are there different rules for the product passport in other EU countries

No, the ESPR applies uniformly throughout the EU

The obligation regarding the digital product passport stems from a European regulation, and a regulation applies directly and identically in all member states. There is therefore no room for a member state to create its own version, stricter or more lenient. What applies in the Netherlands for a tyre importer applies in the same form for a tyre importer in Germany, Poland or Spain. This is also the key difference with a European directive: a directive must first be transposed into national legislation, and in doing so member states can make their own choices. The ESPR is not a directive but a regulation, and that is the difference between "the same in every EU country" and "slightly different from country to country".

For whom this applies, and where the nuance actually lies

This uniformity applies to the core of the obligation: who falls under the regulation, which product categories fall under it once this has been established via a delegated act, and what a product passport must minimally contain. This follows from the scope and definitions in Article 1 and Article 2 of the ESPR (Regulation (EU) 2024/1781), and that text is the same in every member state. Where it becomes more nuanced is in implementation. Regulations are enforced by national market surveillance authorities, and the way a surveillance authority checks, prioritises or acts is a national matter. This does not mean that the rule differs, but it does mean that the practice of enforcement can look somewhat different in one member state than in another. As for whether the product passport applies at all to tyres, that is in any case a separate step: it is established per product category, as described on the page does the digital product passport apply to my tyres.

Also important to distinguish: this uniformity concerns the ESPR obligation itself, not everything else to do with tyres. National rules in other areas — think of customs procedures, VAT administration, or specific enforcement practices at import — can vary from country to country. Anyone wishing to learn more about this will find background on the page on the product passport and customs or VAT at import. The ESPR obligation itself is uniform; it is the environment around it that can vary from country to country.

No fixed date yet, but a fixed structure

There is no delegated act yet published that specifically establishes for tyres from when the product passport is mandatory. The ESPR work plan 2025-2030 mentions 2027 as the expected period for that delegated act, but that is a schedule, not a fixed date. Once the act is in place, it will apply — just like the regulation itself — in all member states simultaneously and in the same way. There is therefore no risk that one member state will be obliged earlier than another: the date of entry into force is established in the act itself and is the same for the entire EU. The fact that such a delegated act is worked out per product category is described in Article 4 and Article 8 of the ESPR, and the way in which the European Commission prioritises product categories follows from Article 18. Until the act is in place, nothing changes in the obligation itself — which still needs to be established — but the basic rules on who is responsible for what are already fixed in the regulation.

What this means in practice for a tyre company

For a company that imports, trades or sells tyres under its own brand, the practical consequence is that there is no need to build up a separate file per country once the obligation takes effect. One product passport, compiled according to European requirements, is in principle sufficient throughout the EU. Anyone wondering what role they play in this can best find out in this order: first check whether their own role is that of manufacturer or importer, as explained on the page am I an importer or manufacturer according to the ESPR, because that role determines who must have the passport compiled. Next, it is relevant whether sales run through a proprietary brand, through a distributor, or through an online marketplace — for each of those situations slightly different emphases apply, even though the underlying European rule is the same in every country in which sales take place. Because enforcement is national, it may be worthwhile to keep track of how your own national supervisory authority deals with this, but that does not change what the product passport must contain substantively.

Where this follows from: article 1, 2, 4, 8 and 18

That the ESPR is a regulation and thus applies directly and uniformly in every Member State follows from the nature of the instrument itself and from the scope in article 1 and the definitions in article 2 of Regulation (EU) 2024/1781. The competence of the European Commission to establish delegated acts per product category, and what those acts must regulate, is set out in article 4 and article 8. The way in which product categories such as tyres come onto the planning is set out in article 18. None of these articles leaves room for a Member State to operate its own, divergent version of the obligation.

Anyone wishing to prepare now what must happen once the delegated act for tyres is in place is best advised to start by getting a clear picture of their own role in the chain — as an importer, as a distributor, or as a seller under a proprietary brand — because that role will determine who supplies the passport in every EU country in which sales take place.