How often must I update the data in the digital product passport?
No fixed update frequency, but an accuracy requirement
The ESPR does not prescribe a fixed interval — there is no requirement anywhere that a product passport must be updated "once a year" or "after every change". What is required, however, is that the passport contains the information applicable to the specific product and that such information must be accurate and complete. How this works in practice — which data remain static and which must be updated as soon as something changes — will be worked out per product category in the delegated act established for that category. For tyres, that act does not yet exist. The ESPR itself (Article 9 and Article 10) sets the framework within which this will be filled in, but the specific rules — who manages the data, what happens when there is a change, and whether that happens automatically or manually — come from the product-specific delegated act, not from the basic regulation.
For whom and for which data this applies
This topic primarily concerns the party responsible for drawing up and keeping the passport current — usually the manufacturer or importer placing the product on the market. There are two types of data that must be distinguished. Some information is fixed and never changes after production: for example, the production year, the materials used, or the test results with which the product was placed on the market. That data does not need to be "updated"; it is fixed at the moment of recording. Other information may change during the lifetime of the product — think of repair history, change of ownership, or additional compliance data that become available later. For that second category, how often and by whom the passport is updated is indeed relevant. What this topic does not cover: which data specifically must appear in the tyre passport, and who is allowed to update which part — that is determined by the delegated act for tyres yet to be published, not by the ESPR itself.
When this will apply
There is no fixed date yet for when an obligation to update tyre passports will come into force. The ESPR determines in Article 10 that a delegated act must be established per product category specifying which market participant is responsible for keeping the passport current and how that process will work. For tyres, that act is scheduled for 2027 according to the ESPR Work Programme 2025-2030; the date on which the obligations will actually take effect is therefore not yet fixed. Until the moment that act is published and becomes applicable, there is no legal obligation for tyres to maintain a digital product passport, let alone to update it. What is fixed, however, is the framework from the ESPR itself: once a product passport is mandatory, it must contain the applicable information and it must be clear who is responsible for it. Once the text of the delegated act for tyres is known, this page will be supplemented with what it specifically lays down about updating.
What this means in practice
For those already dealing with tire passports or preparing for them, it is practical to distinguish between data that is recorded once and data that may change during the tire's lifetime. Start by mapping which data comes from your own administration or from the manufacturer and which data only emerge later, such as usage data in fleet management or repair information at the distributor. Next, it is useful to determine which party provides those later data and whether a process is needed to pass them on to whoever manages the passport. For platforms hosting the passport — such as tyrepas — this means there must be a way to submit and have data processed, even after the passport's initial publication. Finally, it is sensible to follow publication of the delegated act for tires: it will state which role each party has in keeping it up to date, and only then will it become clear whether a specific frequency or trigger for updates is prescribed.
Where this follows from: Article 9 and Article 10 ESPR
Article 9 of the ESPR (Regulation (EU) 2024/1781) lays down the general requirement that a digital product passport contains information applicable to the product and that such information is consistent with what is actually known about the product. Article 10 of the same regulation determines that the delegated act must specify for each product group which market operator is responsible for entering and keeping data up to date in the passport, and how that process is arranged. These two articles together form the framework: the basic regulation states that the passport must be up to date and who may be responsible for that, but leaves the concrete implementation — including any deadlines or triggers for updates — to product-specific legislation.
What to do now
For those now orienting themselves on the tire passport, it is useful to order your own data flows in advance — which data are static and which may change during a tire's lifetime — and to monitor publication of the delegated act for tires, so that the role of each party in keeping the passport up to date becomes clear as soon as that text is available.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 9 (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
The ESPR regulates in Article 9 and Article 10 what a digital product passport must be able to do and what requirements apply to the data it contains. A literal frequency — "every quarter", "annually" — is not specified there. What is specified is a number of principles that together determine how current the data must remain in practice. For a tyre that has been produced and sold once, this amounts to a few concrete obligations.
The data must be correct at the moment the passport is created
Article 10 of the ESPR sets requirements for the accuracy and completeness of the information in the passport. For a tyre, this means above all that the data recorded during production or import must be correct at that moment. For a company with 10 to 100 employees, this means that the intake process — the place where measurement data from the manufacturer is received and processed into passport data — is where quality is determined. What those values are precisely and according to which method they were established is described on the page about which data will be included in the product passport for tyres and on according to which method must I measure the values for the passport.
Static product properties do not change and therefore do not need to be reviewed periodically
A tyre has a fixed rolling resistance class, a fixed grip score and a fixed rolling noise as measured according to the test method applied. These properties do not change over time; they are inherent to the specific product model as tested and placed on the market. In practice, this means that for this category of data there is no automatic "expiration point" — the data remains correct as long as the product model remains unchanged. How these values are established precisely is described at how do I determine the rolling resistance class of a tyre, how is grip on wet road surface established and how do I record the rolling noise of a tyre.
If the product changes, the passport changes
Where it does concern currency is the moment when a product model changes: a different rubber composition, an adjusted tread pattern, a new share of recycled material. Article 9 starts from the idea that the passport represents a specific product or product model — if that product changes, a new or updated passport is generally required. For a company with an ongoing range, this means that changes to the product line deserve a fixed control point: every revision of a tyre model is a moment to check whether the passport still matches the physical product. What changes precisely in a modified composition is explained on the pages about which data on rubber composition must I record and how do I indicate the share of recycled rubber.
The passport must remain accessible during the required period
Article 10 sets requirements for the availability of the passport, not only its content. This means that a company must not only ensure that the data was correct at publication, but also that the infrastructure that provides access to the passport — the QR code, the underlying data — remains available. For an importer or wholesaler that does not have its own hosting capacity, this is often the reason to outsource this task.
Where things go wrong in practice
A few situations come up regularly with companies working with tyre passports.
A manufacturer adjusts the rubber composition of a tyre model to meet a new environmental requirement, but the type designation and model name remain unchanged. The passport of the old composition then remains actively linked to a product that is no longer the same.
An importer receives from the manufacturer a correction to previously supplied measurement data — for example a revised rolling noise value after a retest — but this correction is not applied to passports that have already been published with earlier shipments.
A wholesale distributor takes over a product line from another supplier and assumes that the existing certificate from the previous responsible party will automatically continue to function, without verifying who is now responsible for keeping that data up to date.
A company changes the commercial name of a tyre line for the Benelux market, without reflecting this change in the certificate data linked to the underlying product model — causing the customer and certificate to no longer match one-to-one.
A seasonal line — winter tyres alongside the regular summer assortment — is published under a single certificate template, while the specifications applicable to winter tyres differ from those for summer tyres. More information on this is available on the page must I enter different data in the passport for winter tyres than for summer tyres.
In all five cases, it is not a matter of a missed periodic update, but of a change in the product or in the responsibility that has not been translated into the certificate.
What you can record
A few agreements and documents make it easier to determine whether, and when, a certificate should be updated:
- An internal change protocol that sets out when a product change (composition, tread, recycled material) leads to a new or amended certificate.
- An overview of which party in the chain is responsible for providing updated measurement data, and at what point this party does so.
- A log of certificate publications per product model, so that it can subsequently be traced which data belongs to which version of the product.
- Agreements with the manufacturer or supplier regarding the communication of corrections to previously supplied measurement values.
- Documentation of the process in case data must be adjusted after publication — see the page on can I adjust data after the product passport has already been published for the way this process is arranged.
These records do not exempt a company from the question of whether specific data are correct and up to date, but they make the internal process traceable — something that both the organisation itself and a supervisory authority ask for in practice.
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.