what should I do if the QR code on the tyre is illegible or damaged

A damaged QR code does not invalidate the product passport

The product passport itself persists, even if the QR code on the tyre is no longer readable. The QR code is not the passport — it is merely the data carrier that refers to the passport. The ESPR makes a clear distinction in Article 11 between the digital product passport (the data, stored with a provider) and the carrier by which someone accesses it. If that carrier becomes damaged, faded, or unreadable, the problem is therefore practical: someone cannot consult the passport via that tyre for the time being. The passport does not disappear as a result and the data in it does not change.

For whom this is relevant, and for whom it is not

This issue is particularly relevant for tyres that have been in use for some time: wear, retreading, cleaning with aggressive substances, or simply years of driving can make a QR code unreadable. For a fleet manager or garage that wants to check a tyre, that is inconvenient but not a legal problem — they are not expected to repair the code. For the party that placed the tyre on the market (manufacturer or importer), it is different: they remain responsible for the fact that there is a functioning data carrier on the product at the moment of sale. Damage that occurs afterwards, through use, falls outside that responsibility. This topic is not about how the code is initially placed on the tyre — that is described on the page about how the QR code is applied to the product — and nor is it about whether the passport itself is retained for ten years or longer, which is a separate topic.

When this will come into force is not yet established

The obligation for a digital product passport with QR data carrier for tyres follows from the ESPR, but the date on which this concretely takes effect for tyres depends on a delegated act that still needs to be published specifically for tyres. According to the European Commission's work programme for 2025–2030, this is expected in 2027, but that is an expectation, not an established fact. Until that act is in place, there are no concrete obligations for QR codes on tyres and therefore no rules about what to do in case of damage to them. As soon as the date is established, it will be stated here.

What this means in practice

For those now thinking ahead about how this will work, the logic can be built as follows. First: the QR code is a reference, not a storage location. The data is held by the party hosting the passport — in the case of tyrepas.eu for ten years — and not on the tyre itself. A scratch or fading of the code therefore does not mean that data is lost.

Next: the way someone can still access the passport without a working QR code depends on how the identification is set up. If the tyre has a unique identification code that is also traceable independently of the QR code — for example via the frame number, a DOT code, or another characteristic that the importer has recorded — the passport can often still be retrieved via the register of digital product passports or via the system of the party managing the passport. How that unique identification code is precisely structured and what role the tyre size plays in it is described on the page about the link between tyre size and identification code.

For an importer or wholesaler who has passports created themselves, the practical lesson is primarily preventive: the quality and durability of the data carrier (material, placement, engraving versus sticker) determines how often this problem occurs. This is a choice made when creating the passport, not something that can be remedied afterwards on an individual tyre. If you prefer to have the QR code automatically matched with existing product data, you can set up that process via a link with your own ERP or inventory system, so that the data carrier is consistently generated based on the correct identification code per product.

For an end user who encounters a tire with an unreadable code on the street, in practice there is often no direct action required on their part: this is primarily a point of attention for the party responsible for placing the product on the market, not for the user.

The legal basis: articles 11, 16 and 17 of the ESPR

The fact that the product passport and the data carrier are two separate things follows from article 11 of Regulation (EU) 2024/1781, which describes the technical design and operation of the digital product passport — including the requirement that data must be accessible via a data carrier, without the data carrier itself being the only place where the data exists. Article 16 concerns labels and the requirements placed on them, and article 17 addresses counterfeit labels — relevant to the question of what may and may not happen with a data carrier, even if it is damaged, to prevent confusion or misleading information. Together, these articles form the basis for the distinction between "the product passport exists" and "the code on this specimen no longer works".

Those wishing to investigate this subject further for their own situation are best advised to start with the question of whether the product passport applies to their tires at all — this is a preliminary question that is covered on a separate page and which determines whether the steps below are already relevant or not yet.

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

The QR code must remain readable and functional throughout the entire lifespan of the tire

Article 11 of the ESPR (Regulation (EU) 2024/1781) is based on a data carrier that provides access to the product passport as long as the product is in use. This is not a one-time delivery obligation upon sale: the thinking behind the digital product passport is that a fleet manager, a garage or an inspector can scan the tire years later. For an importer or wholesaler with 10 to 100 employees, this mainly has implications for the choice of data carrier and the location where it is placed on the tire: a QR code that quickly becomes unreadable through normal use of the tire (wear, mounting, storage) does not meet the premise of article 11. How that code is exactly placed on the product and what requirements apply is detailed on the page about how the QR code ends up on your tires.

The product passport itself must also be findable without the physical code

A properly set up data carrier does not stand alone: the underlying link with the unique identification code of the product ensures that the product passport can also be found through another route, for example via the serial number, the batch or the model. For companies working with GS1 Digital Link, this is a built-in feature of the system — see the explanation about what GS1 Digital Link is and whether you need it. In practice, this means that a damaged code is not automatically a dead end if the identification of the tire is otherwise in order.

Counterfeit or misleading labels are something different from a damaged label

Articles 16 and 17 of the ESPR (Regulation (EU) 2024/1781) concern labels that are counterfeit or that give an incorrect impression of conformity. This is a different scenario from a QR code that has become unreadable due to wear, heat or impact. For a company, the distinction is relevant: worn code is a technical/practical problem, not a matter of misleading information. That said, a non-functioning code can in practice lead to questions from a customer or regulatory authority, simply because the information is not accessible at that moment.

The origin of the data must also be reconstructable without scanning

Because the product passport is compiled from data provided by the manufacturer or importer, it is important that this underlying data also exists independently of the QR code on the tire and remains accessible. This relates to the question of how long a product passport must remain available — see how long the product passport exists — and to the question what happens to that data if a company stops for any reason, explained on the page about what happens if your company stops. A damaged code on one tyre is therefore rarely a problem in itself; a missing or unfindable underlying dataset is.

Where things go wrong in practice

The code is affixed to a location that is not resistant to the use of the tyre. A sticker or engraving on the tread or sidewall that quickly wears away due to fitting, outdoor storage or contact with other tyres, becomes illegible within a short time — while the tyre itself will last for years.

There is no alternative route to the passport. If the QR code is the only access route and there is no link to a readable serial number or a unique identification code, a fleet manager with a damaged code is left empty-handed. This is precisely where proper organisation of the identification code makes the difference, as described on the page about giving each product a unique identification code.

Tyre size and identification code get mixed up. With large volumes and multiple sizes of the same model, it is common for the link between size and code to be recorded inconsistently, which means that a replacement code or a manual search can lead to confusion. The relationship between these two topics is explained on the page about the tyre size and the identification code.

A wholesaler replaces the code when resizing or repackaging, without checking the link. When a damaged code is covered over or replaced, the wrong code or an outdated code is sometimes applied, so that the scan leads to the passport of a different product or an older batch.

Reliance is placed on the supplier's memory rather than on documented links. Without an internal system that records which code belongs to which batch, a damaged code in stock cannot be recovered without consulting the manufacturer or importer again — whereas this can be prevented with a proper link to your own ERP system, see linking the product passport to your ERP or inventory system.

What you can record

An overview of where the QR code is affixed to the tyre and why that location was chosen (resistance to wear, fitting, storage).
The link between the tyre's unique identification code and the passport, independent of the physical QR code, so that a second access route exists.
A procedure for if a code in stock or with a customer becomes damaged: who contacts whom, and what information is needed to find the correct tyre again.
The registration of which batch or which model belongs to which code, usable for internal inspection and when answering questions from customers.
References to your own register setup, so that it is clear which passport is registered with which product — see the European register of digital product passports.
Agreements with the manufacturer or importer on how a replacement or additional data carrier is supplied for larger batches, especially relevant when the same data is used for multiple tyre sizes — see reusing data for other tyre sizes.

These records are not a legal obligation in themselves, but make it easier internally to respond quickly if a code no longer works in practice — without having to contact the manufacturer again each 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, reviewed by a human on 2026-09-05. Is something incorrect? Let us know — corrections are given priority.