According to which method must I measure the values for the digital product passport?

What you must do concretely

What is expected of you

The ESPR stipulates in Article 39 that values stated in a product passport must be measured or calculated according to a method established for that purpose — not at the discretion of the manufacturer or importer. That article provides the framework; the concrete measurement method per product requirement comes from the delegated act that still must be established for tyres on the basis of Articles 5 to 7 of the ESPR. For the tyre passport, this subject therefore remains open, but the design of the regulation already indicates where companies can take account of this.

Measuring according to an established method, not at discretion

Article 39 ESPR stipulates that the values in the passport must derive from reliable, accurate and reproducible measurements or calculations. For a company with 10 to 100 employees, this means that an in-house test facility, an estimate based on comparable products, or a method that internally seems "logical" does not simply suffice once the delegated act is in place. The method must align with what is prescribed in it — often a reference to a harmonised standard or a test protocol. Until that act is published, there is no established method for tyres to fall back on.

Reproducibility as a benchmark

A key concept in Article 39 is that another party, using the same method, must be able to arrive at a comparable result. This directly affects issues such as how the rolling resistance class of a tyre is determined, how grip on wet road surfaces is established and how rolling noise in decibels is recorded. For these properties, test methods already exist under the tyre labelling regulation; the question that remains open is whether and how the ESPR delegated act aligns with these or prescribes its own method. A company that now collects data is well advised to record the test method and conditions used, so that a later alignment with the definitive method is more straightforward.

Distinction between measuring and calculating

Not every value in a passport comes from a physical test. Article 39 allows room for calculation methods, for example for properties that cannot practically be measured per production batch. For a property such as the proportion of recycled rubber a calculation based on recipe and procurement data is more obvious than a laboratory test. Here too, what calculation method is acceptable for the tyre passport is not yet established, but the distinction between "measured" and "calculated" is already relevant to make now in your own records.

Aligning with what is already mandated via the tyre label

For tyres, there is already a mandatory test method for rolling resistance, wet grip and noise, imposed via the tyre labelling regulation. The ESPR delegated act may align with this, but that is a choice the legislator still has to make. Companies that wish to understand how these two regulations relate to each other will find more background in how the tyre label relates to the product passport. Those who already have label data are possibly building a basis that can also be used for the passport — without this being presented as certain.

Where things go wrong in practice

An importer takes over test results from the manufacturer without recording the standard or test protocol according to which they were obtained. Once the delegated act prescribes a specific method, it is no longer possible to determine whether the original measurement complied with it.

A wholesaler uses test data for a product line that is several years old, while the test facility or standard has been adjusted in the meantime. The value in the passport therefore differs from what an up-to-date measurement would produce.

A company mixes measurement results and manufacturer data without distinction: some values come from a laboratory test, others are estimates from the supplier. In the passport they are placed side by side, without it being clear which method applies to which value.

A fleet manager who imports tires themselves assumes that a CE conformity test for a different regulation is also valid as substantiation for the product passport, even though the scope of that test does not match what Article 39 requires.

A manufacturer changes the rubber composition of a tire type, but the previously measured values for rolling resistance or noise are not re-determined — causing the passport to display a value that no longer matches the current product. This also raises the question how often the data in the product passport must be updated.

What you can record

• For each data point in the passport: which test method or calculation method was used, and by whom (own laboratory, external test facility, manufacturer statement).
• The version or publication date of the standard or test protocol applied during the measurement.
• The test conditions (date, test setup, equipment used) for measurements already carried out under the tire labelling regulation.
• An overview of which values were measured and which were calculated, with the underlying assumptions in calculations — relevant for example with recording data on rubber composition.
• Correspondence with the manufacturer or importer concerning the origin of supplied values, so that if a method is later modified, it is clear which data need to be reassessed.
• A change log that records when a value was established and based on which version of a test method, so that this aligns with the question whether data can be modified after the passport has already been published.

Once the delegated act for tires is published, the concrete method will appear here. Until then, it is primarily important to know what you have already measured or calculated, and on the basis of which method — so that compliance with the final rules later does not become a puzzle.