How long must a product passport remain available?
The retention period is not yet fixed; it will be determined per product group
How long a digital product passport must remain available is not specified in the EUMR itself with a concrete number of years. Article 10 of the EUMR (Regulation (EU) 2024/1781) does determine that the passport must remain accessible, but leaves the precise duration to the delegated act that is drawn up separately for each product group. For tyres, this delegated act does not yet exist. Once it is published, the retention period for tyres will be established and will be stated here. Until then, there is clarity on the underlying principle — the passport should exist as long as it is relevant for use, maintenance, repair and end-of-life of the product — but not yet on the number of years to which this is tied.
Who this applies to, and what it does not cover
This subject concerns the availability of the passport itself: how long the data must remain accessible via the QR data carrier. It does not concern the warranty period of the tyre, any statutory retention obligation for invoices or other administrative documents, or the validity period of a CE marking or type approval — these are separate obligations with their own rules. Nor is the question of who hosts the passport (the manufacturer, the importer, or a service provider such as tyrepas.eu) the same as how long the passport must exist; Article 10 sets requirements for the passport as a whole, within which hosting and retention period are two separate components.
It is also important to note that this concerns a minimum period that the regulations will subsequently prescribe. Nothing prevents any party from keeping the passport available longer than strictly required — for example, because a fleet manager wishes to be able to retrieve the data even after the tyres are decommissioned, for their own file-keeping.
No fixed date yet, but a clear sequence
The date on which the retention period for tyres is established depends on when the delegated act for this product group is published. According to the EUMR Work Plan 2025–2030, this delegated act for tyres is expected in 2027 — this is a planning date from the work plan, not a statutory deadline, and may therefore shift. Until the delegated act is in place, no concrete obligation regarding the retention period of the passport applies to tyres. What is already fixed: the EUMR as a framework regulation is in force and describes in Article 10 the principle that a passport must remain available; the detailed rules per product group — including the exact number of years — are still to follow.
What this means now for preparation
Anyone already working with digital product passports for tyres can take a few things into account, in the order in which they usually arise. First: assume a longer period than the tyre's warranty period alone, because Article 10 is explicitly aimed at the entire life cycle of the product, not the sales phase alone. Next: when choosing a hosting solution, allow for the possibility that the final term may turn out to be longer than expected, so that a new solution does not have to be sought midway. Then: keep an eye on the publication of the delegated act for tyres, because only then can it be assessed whether an existing solution meets the prescribed term. And lastly: ensure that the source data — the information supplied by the manufacturer or importer — is itself retained for at least as long as the passport must exist, because a passport is nothing more than a representation of that underlying data.
The legal basis: Article 10 and Article 13 of the EUMR
Article 10 of the ESPR describes the requirements for the digital product passport, including the requirement that it remains accessible; the precise period will be determined per product category in the corresponding delegated act. Article 13 governs the digital product passport register, in which passports — or at least their location — are kept centrally; that register is part of how long-term availability is ensured, even after a manufacturer or importer is no longer active themselves. For the full text and current status, the official EUR-Lex publication of Regulation (EU) 2024/1781 is the source to fall back on.
If you already import or trade tyres, it is best to get your own data recording in order so that it is ready as soon as the delegated act for tyres is published, and in the meantime keep an eye on this page for the exact deadline once it becomes known.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 13 (register of digital product passports)
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
Availability during the lifetime of the tyre
Article 10 of the ESPR (Regulation (EU) 2024/1781) stipulates that the digital product passport must remain available for as long as it is relevant to the product to which it relates. For a tyre, this concretely means: the QR code on the product must, even after years of use, continue to point to a passport that is actually accessible. For a company with 10 to 100 employees, this above all means a choice for hosting that does not follow the whims of the moment: no platform that will be phased out after a few years, no subscription that depends on the lifespan of a single supplier. The exact period that the delegated act will prescribe for tyres is not yet fixed — that will be confirmed as soon as that act is published.
The passport remains linkable to the correct identification code
The obligation to maintain the passport is not separate from the question of how that passport is found. Each passport is tied to a unique identification code, and that code must, throughout the entire period of availability, continue to point to the correct, up-to-date passport. Anyone wondering how each product receives a unique identification codeencounters here the other side of the same coin: the code itself does not change, but the system behind it must indeed remain operational for ten years or longer without that linkage being lost.
Registration in the European register also continues to exist
Article 13 of the ESPR governs the register of digital product passports. A passport that "lives" with the manufacturer or importer is also registered in that register — and that registration must move in step with the lifespan of the passport itself. What exactly must be included in that register and how it relates to your own hosting is addressed in the explanation of the register of digital product passports. For a company, this means that availability is not only a technical matter (is the server running?) but also an administrative one: does the registration still match reality?
Availability does not automatically outlive the business
A tyre that lasts ten years often outlives the company that imported it. Bankruptcies, takeovers, mergers — the obligation to maintain availability takes no account of these, and that is precisely why a company must itself make provisions for it. What practically happens if an undertaking ceases is detailed in the article on what happens to the product passport if a company ceases operations; anyone thinking about this now avoids the question only arising at the moment when there is no one left to answer it.
Where things go wrong in practice
An importer opts for a cheap hosting solution that is terminated by the provider after three years — the QR codes on the already sold tyres then point to nothing.
A company switches to a new ERP system and forgets to migrate the existing passports; the link between inventory system and passport becomes loose, even though it had been assumed that linkage to your own ERP or inventory system would automatically carry that transition through.
A wholesaler takes over a product line from another party, including still-available inventory, but no one arranges who becomes responsible for the continuity of the associated passports.
In a merger, the original legal entity that had created the passports disappears, without it having been established beforehand who takes over the hosting obligation.
A company assumes that a passport "must exist forever" and spends unnecessary money on it, even though the exact period for tyres has not even been established in a delegated act.
What you can record
- A hosting agreement with a term that aligns with the expected lifespan of the product — not with the term of the current IT contract.
- An internal instruction as to who is responsible for maintaining the passport, even in the event of personnel changes or reorganisations.
- A procedure for what happens in the event of business termination, takeover or merger, so that the continuity of the product passport does not depend on chance.
- An overview of which product passports belong to which product lines, including the question of whether the same data are reused for other tyre sizes of the same model — because that choice has implications for how many product passports must be maintained.
- An agreement with the hosting party about what happens when the contract ends: whether the data will be transferred, and to whom.
- A log of changes to the product passport, so that at any time it can be demonstrated which version was available at which moment.
Those who now establish this type of agreements do not need to wait until the delegated act for tyres is published in order to already have a structure in place that can adapt to that obligation as soon as the exact period is known.
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.