can multiple locations of my company manage the same product passport

Multiple locations can work with one product passport

Yes, multiple locations of the same company can be involved in the same digital product passport, because the passport is linked to a product or product model and not to a location. The passport belongs to what is placed on the market, with the data of the manufacturer or importer responsible for it. Whether that is supplied from one head office or from different branches that each handle their own part of the import or distribution does not change anything about the passport itself: it remains one digital file per product, accessible via one QR code on the tyre.

For whom this is relevant and where the boundary lies

This is particularly relevant for companies operating multiple locations, branches or subsidiaries where no single central office handles the clearance or sale of all tyre batches. Think of a wholesaler with regional warehouses, or an importer with several offices that each have their own suppliers abroad. The question then is not whether the passport can be "split" per location — it cannot, because the passport remains linked to the product, not to the place where it is handled — but rather who within the company supplies the data and keeps it up to date.

The distinction that does matter is between different batches or models. Every tyre batch or model that is separately placed on the market receives its own passport. If two locations sell the same tyre line that comes from the same manufacturer and the same batch, there is generally one passport that can be consulted from multiple places. If the locations sell different batches or models instead, those are also different passports, regardless of whether they operate under the same company name. This is not about whether a customer or fleet manager may view the passport — they can in any case, see what a fleet manager gets out of the tyre product passport — but about who is internally responsible for maintaining it.

What is already established and what is not

A firm date for the obligation to have a digital product passport for tyres is not yet set. The ESPR (Regulation (EU) 2024/1781) is the framework regulation and it is already in force, but the concrete obligation for tyres will come via a delegated act that is drawn up specifically for this product group. According to the European Commission's work plan for 2025-2030, the delegated act for tyres is expected in 2027. Until that act is published and enters into force, there is no legal obligation to have a passport, let alone to determine how it is organised within a company with multiple locations.

What is already established is the structure within which it will work: Article 9 of the ESPR (Regulation (EU) 2024/1781) establishes that the digital product passport will come into being, Article 10 describes the requirements it must meet, and Article 11 addresses the technical operation, including access to the data. These provisions leave no room for a passport per location; they are written from the perspective of the product, with one central set of data that is accessed via the QR code.

How this is approached in practice

Companies operating multiple locations should start by determining which location actually imports or places on the market which tyre batches, as this determines who is seen as a manufacturer or importer within the meaning of Article 27 of the ESPR (Regulation (EU) 2024/1781) and thus who is responsible for the accuracy of the data. Next, it is necessary to agree internally on who will supply the data when drawing up the passport, and who will keep it up to date if something changes — for example in the event of a recall, where the passport can play a role as described in how the passport works in a recall. After that, it is practical to determine whether all locations need access to the same passport, or whether some locations only sell what another location has already registered. When choosing a platform, this is one of the points to clarify in advance, because not every system is designed for multiple users within a single company structure — this is covered under things to pay attention to when choosing a platform. Finally, it is advisable to establish who within the company keeps their own copy of the supplied data, independently of the platform on which the passport is hosted.

The legal basis: articles 9, 10, 11 and 27 of the ESPR

That the passport is linked to the product and not to a location follows from article 9 of the ESPR (Regulation (EU) 2024/1781), which describes the digital product passport as part of the product itself. Article 10 specifies which data must be included and what requirements that data must meet, without making any distinction based on the internal organization of the party that supplies it. Article 11 governs the technical operation, including how the data is made accessible via the data carrier — this is technology that by definition can be accessed from multiple locations. And article 27 sets out the obligations of manufacturers, which forms the basis for the question of who within a company with multiple locations acts as the responsible party.

Those who want to prepare now how this will be organized within their own company structure can review the steps in order under how the product passport for tyres is tackled step by step, or check what can already be done now while the final rules are still being determined via what can already be done now.

What this is based on

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 with multiple locations — a head office with procurement and a number of branches that order or sell independently — often asks themselves who exactly is "the responsible party" for the product passport. The ESPR does not reason from locations, but from roles: manufacturer, importer, distributor. This distinction determines how multiple locations can work with one passport.

The obligation rests with the market participant, not with the location

Article 27 of the ESPR (Regulation (EU) 2024/1781) places the obligations for the product passport with the manufacturer, and upon import with the importer. This is a legal entity, not a building or a branch. For a company of 10 to 100 employees with, for example, three locations, this means in practice that the passport is linked to the product and to the entity that places it on the market — not to the location that opens the box. Locations that fall under the same legal person work in practice on the same passport because the obligation is already centralized there. Locations that import independently (their own VAT number, their own customs declarations) are, in the eyes of the regulation, a separate importer, with their own obligation.

The passport follows the product, not the location

Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as a collection of data linked to a specific product or product model. For a tyre, this means: the passport belongs to that tyre (or that model), not to the place where it is stored. A location that receives a batch of tyres from the head office thus works with a passport that already exists and is already completed — there is nothing new to "manage" at location level, only to consult and pass on. This is relevant for fleet managers and wholesalers with multiple locations: what is the value of the tyre passport to me as a fleet manager? addresses what can be done with that data on the user side.

Access to the data carrier is not synonymous with management

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the accessibility of the passport: the data must be retrievable via the data carrier, in practice the QR code on or near the product. Multiple locations can scan that QR code and view the data without there being a case of "multiple managers". Management — the modification, supplementation or correction of the underlying data — is different from access. A branch that scans a QR code to check whether a delivery is correct does not manage anything; it consults.

Technical setup determines who may modify

Article 11 of the ESPR (Regulation (EU) 2024/1781) concerns the technical design and operation of the passport, including who may register or modify data. This article allows for a technical setup in which one central party manages the data and multiple locations are linked to it as a user or as a pass-through point. For the practice of a company with multiple locations, this is the point where the switch is really flipped: not the organisational structure determines what is possible, but the way in which the platform sets up roles and rights. When choosing a system, that is a question that should be asked beforehand — see what should I pay attention to when choosing a platform for the product passport.

Where things go wrong in practice

A number of situations come up regularly in companies with multiple locations:

Two locations supplement the same product group independently of each other. Branch A registers a tyre delivery under its own model name, branch B does it slightly differently. Two passports are created for what in reality is one product model.
A location thinks it imports independently, but falls under the legal entity of the head office. The obligation under Article 27 is then fulfilled at the wrong level: it is thought that the location "must arrange its own passport", while the legal entity already has one obligation.
Login credentials for the platform circulate informally between locations. Everyone can modify, no one knows anymore who made which change. If a supervisory authority asks a question, it is then no longer possible to reconstruct who entered what — whereas that is precisely one of the things that what does a supervisory authority ask for during a tyre inspection can point out.
During a merger or acquisition of a location, the legal entity changes, but the passport does not change with it. The link between product and market participant no longer matches the actual business structure.
A central department compiles the passport, but the location that sells has no access to show it to a customer. As a result, a simple customer question at the counter cannot be answered, whereas can my customers check the product passport data before they buy describes that this inspection should in fact be straightforward.

What you can record

For a company with multiple locations, it is worthwhile to have a few things on paper in advance, separate from what the platform technically allows:

An overview of which legal entity has which role (manufacturer, importer, distributor) per location, so that the obligation under Article 27 lands in the right place.
An internal agreement on who within the organisation is authorised to create or modify passport data, and who only has access to view.
A list of product models with the location that registered a model first, to prevent duplicate registrations.
A fixed procedure for what happens during acquisition, merger or closure of a location, so that the link between product and market participant stays up to date.
A separate copy of the entered data, apart from the platform — see must I keep a copy myself of the data contained in the product passport for the considerations involved.

Anyone already working with multiple locations and wants to think ahead without waiting for the final regulations will find a starting point in what can I already do while the rules are not yet final.

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, reviewed by a human on 2026-09-05. Is something incorrect? Let us know — corrections are given priority.