What does the digital product passport mean if I import tyres from outside the EU?
The importer receives its own obligation under the ESPR
Whoever imports tyres from outside the EU receives a separate role as an importer under the ESPR, with its own obligations regarding the digital product passport — regardless of what the manufacturer outside the EU has already done. Regulation (EU) 2024/1781 (ESPR) sets out obligations for importers in Article 29, and in Article 15 it gives customs the authority to check the digital product passport upon entry of goods. For a tyre that is manufactured in a factory outside the EU and subsequently imported by a European party, this means there are two contact points: the manufacturer who originally supplies the data, and the importer who becomes responsible the moment the product enters the EU market.
Who this applies to, and who it does not
This obligation specifically affects the party acting as an importer: the one bringing tyres from outside the EU onto the EU market. This is a different position from that of a distributor who buys tyres from a party already established in the EU — in that case there is no import from outside the EU, and different links in the chain apply. Nor does it concern the manufacturer itself, if that manufacturer is located outside the EU: the manufacturer remains responsible for compiling the underlying data, but the obligations of Article 29 are directed at the importer as a separate market participant. Fleet managers and end users who purchase tyres via a European supplier are in practice mainly dealing with the party that has already arranged the passport, and do not themselves face this importer obligation.
Date not yet confirmed
There is no fixed date yet on which these obligations for tyres will come into effect. The ESPR is the framework regulation; the actual product requirements for tyres — including the digital product passport — are being developed per product category in a delegated act. According to the European Commission's work plan for the period 2025-2030, that delegated act for tyres is expected in 2027. Once that act is published, it will become clear from which date tyres fall under the passport regime and what specific data and deadlines are involved. Until then, the general provisions of the ESPR apply as a framework, without a fixed entry date for the tyre passport yet being set. Once the delegated act is in place, this page will be updated with the date.
What this means for those importing tyres
For an importer sourcing tyres from outside the EU, the first step is to clarify which manufacturer or supplier the underlying product data come from, and whether that party is able to supply this data in a timely and complete manner. Once the delegated act for tyres comes into force, the second step is to check whether the passport is in place at the moment the goods enter the EU — that is precisely the moment when the customs check under Article 15 becomes relevant. A third point to keep track of is the source of the data: the importer is responsible for the passport being present, but is usually dependent on the manufacturer outside the EU for its content. It is therefore practical to establish this arrangement early in the purchasing relationship, rather than waiting until the first shipment after the obligation comes into effect. A platform such as tyrepas.eu can be a link here: it compiles the passport based on the data supplied by the manufacturer or importer, hosts the passport for the required period, and provides the QR data carrier that is attached to the physical product or packaging. This means that the substantive responsibility for the accuracy of the data lies with the party that supplies it, but the technical side of availability and recognisability upon entry is addressed.
The legal basis: Article 15 and 29 ESPR
These obligations follow directly from the ESPR itself. Article 29 of Regulation (EU) 2024/1781 sets out obligations for importers that specifically concern the digital product passport, in addition to the obligations already placed on manufacturers. Article 15 of the same regulation gives customs the authority to check for the presence of the digital product passport when goods enter the EU market. Together, these two articles form the basis for why imports from outside the EU entail a separate responsibility, distinct from the obligations already placed on the manufacturer. The precise product requirements for tyres follow from a delegated act that builds on these framework provisions.
What to do
If you already import tyres from outside the EU, it is best to check with the manufacturer or supplier which product data are available and whether that party is prepared to provide a digital product passport as soon as that becomes mandatory for tyres. For the current status of the delegated act and the exact implementation date, the official text on EUR-Lex is the appropriate source, and this page will be updated as soon as that act is published.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 15 (customs checks concerning the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 29 (obligations of importers)
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
A company that sources tyres from outside the EU and places them on the European market is considered an importer for those tyres. This is a separate role with its own obligations, separate from the question of whether the product passport is materially correct — that responsibility lies with the manufacturer, but the importer has their own role at the border. Article 29 of the ESPR (Regulation (EU) 2024/1781) describes what is expected of an importer.
Verify that the product passport exists before the tyres are imported
For an importer, this means that the passport and the accompanying QR data carrier must be present before the tyres enter the EU market, not only when a customer requests it. For a company with 10 to 100 employees, this is usually a matter of organisation: someone in procurement or quality who checks with every new order or new tyre line whether the passport has already been supplied by the manufacturer outside the EU, before the order is confirmed. Which data is precisely needed for this is described on the page on which data you request from your tyre supplier.
Verify that the data in the passport are correct and complete
An importer is not expected to verify the technical content themselves as a manufacturer would, but they must reasonably verify that the passport is present, readable and complete. This is more than opening the passport and seeing that there is something in it — it involves checking that the fields that belong to this type of tyre are filled in. How this is set up in practice is described on the page on how you verify the data from your supplier for accuracy.
State name and contact details
An importer is expected to state their name, registered trade name or brand and contact details, so that there is a point of contact within the EU. For a company of this size, this is often already part of existing labelling or documentation, but it is a separate, explicit obligation that stands apart from the usual company details on the packaging or invoice.
Retention of data and cooperation with inspections
Article 15 of the ESPR concerns customs checks on the digital product passport. For an importer, this means that customs at the border can request to see the passport — via the QR data carrier — before the tyres enter free circulation. Practically speaking, this requires a procedure in which the data carrier is already present with the shipment or the accompanying documents, not something that needs to be arranged afterwards. A company that works with multiple shipments and suppliers would be well advised to embed this as a fixed part of the customs clearance process, just as is already done with other import documents.
Intervene when a tyre is not in order
When an importer has reason to believe that a tyre model does not meet the requirements — for example because the passport is missing or clearly incomplete — the importer is expected to respond to this, including by not placing those tyres on the market. For an importer, this is a different position than merely "passing on what the manufacturer supplies": an independent assessment is required.
Where things go wrong in practice
A few situations recur regularly in the practice of tyre importing.
An importer orders a new tyre line from a factory in Asia and only discovers when the container arrives that no QR data carrier has been applied to the tyres or packaging. The shipment is already at the border, and adjustments cannot be made in time.
A manufacturer outside the EU supplies data, but in a proprietary format that does not align with what the passport requires — for example, missing fields on material composition. The importer assumed that "a passport" was sufficient, without verifying whether the content was complete.
A company works with multiple factories for the same tyre model, for example to spread production capacity, and receives separate, uncoordinated data from each factory. When merging into one passport per model, contradictions arise that no one removes in time.
An importer assumes that the manufacturer outside the EU remains responsible for any errors in the passport, and takes no action itself if there is doubt about the accuracy of the data. Its own role in identifying and possibly withholding a defective shipment is thereby overlooked.
A company sets up passport inspection as a one-time action for the first shipment of a new tyre model, but does not repeat that inspection for subsequent shipments — while a manufacturer may have changed specifications in the meantime without updating the passport.
What you can record
For an importer of tyres from outside the EU, it is useful to document a number of matters in writing or by procedure, so that its own obligations can be demonstrated to have been fulfilled:
- A standing agreement with each manufacturer outside the EU on when and how the product passport and QR data carrier will be provided, for example documented according to the approach on the page on agreements in your purchase contract.
- An internal checklist that is run through with each new order: is the passport present, is the QR data carrier readable, are the expected fields in it.
- A documented procedure for what to do if the data is missing or incomplete, including who within the company decides whether or not to proceed with the import. If problems with a supplier persist, it is useful to know what steps are possible, as described on the page on what you can do if your supplier does not deliver the data.
- An overview of your own company data as it must be stated on each shipment, so that this does not need to be determined anew per shipment.
- A file for each tyre model documenting which factory or factories the tyres come from, relevant for companies that work with data from multiple factories and must combine these in one passport.
This documentation is not an end in itself, but makes it possible to quickly demonstrate during customs inspection or in response to a customer inquiry that your own role as importer has been fulfilled, even if the source data comes from a manufacturer outside the EU who is not directly under European supervision.
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.