can I adjust data after the product passport has already been published

Yes, a passport can be updated after publication

A published product passport is not a snapshot that is fixed forever: the data within it can be adjusted after the passport is already live. This follows logically from the nature of the digital product passport as described by the ESPR (Regulation (EU) 2024/1781) — the passport is intended as an ongoing information source that remains accessible via a QR code or similar data carrier, not as a one-time document that is 'closed' after publication. Changes may be necessary because a manufacturer makes a production modification, because a measurement value is revised, or because there was simply an error in the first version.

Which data this applies to, and which it does not

This possibility to adjust applies to the content of the passport as displayed to the end user: technical specifications, performance values and the other data supplied by the manufacturer or importer. This is not about which data is precisely mandatory — that is described on the page about which data will be in the product passport for tyres — but about whether that data, once published, can still change.

Where this does not apply: the identity of the product itself. A product passport belongs to a specific product or a specific product group as placed on the market. A modification that amounts to a different product — for example a different rubber composition that materially changes the performance — is not a 'correction' of the same passport, but calls for its own passport for that modified product. Where precisely the line lies between an adjustment of existing data and a new product with a new passport is something the delegated act for tyres needs to provide more clarity on. Nor does the possibility to modify serve as a licence to allow structurally outdated or incorrect information to remain for a long time: how often and how quickly data must be current is described on the page about how up to date the data in the digital product passport must be.

When this becomes relevant, and what applies until then

For tyres, there is as yet no fixed date on which the digital product passport becomes mandatory. The ESPR itself already applies, but the specific obligations for a product category — including tyres — are worked out per product category in a delegated act. For tyres, that act is expected in 2027 according to the European Commission's work plan for 2025-2030. Until that delegated act is published, it is also not certain how the process of modifying after publication will work in practice: which data may be modified, by whom, and whether this involves a notification or new version. Once the act is published, that date and that specification will be added here.

Until then there is no legal obligation to already publish a passport, and therefore no practical situation in which a published passport already needs to be modified. What is already established is the principle from the ESPR itself: the passport in Article 9 and Article 10 is designed as a living database linked to a product via a data carrier, and not as a static file that is locked after publication.

What this means in practice

For those already thinking about how a passport is managed after publication, the sequence is roughly as follows. First, it is established which data has actually been modified — an adjustment in rolling resistance requires a different approach than a correction of an address. With a revised measurement value, it is relevant to look at how that value was determined; the page about the method by which values for the passport are measured describes that process, and that same method is relevant in determining whether a revised value is actually correct before it is published.

Subsequently, it is important to know who sees the modification and when. A wholesaler or fleet manager who previously consulted a passport will, upon subsequent consultation via the QR code, in principle see the current version — provided the passport is set up in such a way that the data carrier refers to the most recently updated data instead of to a fixed file. Who has access to which data, and whether that differs per party in the chain, is described on the page about who may view which data from the product passport.

Finally, it is practical to establish now who within your own organization is responsible for identifying modifications — a production change at the manufacturer, a revised test value, or a correction following an internal audit — and how that modification reaches the party that actually manages and publishes the passport.

Where this is based on: Articles 9 and 10 of the ESPR

Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as a link between a product and the data made available about it via a data carrier, established with a view to accessibility throughout the product's lifespan. Article 10 elaborates on the requirements for that passport. Both articles contain no provision that makes publication a one-time, immutable action; the precise rules for modification after publication will be further detailed per product category in the delegated act, which for tyres has not yet been published.

Anyone preparing a product passport now can arrange its management in such a way that modifications — a revised measured value, a corrected piece of data — are recorded and implemented as soon as the data changes, rather than waiting until the next publication round. Once the delegated act for tyres is known, this will be supplemented here with how that process looks in practice.

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 ESPR is based on a product passport that remains usable and reliable throughout the entire lifespan of the tyre. This does not mean that a passport is immutable after publication, but neither does it mean that data can be adjusted at will. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as a means that makes data about a product accessible throughout the entire life cycle, and Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the requirements that the passport and the underlying data must meet. From this framework follows a number of practical expectations.

The link between tyre and passport remains intact

The passport belongs to one specific tyre or tyre model, via the data carrier (the QR code) affixed to or with the tyre. Modifications to the underlying data must not break that link. For a company with 10 to 100 employees, this means that an adjustment of data must not be grounds to replace the QR code or place the passport under a different identification, unless there is a good reason for this that can be traced back to the product itself. Anyone in doubt about which data precisely are attached to that identification will find an overview on which data will be in the product passport for tyres.

Data must be correct at the moment someone consults them

A product passport is not filled in once and then left to its own devices. The thinking behind Article 10 of the ESPR (Regulation (EU) 2024/1781) is that a passport provides useful information throughout the product's lifespan. This implies that data that prove factually incorrect — for example a incorrectly recorded rolling resistance class — are corrected. How often and under what circumstances data must be kept current is described on how up to date the data in the digital product passport must be. For an importer or wholesaler, this is primarily an organizational matter: there must be someone who can process corrective notices from a manufacturer.

Modifications must be traceable

Where the passport is compiled and hosted by a third party — such as via tyrepas.eu — the source information remains with the manufacturer or importer. A change in the published passport should be traceable to a change in that source data, not to an adjustment made only in the passport itself. For companies of this size, this means that a request for modification ideally follows a fixed channel (for example, the same person or department that provided the original data), so there is no uncertainty about who requested which change and why.

Access to modified data remains appropriate for the target group

A change in the passport may also affect the question of who may see which information. If, for example, a value is adjusted that was previously only visible to a limited group, this does not change the access rules themselves. Those who want to know which parties may access which data will find that information on who may view which data from the product passport. This is relevant because a change is sometimes used as an opportunity to also reconsider the visibility of a data point — however, these are two separate questions.

Where things go wrong in practice

A passport is published based on data provided by the manufacturer, but a later retest of the tyre yields a different rolling resistance class. Without a fixed procedure, the old value remains in the passport, while the physical tyre meanwhile scores differently.

An importer changes the supplier of the rubber compound, which changes the proportion of recycled rubber. The change is implemented in the internal administration but is not communicated to the party hosting the passport, so the passport continues to display an outdated figure.

A company discovers an error in the passport — for example, a mix-up between two tyre models — and corrects it themselves without recording when and why the correction was made. In response to a later inquiry from a customer or supervisory authority, it is no longer possible to reconstruct exactly what was changed.

For seasonally specific variants of a tyre, a change in the summer tyre is accidentally also applied to the winter tyre because both are created under one product family. The differences that apply specifically to season-specific tyres are described on or different data in the passport should apply for winter tyres than for summer tyres, and these differences also affect the way in which changes must be implemented.

A wholesaler assumes that a change in the passport also brings about a change in the tyre label, or vice versa, whereas the passport and label are separate obligations with their own coherence, described on how the tyre label relates to the product passport. An adjustment in one is then incorrectly not implemented in the other, or conversely, even though that was not necessary.

What you can record

A fixed point of contact or process within the company for reporting changes to the party that compiles and hosts the passport.
An internal log of change requests: which data point, which old value, which new value, when requested and by whom.
The underlying measurement reports or test results that support a change, in particular for values such as rolling resistance, wet grip or rolling noise — see also how the rolling resistance class of a tyre is determined, how wet grip is determined and how the rolling noise of a tyre is recorded.
Documentation of the measurement method used for a modified value, so that it is clear whether the change is due to a different measurement method or to an actual product modification — the applicable methods are explained on according to which method the values for the passport are measured.
A template for change requests to the hosting party, containing at minimum: identification of the tyre, the modified data point, the reason for the change and the attachment with supporting evidence.
An overview of which data on rubber composition and recycled rubber are subject to modification, linked to the source of that data — see which data on rubber composition are recorded and how the share of recycled rubber is demonstrated.
An internal agreement on who assesses whether a modification also has consequences for the visibility of data towards certain customers or supervisory authorities.

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.