What is the registry of digital product passports and what do I need to enter in it?
The register contains core identification data, not the full passport
The European register of digital product passports is a central database established and managed by the European Commission. For each product for which a passport is mandatory, it contains a unique registration number, together with a limited set of core data: including the identity of the manufacturer or importer and the product category. The full passport itself is not stored in this register — it remains hosted where it belongs, for example with a party such as tyrepas.eu that retains the data for ten years and provides the QR data carrier. The register primarily ensures that market surveillance, customs and the public can verify via that unique number whether a passport exists and where to find it, without the Commission itself needing to manage all passport content.
Who this applies to and what it does not
The registration obligation applies to the economic operator responsible for placing a product on the market — usually the manufacturer or importer — and only from the moment a delegated act under the ESPR makes a digital product passport mandatory for that product group. Consumers and points of sale do not register anything themselves; they may only consult the passport via the QR code. Furthermore, the registration obligation does not automatically apply to all products: as long as no delegated act has been adopted for a product group, there is no registration requirement in the European register for that group. Moreover, what the register contains is limited to identification data and a core set of data — not the full technical content of the passport, which is hosted separately.
The date is not yet fixed; the work plan points towards 2027
No delegated act has yet been published for tyres that makes a digital product passport mandatory, and therefore there is also no point at which registration in the European register for this product group is relevant. The Commission's work plan for the ESPR, covering the period 2025-2030, mentions a delegated act for tyres expected in 2027. This is a planning date from a work plan, not an established obligation. As long as that act is not in place, there is no obligation for tyre importers and wholesalers to register anything or supply anything to the European register. As soon as the act is published and an applicable date is fixed, this will be stated here.
What registration means in practice
Once a delegated act for tyres becomes applicable, registration typically follows a fixed sequence. First, the responsible party — manufacturer or importer — requests the necessary unique identification numbers before the product is placed on the market, as required by article 13 of the ESPR. Those identification numbers then appear in the data carrier, the QR code on or attached to the tyre, as is already provided by tyrepas.eu. The actual passport data remains hosted with the responsible service, accessible for ten years, while the register contains only the location and core identification. Via the web portal described in article 14 of the ESPR, supervisory authorities, customs and the public can then verify whether a registration exists and consult the associated passport. For the tyre sector, this means that registration becomes an additional step on top of compiling and hosting the passport — not a replacement for it, but a supplementary link that regulates discoverability and verifiability.
Where this is laid down: article 13 and article 14 of the ESPR
This explanation follows directly from Regulation (EU) 2024/1781, the ESPR. Article 13 governs the register of digital product passports: the Commission establishes and manages the register, and assigns unique identification numbers to it that must be registered prior to placing a product on the market. Article 14 governs the web portal through which the data from that register is made accessible, including for supervisory authorities and the public. Both articles concern the registration and access structure itself; the obligation to actually have a passport and registration for a specific product group such as tyres follows only from the delegated act that the Commission adopts for that product group.
Anyone working with tyres now does not need to register anything at this time and can monitor the Commission's work programme for the publication of the delegated act for tyres. Once that act is in place and an implementation date is fixed, it will be added to this platform, together with the practical steps for registration and linking the identification numbers to the QR data carrier.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 13 (register of digital product passports)
- Regulation (EU) 2024/1781 (ESPR), Article 14 (web portal for data in 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
Article 13 of the ESPR (Regulation (EU) 2024/1781) introduces a central European register in which certain data from each digital product passport is stored. Article 14 adds a web portal to this, which gives supervisory authorities and other competent authorities access to that data. For a tyre importer or wholesaler, this does not replace the product passport itself, but supplements it: the passport remains with the product, the register is the place where (part of) the underlying data is also centrally stored.
Register data that belongs to the passport
What exactly must be registered and by whom is elaborated per product group. For tyres, this means that the data contained in the passport — the same data as behind the QR code on the product — must also be findable via the register. From a practical standpoint, this is not a separate data entry task if the passport is properly set up: registration in the European register builds on the same underlying dataset. A company with 10 to 100 employees that already supplies data in a structured manner for the passport effectively provides the foundation for what ends up in the register.
Ensure that the unique identification code is consistent
The register works with identification codes to link passports to products. This makes it all the more important that each product receives a unique identification code that is applied consistently — even when the same data is used for multiple variants. For tyres, this plays a direct role: the same design can come on the market in dozens of sizes, and the question of how the tyre size relates to the identification code is precisely the kind of issue to which a register is sensitive. An error or ambiguity in the identification code has repercussions in the register, not only in the passport.
Access for competent authorities via the web portal
Article 14 governs the web portal through which competent authorities can access data from the register. For a company, this mainly means that the data supplied is also verifiable through a channel other than its own QR code. This does not change the substance of the obligation, but it does change visibility: an incomplete or inaccurate passport is not only visible to anyone scanning the tyre, but also to anyone consulting the register.
Ensure that data remains correct when systems change
Many companies with 10 to 100 employees do not enter their product data manually, but via an ERP or inventory system. The question of whether the product passport can be linked to an own system is therefore also relevant for the register: data supplied via a link must remain consistent with what has already been registered when changes are made to the source system. A manual correction in one system that does not carry through to the other results in a mismatch between passport and register.
Where things go wrong in practice
A number of situations recur in practice among companies that deal with the register.
First: companies that treat the passport and the register as two separate processes, resulting in data being entered twice — once for the QR code, once for the register — and no longer matching after an update.
Second: unclear which identification code is leading when an importer carries the same tyres under its own item code, while the manufacturer uses a different code. Without coordination, a register results with two "truths" for the same product.
Third: reusing data for multiple tyre sizes of the same model without checking whether the same data for other tyre sizes actually applies. What is correct for one size is not automatically so for another — and a registration error arising in this way is difficult to trace afterwards.
Fourth: companies that expect the register to be an obligation that is "ticked off" at one point in time, whereas it is rather about a data stream that must remain current as long as the product passport exists.
Fifth: no internal arrangement about who is responsible for registration when the product passport is managed by a third party — such as a platform that compiles and hosts the product passport. Unclear division of roles leads to delays when a correction is needed.
What you can record
Without the delegated act for tyres already being published, there are a number of matters that can already be determined internally now, so that registration later is a matter of connecting rather than starting over:
- An overview of which identification code is used per tyre model and per size, and who within the company assigns and manages that code.
- An arrangement about who is responsible for keeping current the data on which the register is based — the own organisation, the manufacturer, or the platform that hosts the product passport.
- A documented procedure for when data in the source system change, so that it is clear how and when that is reflected in the product passport and any registration.
- Documentation of the source of data per product group, so that when a competent authority makes an inquiry, it can quickly be traced where a piece of data comes from.
- An overview of which products fall under which product passport when multiple product passports for one product come together, so that registration does not lead to confusion between product passports.
These points can be organised now, even without the exact registration obligation for tyres being determined. Once the delegated act for tyres has been published and the date of application is known, this article will be supplemented with the concrete deadline and the precise content of the registration obligation.
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, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections are given priority.