in which language must the product passport data be for sales in other countries
No fixed language rule yet in the ESPR text itself
The ESPR stipulates in Article 10 that the digital product passport must contain a number of requirements regarding the form and accessibility of the data, but a detailed list of mandatory languages is not explicitly stated therein. What can be recognised as a principle is: data intended for a user or consumer in a specific market must in practice be comprehensible to that market. For a product passport that travels with a tyre sold in multiple EU countries, this concretely means that the language choice aligns with the country of sale and is not automatically fixed to a single language for the entire EU.
For whom this is relevant, and for whom it is not
This issue is particularly relevant for tyre importers and wholesalers who place the same batch of tyres on the market in multiple member states. They are the ones who determine which data goes into the passport and, connected with that, in which language or languages that data is offered. It is not, or far less, relevant for fleet managers who purchase and use tyres: they read the passport via the QR data carrier, but do not themselves determine anything about the language in which it is drawn up. It is also important to make a distinction from the content of the passport: which data must be included is a different question than in which language it appears. For the former, the separate page on which data will be in the product passport for tyres the starting point; this article addresses only the language aspect.
Also important: the language issue does not affect who may access which data. A passport can be available in multiple languages and still restrict certain data from certain parties. Those wishing to find out more will find the rules on that on the page about who may view which data from the product passport.
Date not yet fixed, as the delegated act is still lacking
There is no established entry date yet for the product category tyres within the digital product passport. The ESPR itself (Articles 5 to 7) describes the general framework for ecodesign, performance and information requirements, but the concrete, product-group-specific implementation — including practical questions such as language use — comes via a delegated act established per product group. For tyres, this act has not yet been published. According to the ESPR work plan for 2025-2030, it is expected around 2027; the actual entry date for the tyre passport thereafter is currently expected around 2029. As soon as the delegated act is published, this page will be updated with the date and, if included therein, the specific language rule.
Until then, there is no legal obligation for tyres to have a digital product passport, and therefore no legally established language requirement for that passport either. What does already exist now is the tyre label with data on rolling resistance, wet grip and noise; how this label relates to the future passport is described on the page about the tire label and the digital product passport.
What this means for those already dealing with multiple countries
Anyone who is already importing or trading tyres in multiple EU member states can reasonably assume that the passport will not work with a single fixed language for the entire EU. The first step is therefore to determine in which countries the relevant tyres are actually sold, as this determines which languages are relevant. The second step is to get the data itself in order, independent of the language — most of that data (rolling resistance, wet grip, noise, rubber composition) must be recorded anyway, and it is more efficient to have that structure ready before the language question becomes concrete. The third step is: wait for the delegated act before investing time or money in translation work, because the precise requirements — which fields, which languages, which exceptions — must come from that and not from the ESPR base text itself.
For those wondering whether filling in language variants also means that sensitive information is shared more broadly: that is not the case. Language and data accessibility are two separate matters. Those concerned about competitively sensitive information in the passport will find more on the page about sensitive business data in the digital product passport. And because a passport is not filled in once but must be kept current, it is also useful to look ahead at the page about how current the data in the digital product passport must remain — a language version that does not move along with an update is just as much a problem as a missing language version.
Where this follows from: Article 10 and Articles 5 to 7 of the ESPR
The requirements for the digital product passport itself, including the form and accessibility of data, are set out in Article 10 of the ESPR (Regulation (EU) 2024/1781). The underlying system of ecodesign, performance and information requirements, within which product group-specific choices such as language are made through delegated acts, is set out in Articles 5 to 7 of the same regulation. An explicit, tyre-specific language rule is not currently laid down anywhere, because the delegated act for tyres has not yet been published.
Those wishing to prepare for this now within their own organisation can best start by inventorying the countries of sale and putting the underlying data in order, so that when the delegated act is published, a quick switch can be made to the language requirements then in force.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Articles 5 to 7 (requirements concerning ecodesign, performance and information requirements)
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 in Article 10 that the digital product passport makes a set of data accessible via a data carrier, but the regulation contains no detailed language arrangement that sets out per product group in which language or languages the content must appear. This is to be filled in by the delegated act for tyres, which at the time of writing has not yet been published. What does follow from Articles 5 to 7 is that the information and performance requirements are designed so that a user throughout the Union can consult the data — and this points in practice to a language issue that becomes relevant for companies selling internationally once the act is in place.
Accessibility of data for the end-user
Article 10 requires that the passport discloses the data in a way that is comprehensible and usable for the parties involved. For a company of 10 to 100 employees that imports or resells tyres in multiple Member States, this currently means taking into account that a passport drawn up only in the language of the country of origin may not meet the expectation of comprehensibility in another sales country without further ado. However, a definitive, binding language list per product group is still missing; this follows from the delegated act.
Alignment with existing labelling and documentation obligations
Companies that already provide tyres with the tyre label know the principle that sales information is offered in the language of the destination market. How that practice relates to the new digital passport has not yet been worked out in detail, but it is to be expected that the two systems will align. Those who want to know now exactly which fields will make up the passport can find an overview at which data will be in the product passport for tyres.
Consistency between source language and translated version
A third point that also deserves practical attention is the monitoring of content when data exists in multiple languages side by side. Figures on rolling resistance, grip or noise must not deviate in a translated version from the original measurement data. How those values are obtained is described at the method by which the values for the passport are measured; translation changes nothing about the underlying measurement, only its presentation.
Where things go wrong in practice
An importer supplies the same tyre type to three Member States and leaves the passport unchanged in the source language, assuming that a QR code with digits and symbols is "international" enough. As soon as one of the sales countries applies a language requirement that has not been completed, a discrepancy arises between what is actually available and what is reasonably expected.
A wholesaler has an external party translate the descriptive text in the passport, but forgets that the translator has also retyped numerical fields — such as rolling resistance class or the share of recycled rubber — instead of linking them to the source. When the measured value is later updated, the translated version then lags behind the original.
A fleet manager receives passports in different languages from different suppliers for the same tyre type, without clarity on which version is the "leading" one in a dispute over the stated values. No one has established which language version is authoritative.
A manufacturer decides to anticipate in advance a language requirement that has not yet been determined and adds its own assumptions about which languages would be "mandatory", with the risk that this assumption will later not match the final delegated act.
A company that sells both summer and winter tyres treats the language issue as a one-off project per product line, while the specifications for seasonal tyres are maintained separately and thus also run through the translation cycle separately.
What you can record
- An overview of the Member States in which the tyre type is sold, linked to the language in which the passport is currently offered.
- An indication of which language version serves as the source when multiple translations of the same passport are in circulation.
- A procedure for updating translated fields whenever the underlying measured value changes, in line with what is described in how up to date the data in the digital product passport must be.
- A brief note on the origin of numerical data such as rolling noise, grip on wet road surface and rubber composition, so that a translator or external party does not inadvertently rewrite that data instead of adopting it — with reference to the recording of rolling noise in decibels, grip on wet road surfaces and rubber composition.
- A note on what agreements have been made with suppliers or importers regarding who provides the translation and on the basis of which source version.
- A reference to internal agreements within the company on who has access to the source language version versus the translated version, to be coordinated with what is described in who may view which data from the product passport.
Once the delegated act for tyres is published and contains a specific language arrangement, this overview will be supplemented here with the exact requirements.
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.