Who creates the digital product passport for tyres fitted to a new vehicle?
The tyre manufacturer compiles the passport, not the vehicle manufacturer
The product passport of a tyre is created by the manufacturer or importer of that tyre, even if the tyre is already mounted on a new vehicle at the factory. Under the ESPR system, the tyre remains its own product with its own passport obligation, regardless of whether it is sold separately to a garage or mounted during vehicle assembly. The vehicle manufacturer mounts the tyre, but is not the party that provides the underlying data on the tyre's materials, origin and performance — that is done by the party that produced or imported the tyre. For an importer, wholesaler or fleet manager, this means that the question "who creates the passport" in practice always comes down to the tyre itself, not the vehicle on which it is mounted.
For original and replacement tyres, not for the vehicle as a whole
This distinction applies to the tyre as a product, whether it is mounted as "original equipment" (OE) directly during vehicle assembly, or sold later as a replacement tyre. In both cases, the tyre that falls under the future delegated act for tyres is the one that receives a passport — created by whoever places the tyre on the market. This explicitly does not concern the passport of the vehicle itself: a car, van or other vehicle category is subject to its own framework and its own obligations, which are not covered here. Nor does it concern other vehicle components that may fall under a different product. The demarcation is therefore based on the product "tyre", regardless of where and when it is mounted.
No fixed date yet, expected around 2029
There is no fixed entry date yet for the tyre passport obligation. The ESPR work plan for the period 2025-2030 states 2027 as the expected date when the delegated act for tyres will be adopted. The actual date on which tyre manufacturers and importers must provide a passport will only follow after publication of that act; based on current planning, the obligation is expected to take effect around 2029, but this is therefore not yet fixed. Until that time, there is no legal obligation to create a digital product passport for tyres — whether loose or mounted on a new vehicle. Once the delegated act has been published, the date will be updated here.
What this means in practice
For those who import tyres, resell them or manage a fleet, the sequence of action is straightforward. First: check whether the tyres being purchased or managed fall within the forthcoming regulation — this concerns the tyre categories designated in the delegated act, once it is known. Next: when purchasing new vehicles with tyres already mounted, ask the vehicle supplier or the tyre manufacturer themselves which party holds the data on that tyre — this is typically not the vehicle manufacturer. Finally: do not take action based on a date that is not yet fixed, but do start mapping which tyre brands and types are present in your own procurement package or fleet, so that when the delegated act is published, it will quickly be clear which passports become relevant. For tyre importers who themselves place a tyre on the EU market as the first party, the role of "passport compiler" is most obvious, even if that tyre is subsequently mounted on a new vehicle by a third party.
Where it is stated: Article 27 and Article 38 of the ESPR
This follows from the systematic approach of Regulation (EU) 2024/1781 (ESPR). Article 27 describes the obligations of manufacturers: they are responsible for compiling and keeping up to date the product information that goes into the passport, for the product they manufacture or place on the market under their name — in this case the tyre. Article 38 regulates the requirements for actors in the supply chain: parties that process a product with a passport into a larger whole, such as a vehicle manufacturer that mounts tyres, are dealing with the transmission and use of that passport data, without the core obligation to create the passport shifting to them. That distinction between "manufacturer of the product" and "actor who further processes the product" is the reason why the tyre, even when mounted on a new vehicle, retains its own passport and its own responsible party.
Those who wish to sort things out in advance should best document which tyre suppliers and types appear in their own procurement or fleet inventory, and ask their own tyre supplier whether preparations are already underway towards a digital passport — so that when the delegated act is published, no time is lost in retrieving basic data.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 27 (obligations of manufacturers)
- Regulation (EU) 2024/1781 (ESPR), Article 38 (requirements for actors in the supply chain)
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
Tyres fitted to a new vehicle are a special case. The tyre itself remains a product with its own passport obligation, but the tyre simultaneously becomes part of a larger whole: the vehicle. This often raises the question for importers and distributors about who is actually responsible for the passport — the tyre manufacturer, or the vehicle manufacturer who fits the tyres.
The tyre manufacturer remains responsible for the tyre as a product
The obligations for manufacturers under Article 27 of the ESPR (Regulation (EU) 2024/1781) rest with the party that produces and places the tyre on the market. This does not change because that tyre is subsequently fitted to a new vehicle. For a company with 10 to 100 employees that imports or produces tyres, this means that the obligation to provide a passport of its own is separate from the question of whether the tyre is sold separately or as original equipment on a car, bus or lorry. The tyre carries its own passport, with its own data, regardless of its destination.
Your position in the supply chain determines what you supply
When a tyre manufacturer or importer supplies tyres to a vehicle manufacturer, a link is created in the supply chain as referred to in Article 38 of the ESPR (Regulation (EU) 2024/1781). That Article governs what actors in that chain must be able to pass on to each other, so that the information needed for the passport is not lost between the tyre factory and the vehicle builder's assembly line. For a tyre distributor or importer, this means in practice that the product information of its own is supplied in a way that the vehicle manufacturer can use — not that the tyre batch itself compiles the vehicle passport.
Two passports, two parties responsible
A new vehicle may eventually receive its own product passport, separate from the passport of the tyre fitted to it. These are two different documents with two different parties responsible: the vehicle manufacturer for the vehicle, the tyre manufacturer or importer for the tyre. For a company that supplies only tyres to the automotive industry, this means that there is no additional obligation to document anything about the vehicle itself. Your own scope remains the tyre.
The data must match what the tyre actually is
Because the tyre as original equipment has the same technical identity as a tyre sold separately, in most cases the same data is relevant for the passport. Which data exactly that is, is described on the page about which data will be in the product passport for tyres. For a manufacturer that both sells separately and supplies to vehicle builders, this means that in practice it is possible to work with one information base per tyre type, regardless of the sales channel.
Where things go wrong in practice
A first situation that often occurs: a tyre manufacturer assumes that the vehicle manufacturer 'will take care of it' because the tyre is now part of a car. This is a misconception — the passport obligation for the tyre as a product does not disappear through fitting to a vehicle.
A second situation: data is supplied to the vehicle manufacturer, but in a form that does not match what is needed for a separate passport of the tyre. Double work is then performed as soon as the tyre is also marketed separately, because the information is not stored in a reusable manner.
A third situation occurs in companies that sell tyres both separately and supply them to vehicle builders: two different files are created for exactly the same tyre type, with minor differences between them that can no longer be traced to the correct version afterwards.
A fourth situation: an importer thinks that their own role as a supplier in the chain (Article 38) exempts them from manufacturer obligations (Article 27), whereas both roles can exist side by side when the same party is both tyre manufacturer and supplier to the automotive industry.
A fifth situation: no distinction is made between the question of whether the tyre falls under the ESPR as an independent product — that question is answered on the page about which products from the tyre sector fall under the ESPR — and the question of who in the supply chain passes on which information. These are two separate questions that are being conflated, with the result that no one in the chain feels responsible for the tyre's own product passport.
What you can record
- An overview of which tyres are supplied as original equipment to which vehicle manufacturers, and which of those same tyre types are also sold separately on the market.
- A fixed dataset per tyre type (technical specifications, material composition, origin) that serves both as the basis for its own product passport and for the information passed on to a vehicle manufacturer under Article 38.
- An internal agreement about who within the company is responsible for keeping that dataset up to date, so that a change in the tyre is not updated in one file and not in the other.
- Correspondence or contractual agreements with vehicle manufacturers on the form in which data are supplied, so that it can later be demonstrated which information was shared at which point in time.
- A reference to the company's own status as manufacturer or importer — that status determines whether, and if so how, the product passport for the company's own tyres appliesand that determination can be separated from the question of whether the tyre ultimately ends up on a new vehicle.
- Documentation of the company's own role in the supply chain: is the company here a manufacturer, importer, or only a supplier of components to another manufacturer — that distinction is relevant once the obligations from Article 27 and Article 38 come into view at the same time.
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.