I have tyres manufactured in multiple factories how do I combine that in one product passport

What you must do concretely

What is expected of you

Producing tyres from multiple factories under one own brand or specification is in the tyre industry more the rule than the exception. If you do that, you face a practical question with the digital product passport: is that one passport per tyre type, or must each factory location deliver something separately? The ESPR reasons from the product and the actors in the supply chain, not from the production location as such.

Each manufacturing address provides its own data

Article 38 of the ESPR describes the requirements for actors in the supply chain: each party that contributes to the product provides the information that falls within its role. For a company of 10 to 100 employees having tyres made at multiple factories, this means that each factory in principle provides its own production data, materials and test results — even if the end result for the customer is one and the same tyre name or specification. Practically, it is important to know per factory which data it registers itself and which must come from you as the contracting party. What data must I request from my tyre supplier? provides an overview for this that can be repeated per manufacturing location.

The passport must be correct in content, per product model

Article 10 describes the requirements for the digital product passport itself: it must contain the correct information and that information must be current and verifiable. If two factories produce the same tyre model with minor differences in rubber composition or test values, that is content-relevant. One passport text that applies to "the model" while the actual composition differs per factory does not meet what Article 10 requires. For a company with multiple production locations, this means it must be established whether a tyre model from factory A is truly identical to the same model from factory B, or whether it is actually two slightly different products that each deserve their own passport.

When importing from third countries there is an additional role

Anyone importing tyres made outside the EU — often the case with multiple factories in, for example, Southeast Asia — also has to deal with Article 29, which describes the obligations of importers, and with Article 15 on customs controls with regard to the digital product passport. For an importer taking delivery from three factories at the same time, it is relevant that the passport must already be present and verifiable at the time of import, per shipment and per product model. What this concretely means for companies that source from outside the EU is worked out further on What does the digital product passport mean if I import tyres from outside the EU?

Where things go wrong in practice

A number of situations come up repeatedly in practice at companies that source from multiple factories.

One passport for a "product line" that in reality consists of variants. The marketing name of a tyre type suggests one product, but the factories each use their own rubber compound or tread variant. The passport then follows the marketing name instead of the actual technical composition.

Factory supplies data in a different format or language than the other factories. With two or more production locations, often in different countries, technical files arrive in different languages, units or document structures. This makes merging into one correct passport error-prone.

Unclear who is responsible if a factory stops a particular production line. If one of the factories ceases production of a tyre model, the question remains who manages the data for that model and keeps it current for the remaining term of the passport.

Data from a new factory are not compared with the existing data. When expanding to an additional factory for the same model, it is sometimes assumed that the existing passport text can be taken over without amendment, without checking whether the technical data from the new location actually match.

Import data and factory data do not align. On importing tyres from multiple factories outside the EU, customs inspection reveals that the passport does not match the actual origin of the specific shipment, because internal administration does not consistently distinguish between the factories.

What you can record

• An overview per factory of which data they supply themselves and which you supplement, so it is clear where a gap in the data comes from. See What data must I request from my tyre supplier? as a starting point per factory location.
• Contractual agreements with each factory on the supply of passport data, including language, format and time of delivery. How do I document the provision of digital product passport data in my purchasing contract? describes how this is incorporated into a purchase contract.
• A fixed procedure to check whether data from different factories operating under the same tyre name actually match in substance before they are merged into one passport. See How do I check whether my supplier's data is correct?
• An internal list per tyre model with the associated factory location(s), so that when changing suppliers or phasing out a factory, it is clear which passport belongs to it.
• A documented procedure for what happens if a factory stops production of a model: who then manages the data, and how this is determined in relation to the party who is to be able to demonstrate the passport for ten years.
• On import from outside the EU: a link between shipment data and factory origin, so that customs inspections clearly show which passport belongs to which shipment.