does the product passport help with a recall of tyres and how does it work

The passport makes tyres traceable, and that is precisely what a recall is all about

The product passport helps with a recall because it links the tyre to fixed, retrievable data on manufacturer, model, composition and batch. A recall stands or falls on the question: which tyres are exactly affected, and how do you reach the batches that have them in their possession? The passport was not created for this purpose — the ESPR names the objective more broadly, namely to provide information on the sustainability and circularity of a product — but the data it contains (product identification, technical characteristics, manufacturer) are the same data needed to quickly and unambiguously identify a tyre during a recall. Whoever scans the QR code arrives at the same source data that an importer, wholesaler or supervisory authority would also consult.

For identification yes, for the handling of the recall itself no

The passport is an information source, not a recall system. It contains the data that make a tyre identifiable, as intended in Article 9 and Article 10 of the ESPR (Regulation (EU) 2024/1781), but it does not govern the procedure of a recall itself — who warns whom, within what timeframe, and via what channel. Those obligations rest with the manufacturer, as Article 27 of the ESPR describes, and with any sector-specific rules for product safety that are separate from the product passport. The passport makes it easier to determine whether a tyre belongs to an affected batch, but it does not replace the reporting obligation, the risk assessment or the communication towards customers that are part of a recall. Those looking for a ruling on how a supervisory authority assesses a recall in detail will not find it here — that is a different process than the passport itself.

The obligation to a passport is not yet fixed in date

There is no delegated act yet published that makes the digital product passport for tyres mandatory; the ESPR work plan 2025-2030 names the year 2027 as the expectation for this. Until that act is published, there is still no legal obligation for tyres to have a product passport, and therefore no legal link between that passport and a recall process. Once the delegated act is there, the precise date will be stated here. Until then, the question "when must this be ready" remains unanswered in exact terms — what is already established is the structure from Article 9, 10 and 13 of the ESPR: those articles describe what a passport must contain and how it is registered, regardless of the date when the obligation for tyres comes into force.

What this means for those already accounting for recall risk

For those already thinking about the relationship between passport and recall, the most practical sequence is: first look at what data are already fixed at the manufacturer or importer, then look at how that data remains findable and up to date, and only then think about the link with a possible recall process. A passport that is well set up makes three things easier in practice in a recall: identifying the exact product variant, tracing origin and batch, and quickly having technical specifications available without having to first request files from the manufacturer. That is a gain, regardless of the question whether and when the passport becomes legally mandatory for tyres.

Those who want to prepare already without waiting for the final rules can better first ask themselves what can already be done now while the rules are not yet final. For fleet managers there is an additional interest: a passport with clear identification data makes it easier in a recall to quickly see which tyres in the own fleet fall under a recall, and that directly affects what a fleet manager gets out of the tyre product passport. The choice of platform in which data is kept is also not neutral for recall purposes: a platform that keeps data searchable and up-to-date operates differently than a platform that only displays a static file, and that difference is relevant when choosing a platform for the product passport.

This follows from the articles on the passport and the obligations of manufacturers

The link between passport and recall is not explicitly stated in the ESPR — the regulation primarily describes an information obligation regarding sustainability and circularity. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as such, Article 10 describes the requirements to which the content must comply, and Article 13 describes the register in which passports can be found. Article 27 describes the obligations of manufacturers, and that is where corrective measures — including the type of action that fits a recall — have a basis. The precise relationship between these articles and a recall procedure for tyres specifically is not yet determined as long as the delegated act for tyres has not been published.

Anyone collecting data now for a future passport is well advised to build it in an orderly and complete manner — not only with the passport itself in mind, but also with a view to what a competent authority might request during an inspection of tyres, and with a backup copy of the data on hand in case the platform or connection is not immediately available.

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

Traceability of the product

The digital product passport links data to a specific product or a specific product group, via the data carrier affixed to the tyre. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes that the passport makes product information accessible via that data carrier, linked to a unique identification. For a company of 10 to 100 employees, this means in practice that a tyre is no longer merely an article number on an invoice, but a product whose origin, composition and batch information can be traced digitally. In a recall, that is the foundation: without unambiguous identification, it is not possible to determine which tyres are precisely subject to the action and which are not.

Keeping data current and correct

Article 10 of the ESPR sets requirements for the content and quality of data in the passport. This directly affects usability in a recall: data that is incorrect or outdated makes it more difficult to quickly determine which tyres have a problem. For an importer or wholesaler, this means that filling in the passport once upon first sale is not sufficient. Changes that are relevant — for example an adjustment in a production batch or a new insight about a specific batch — must be traceable in the data underlying the passport.

Obligations of the manufacturer in case of a problem with the product

Article 27 of the ESPR describes the obligations of manufacturers, including taking corrective measures when a product does not meet the requirements or poses a risk. The product passport plays a role here as an information source: it makes visible which product characteristics, materials and documentation belong to a particular batch. For a company acting as an importer and processing the manufacturer's data, this means that its own records must align with what is shown in the passport — otherwise a discrepancy arises between what the passport displays and what actually lies on the shelves or in the vehicle fleet.

Findability via the register

Article 13 of the ESPR provides for a register of digital product passports. That register is intended to make passports and the associated data searchable, also for authorities that supervise compliance. In a recall, this register can play a role because it offers a way to determine which passports belong to which products, regardless of the platform on which the data are hosted. For a company with multiple locations, this is one of the points where the question arises whether multiple locations of my company can manage the same product passport — because a recall often affects not just one location, but the entire chain in which a batch has been distributed.

Where things go wrong in practice

A first situation that frequently occurs: the QR code on the tyre refers to a passport, but the underlying data have been modified by the manufacturer without this change being reflected in the version that the importer displays. In a recall, this creates uncertainty about which information is authoritative.

A second situation: a company has never linked batch or lot data to its own inventory management, so the passport exists, but cannot be traced back to which tyres are still physically on site. This is particularly relevant when inventory that is already in stock when the rules take effect — older batches are not always documented in the same way as new deliveries.

A third situation: a fleet manager discovers via the tyre itself or through a notification that a recall is taking place, but has no direct way to check whether the own fleet contains tyres from the relevant batch. Without a link between the passport and the own record of mounted tyres, this becomes a manual search process.

A fourth situation: a platform on which the passport is hosted ceases operations or changes ownership, and the QR code no longer points to usable data at the moment they are needed. This is one of the reasons why selecting a platform for the product passport requires more attention than price alone.

A fifth situation: it is assumed that the passport itself handles or reports the recall. The passport is an information carrier, not a reporting system — the obligations regarding corrective measures under Article 27 of the ESPR rest with the manufacturer or importer, not with the passport as such.

What you can record

A link between batch or lot numbers and the unique identification in the passport, so that a specific batch can be quickly located.
An internal arrangement about who is responsible for updating data when the manufacturer communicates a change.
An overview of which inventory already has a passport and which does not yet, relevant to determining whether unsold tyre inventory may still be destroyed or must first be processed into the documentation.
A copy of the data contained in the passport kept by oneself, separate from the platform — this relates to the question of whether keeping one's own copy of the data from the product passport is advisable, precisely for the moment when quick action must be taken.
A documented procedure for what happens if a supervisor asks about the origin of a batch; this relates to what is actually asked in practice during an inspection on tyres.
A template for internal communication to fleet managers or customers when a batch may be affected, so that a process does not have to be set up anew each time.

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.