fulfills, by compiling the passport from the data of the manufacturer or importer and providing the data carrier. Finally, it is practical to know now who within your own organization will be responsible for verifying passports when receiving a shipment of tyres, so that this role is not filled only when the obligation comes into force.
Legal basis: Articles 30 and 31 of the ESPR
This allocation of roles and responsibilities follows from Article 30 and Article 31 of Regulation (EU) 2024/1781 (ESPR), which set out the obligations of distributors and traders in addition to those of manufacturers, authorised representatives and importers elsewhere in the same chapter. These articles describe the general division of roles that applies to all products within the ESPR; the product-specific implementation for tyres — which data exactly must appear in the passport and from when — will only follow from the delegated act for tyres that still needs to be adopted and published.
If you want to prepare now, the best approach is to map your own supply chain and discuss with suppliers who will be responsible for the digital product passport. Once the delegated act for tyres has been published and a date is known, this page will be updated accordingly.
What this is based on
The regulation itself is available on EUR-Lex. We provide references per statement; you do not have to take our word for it.
What you must do concretely
What is expected of you
A distributor or trader is anyone who trades in tyres without manufacturing, importing, or placing them on the market under their own brand. Think of a wholesaler that purchases tyres from an importer and resells them to garages, or a tyre shop that supplies vehicle fleet managers directly. The ESPR (Regulation (EU) 2024/1781) imposes a number of obligations on this link in the chain, in Articles 30 and 31. These are less stringent than those of a manufacturer or importer, but not optional. If you are uncertain about the exact role your company has, this should first be clarified via am I an importer or manufacturer according to the ESPR? — the obligations below apply only if that question is answered with "distributor".
Check whether the product passport is present
Before a batch of tyres is offered on the market, a check is required: is there a digital product passport, and has the QR data carrier been affixed to the tyre or the packaging? For a company with 10 to 100 employees, this means in practice a fixed control point upon receipt of goods — comparable to a quality control. It is a visibility check, not a recalculation of the contents of the passport.
Check whether required information is visible
In addition to the passport itself, certain information must be displayed on or with the product, such as conformity markings. A distributor does not need to generate these themselves, but is expected to flag when they are missing before the batch is resold.
Do not participate in offering non-conforming products
When a distributor knows — or on the basis of available information should know — that a batch of tyres does not meet the requirements, he is expected not to offer that batch on the market until this has been rectified. This particularly affects companies that maintain their own inventory and repackage or redistribute on their own initiative.
Corrective measures upon detection of non-conformity
If a distributor finds that a product that has already been offered is not in conformity, he is expected to take action within his capabilities — for example by informing the manufacturer or importer, or by withdrawing the batch. For a mid-sized company, this means there must be a point of contact who knows who the manufacturer or importer in the chain is, and how to reach them.
Pass on and retain information
A distributor is expected to be able to pass on relevant information about the product — including the identity of the party responsible for the product passport — to supervisory authorities and other links in the chain, upon request. This requires basic record-keeping: from whom a batch of tyres was taken and to whom it was supplied.
Cooperation with supervision
Upon request from a supervisory authority, a distributor is expected to cooperate in providing documentation and information needed to demonstrate the conformity of a product. This is usually a matter of being able to submit files, not of conducting substantive investigations themselves.
Where things go wrong in practice
A number of situations occur regularly in practice.
Resale without check. A wholesaler takes over a batch of tyres from a smaller importer and sends it on to garages without further checks. No consideration is given to whether a passport and QR code are present, because "the supplier will have taken care of that".
Own labelling without awareness of change of role. A trader places their own stickers or labels on the packaging, without realising that this may under certain circumstances have consequences for the role the company holds in the chain. This relates to the question also raised in selling under your own brand — what obligations do I have?.
No established point of contact with the manufacturer. When a supervisory authority notifies, it appears that nobody in the company knows who the original manufacturer or importer is, because purchasing data has not been systematically retained.
Lack of clarity regarding non-EU manufacturers. A distributor obtains tyres from a batch that was ultimately manufactured outside the EU, without clear understanding of who in the chain is responsible for the product passport. This situation is further explained at my manufacturer is outside the EU — who arranges the product passport then?.
Sales via a platform without separate verification. Tyres are also offered via an online marketplace, with the assumption that the platform itself is responsible for the presence of the passport. See regarding this what does the product passport mean if I sell tyres via an online marketplace?
What you can record
For a distributor or trader, it is practical to document a number of matters in writing, so that these are quickly available upon request:
- An overview of suppliers per product line, with contact details of the manufacturer or importer responsible for the product passport.
- A fixed control point upon receipt of goods, in which it is recorded whether the passport and the QR data carrier are present.
- A procedure for the case in which a batch is identified as non-compliant: who is informed, and what steps are taken before sales take place.
- Purchasing and sales administration showing from whom a batch was received and to whom it was delivered.
- A point of contact within the company that can handle communication with supervisory authorities.
This documentation need not be burdensome for a company of this size; a few standard templates and a fixed control point are sufficient in most cases. Those who wonder how this relates to their own position in the chain will find a general overview at who is responsible for the product passport of tyres?
This is not legal advice. This page provides general information about the legislation that this platform concerns. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections are given priority.