must I keep a copy myself of the data contained in the product passport
Keeping your own copy is advisable, even if it is not explicitly listed as a separate obligation in the ESPR
Yes, it is advisable to keep your own back-up of the passport data, independently of whether or not that is formulated anywhere in so many words. The ESPR requires that data remain available and accessible for ten years (or the period that will apply for the product group in question), and that obligation rests with the party that creates or arranges for the passport to be created. If someone depends on a single platform or a single supplier for that availability, there is a risk that data cannot be retrieved at the moment when a supervisor, customer or other party requests it — for example because the service is discontinued, changes ownership, or experiences technical problems. A copy of the source data is then not unnecessary effort, but simple insurance against something that no one can guarantee will never happen.
Who this is relevant for and who it is not
This question is particularly relevant for the party responsible for creating the passport: the manufacturer or importer that supplies the underlying product data. For a wholesaler or fleet manager who only consults the passport via the QR code, the situation is different — that party uses the data, but is not the one who must retain it. Anyone who resells tyres without being an importer themselves generally does not need to worry about keeping a copy; that is a task that lies with the source of the data. It is also a separate issue from the question of whether a passport is mandatory for a particular type of tyre — that is covered on the page on whether the product passport applies to your tyres. Here it is purely about: if a passport exists, who ensures that the data is not lost.
Your own back-up is also different from the register of digital product passports that the European Commission is setting up under article 13 of the ESPR. That register is a central facility in which (metadata of) passports are recorded, but that register does not replace the manufacturer's or importer's own responsibility to keep the underlying data available. The register is an addition, not a replacement for your own archiving.
This is separate from the date on which the delegated act appears
The obligation to keep passport data available for ten years (or the established period) follows from article 10 of the ESPR and applies as soon as the delegated act for tyres comes into force. That delegated act is expected in 2027 according to the Commission's work plan for 2025-2030; the exact date has not yet been determined. As long as that act does not exist, there is no legal obligation for tyres to have a digital product passport, and therefore no legal obligation to keep a copy of it. But the question of whether your own back-up is advisable is separate from that waiting period: anyone who is already gathering and structuring data now can just as well set up a system now in which that data is also retained outside the platform. What you can do in the meantime is described in more detail on the page about what you can do now while the rules are not yet final.
How to approach this in practice
The most logical order is: first determine which source data underpin the passport — technical specifications, test results, material information — and store them separately, outside the platform, in your own archive or document management system. Next, it is advisable to set out who within the organisation is responsible for keeping that copy up to date, especially if data change or are supplemented over the course of ten years. After that, it is recommended to check whether the chosen platform itself offers an export function with which data can be retrieved in a readable format — that is a point to take into account when choosing a platform for the product passport, because not every platform makes that equally straightforward. Those working with multiple locations should also agree on where that back-up is stored centrally, so that each location does not keep its own version — more about this is on the page on multiple locations managing one passport. Finally, it is advisable to also consult the back-up in the event of a recall, because quick access to complete product data often makes the difference there — this is covered on the page on the passport in a recall.
Where this follows from: article 10 and article 13 of the ESPR
Article 10 of the ESPR requires that the data of the digital product passport remain available for the established period, and places that responsibility with the market participant who creates the passport. A back-up of one's own does not follow literally as a separate requirement from that text, but is a practical way to continue to meet that availability obligation, even if a platform or service provider ceases to operate. Article 13 of the ESPR governs the central register of digital product passports that the Commission establishes; that register is a supplementary provision at European level and does not relieve the manufacturer or importer of their own responsibility for the underlying data.
Those already preparing now can best include this topic in the broader approach: the step-by-step explanation for the product passport for tyres describes where data storage fits in that sequence, and is a logical follow-up to this question.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 13 (register of digital product passports)
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
The ESPR provides that the digital product passport is accessible via a data carrier, and that the data remain available for a certain period (article 10, Regulation (EU) 2024/1781). The regulation addresses the question of whether the data are present and remain present, not the question of who exactly stores which copy where. The latter is a practical implementation that varies by company, and for which the legislation itself provides no instruction. Yet it is a question that every company dealing with a passport must answer for itself.
Availability of data over time
Article 10 is based on a data carrier that operates for a certain period. For a company of 10 to 100 employees, this means that something must be arranged for what happens if the party hosting the passport, for whatever reason, ceases operations, changes ownership, or encounters technical problems. Anyone who leaves the passport with only one party without making further arrangements has no visibility of what happens if that party becomes unreachable tomorrow.
Traceability via the register
Article 13 describes a register of digital product passports. That register is intended to make passports findable and verifiable. For a company, this means that its own administration and the register must align: which passport belongs to which batch of tyres, which version was active at which time. An own copy of the core data makes it easier to verify that alignment, especially when more than one supplier or platform is involved.
Demonstrability when asked later
Both in an inspection and in a dispute with a customer or supplier, the question may arise as to what was ever in a passport, and since when. A platform hosting the passport for ten years can answer that question as long as the platform exists and the data are intact. An own archive of the key data — even if it is only an export or screenshot with a date — is a second source that is not dependent on one party.
Where things go wrong in practice
An importer works with a platform that after two years is taken over by another company. The new owner stops the service after a period. Without its own copy of the passport data, the importer must start completely from scratch, asking the same manufacturers the same questions, who in the meantime may be providing different data.
A distributor sells a batch of tyres to a fleet manager. A year later, a question arises about the composition of the tyre. The distributor refers to the passport, but the passport has since been updated by the manufacturer with newer data. No one can demonstrate what it contained at the time of sale.
A company with multiple locations has each location keep its own copy independently, without an agreement on which version is the valid one. During an inspection, two locations turn out to show different data for the same tyre line. That is a risk that could have been prevented with a clear agreement on who manages the copy — a question that also comes up when setting up a passport across multiple locations of the same company.
A company switches platforms because the costs of the previous provider became too high, and discovers that the old data could not simply be transferred. Without its own archive, there was no basis to quickly provide the new provider with the correct data, which raises questions that also apply when selecting a platform for the product passport.
A supervisory authority asks during an inspection for the data as they existed at the time of sale, not as they appear now. A company that can only refer to the current passport, and has no own record of the situation at the moment of sale, has no answer to that specific question — something explained further in what a supervisory authority asks in practice about the inspection of tyres.
What you can record
- An export or copy of the passport data at the time of sale or delivery, with date, so that it can later be reconstructed what it contained at that time.
- An overview of which passport belongs to which batch of tyres, including the reference number or link to the register as referred to in Article 13.
- An agreement with the hosting party about what happens if the service is discontinued, taken over, or the contract ends — and whether data can then be transferred.
- An internal agreement, especially with multiple locations or multiple people with access, on who is responsible for maintaining the own copy.
- A fixed location — separate from the platform itself — where these copies are stored, so that they are not lost during a system change.
For those who still need to start with these agreements, there is an overview of the steps at addressing the product passport for tyres step by step. And for those who want to prepare now without waiting for the final rules, there is an overview of what can already be done at what you can already do while the rules are not yet final.
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, reviewed by a human on 2026-09-05. Is something incorrect? Let us know — corrections are given priority.