can I use the same data for multiple tyre sizes of the same model
Shared content is possible, but the identification code remains separate per variant
No, not simply in the way the question is usually meant. The product information that is substantively identical across an entire range of tyre sizes — think of material composition, test methods, general product description — can in practice come from the same source and does not need to be drawn up anew for each size. But the product passport itself, as a whole with its own unique identification code, is linked to a specific variant of a product. Using one and the same passport entry for multiple tyre sizes of the same model, without distinguishing the identification code, is not what the regulation envisages.
For whom this applies and where the distinction lies
This matter is relevant for any party that draws up passports for a product line with variants: the same tyre model, but in different sizes, load indices or speed classes. The question then is always: is this one product with minor differences, or are these different products that each need their own passport? The answer does not lie in the model or the brand name, but in the question of whether the tyre size (and the properties associated with it, such as load and speed) constitutes a separate variant. More on that link between size and identity is described on the page on how tyre size relates to the unique identification codeWhat does not fall under this: the reuse of text, test results or sustainability claims as such. That content may be shared and reused to the extent that it actually applies to multiple variants — that is not a problem. The problem only arises if that reused content is published under one and the same identification code for products that should actually be distinguished as separate variants.
When this takes effect and what is already established
A firm entry date for the tyre sector is not yet fixed. The ESPR itself, Regulation (EU) 2024/1781, is already in force, but the delegated act that sets the concrete requirements for tyres — including the precise functioning of the identification code for this product — has not yet been published. The European Commission's work plan for 2025-2030 mentions 2027 as the expected time for that delegated act. Once that text is available, the date will be added here. Until then, the principle in Article 12 of the ESPR is already established: each product receives a unique identification code, and that code is the key by which a passport is linked to a specific product. That starting point will not change; only the tyre-specific implementation (which characteristics make a separate variant) has yet to be published.
How to approach this in practice
For anyone already preparing passports for a range of tyre sizes, it is advisable to first determine which data actually differ per size — think of load index, speed code, dimensions, weight — and which data are generic for the entire model, such as rubber composition or general test methodology. The generic content can be drawn up once and reused in each passport; that saves work. Subsequently, each size, as a separate variant, receives its own unique identification code and thus its own passport instance, even if the underlying text largely matches. Practically, this means that the system in which the passports are drawn up ideally has a structure in which shared fields are managed at product line level, and variable fields at size level. Anyone wishing to use their own ERP or inventory system for this will find more on that link on the page on linking the product passport to an ERP or inventory system. This is followed by the question of how the identification code is practically assigned and processed in the QR data carrier; that process is described on the page on how each product receives a unique identification code. If you are uncertain whether a particular size variant qualifies as a separate product or as a minor variation within the same model, it is advisable to settle that question early in the process — before the QR codes are printed and applied to the tyres, not after.
The basis: Article 11 and Article 12 of the ESPR
Article 12 of Regulation (EU) 2024/1781 requires a unique identification code per product, which links the digital product passport to that specific product. Article 11 describes the technical design of the digital product passport itself and the manner in which data must be accessible via that code. From the combination of both articles it follows that the identification code cannot be separated from the underlying product: the code exists precisely to distinguish one model from other models. The precise definition of what counts as "the same product" and what counts as "different model" for tyres specifically must still emerge from the delegated act.
Businesses preparing digital product passports now would be well advised to begin by separating shared product information and size-specific data in their own system, so that this structure is ready once the tyre-specific requirements are final.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique product identification code)
- Regulation (EU) 2024/1781 (ESPR), Article 11 (technical design and operation of the digital product passport)
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
Each product receives its own unique identification code
Article 12 of the ESPR (Regulation (EU) 2024/1781) requires that a product subject to a digital product passport receives a unique identification code. That code identifies the product, and with it the associated digital product passport, unambiguously. For a tyre importer or wholesaler this means that a 205/55 R16 and a 225/45 R17 of the same line — even with identical tread pattern, rubber compound and manufacturing process — are two different products within the meaning of the regulation. Each size therefore receives its own code, and as a rule its own digital product passport. How that code is constructed precisely and linked to the tyre size is described on the page on how tyre size relates to the unique identification code.
For a business with 10 to 100 employees, the practical impact is primarily organisational: whoever compiles the digital product passports (as tyrepas.eu does on the basis of manufacturer or importer data) must provide a separate identification code and a separate passport registration per size variant, even if the underlying technical data largely overlap.
The digital product passport must reflect the characteristics of that specific product
Article 11 of the ESPR governs the technical design and operation of the digital product passport, and requires among other things that the information in the digital product passport be reliable, consistent and up-to-date for the product to which it relates. A tyre type can vary by size in weight, load index, speed category, rolling resistance and sometimes in exact composition. Where those values differ by size — and that is often the case with tyres — then generic reuse of data across multiple sizes is not tenable, even if the basic documentation covers the same model.
For a business this means that the question "can I use the same data" splits into two parts: data that are identical per size (brand, model, general composition) can be repeated, but data that differ per size (technical performance values, weight, code) must be specific to that size.
The link between digital product passport and physical product remains one-to-one
Even when the content of multiple digital product passports largely matches, the link between a digital product passport and the physical product is one that runs via the data carrier on the product itself. How that link is applied to the tyre is explained on the page on how the QR code for the product passport gets on the tyre. That means a shared data source may exist in the background, but each size requires its own visible, scannable reference that leads to the correct digital product passport — not to the digital product passport of another size from the same line.
Where things go wrong in practice
One digital product passport for the entire product line. An importer creates one product passport for "tyre type X" and references all sizes to the same QR code, because the rubber compound and tread are identical. As soon as a check or customer scans the code of the 17 inch version and sees data from the 16 inch version (different weight, different load index), a discrepancy arises between the passport and the product.
Copying technical values without recalculation. When compiling product passports for a new size, the source data from an existing size is copied and only the size designation is adjusted, while values such as rolling resistance class or load index are actually different for that size. This often happens under time pressure, when multiple sizes must be delivered simultaneously.
Confusion between "same model" and "same product". Some companies reason from the commercial model number (as it appears on the packaging or in the catalogue) and incorrectly assume that one model number also means one identification code and one product passport. The ESPR reasons from the product as it is placed on the market, and that is a different product per size.
Insufficient coordination between ERP system and product passport data. When the inventory or ERP system treats tyre sizes as variants of one item, that structure is sometimes adopted wholesale in the product passport data, without a separate check being performed for each variant or the technical data actually being identical. With the linking the product passport to an ERP or inventory system this is a point of attention: the link must take the product passport identification code as leading, not the internal article number.
Register not updated per size. When new sizes of an existing tyre type are placed on the market, a registration in the European register is not always made separately for each size. What must be included in it per product is described on the page about the register of digital product passports.
What you can record
- An overview per tyre type of which technical characteristics (weight, load index, speed class, rolling resistance, noise class) are the same per size variant and which differ, as a basis for whether or not to reuse data.
- A fixed procedure for assigning the unique identification code per size, so that no two sizes ever share the same code.
- A template in which, for each size variant, it is documented which data have been taken from an existing size and which have been newly obtained from the manufacturer or importer.
- A control point before publication, in which it is checked whether the QR code on each size refers to the corresponding, specific product passport — see also the approach in a damaged or unreadable QR code for what happens if that link cannot be restored afterwards.
- A fixed agreement with the supplier or manufacturer on how changes in technical specifications per size are communicated, so that shared basic data do not become outdated without this being noticed.
- An internal check whether the model number used in the catalogue corresponds to the correct series of unique identification codes, to prevent confusion between commercial model and legal product.
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.