must I show the product passport at customs when I import tyres

Yes, customs may inspect the product passport upon import

Tyres entering the EU from a country outside the EU may be inspected by customs for the presence of a digital product passport once the obligation for tyres takes effect. The ESPR (Regulation (EU) 2024/1781) provides in Article 15 that customs authorities may carry out checks on products falling under this regulation, with the product passport being one of the matters on which attention may be focused. For those importing tyres from outside the EU, this means that the passport is not only something for the webshop or the sales floor, but also a matter with which the consignment itself may have to deal upon entry.

This concerns import from outside the EU, not internal EU traffic

This rule is relevant for companies importing tyres from a country outside the European Union — think of an importer who buys directly from a manufacturer in Asia. Tyres already circulating within the EU, from manufacturer to wholesaler to dealer to fleet manager, do not pass through customs again and thus do not fall under Article 15. For those internal links, different obligations apply, which have more to do with passing on and making the passport available than with a border inspection. Those wondering what role they play in this will find an overview at what obligations a distributor or dealer of tyres has. It is also good to know that a customs inspection in itself is not a judgment on whether the passport is substantively correct — that is a different question, with different parties responsible.

A second delimitation: this article concerns the presence and findability of the passport upon import, not who compiled the passport or who is responsible for it. That question arises before the moment of import and is described in who is responsible for the product passport of tyres.

The date is not yet fixed, but the obligation is already established

There is no fixed date yet on which tyres will actually be subject to the product passport obligation, and therefore no fixed date on which Article 15 will become practically relevant for tyres. The ESPR itself is a framework regulation: the concrete requirements per product category, including tyres, will come in a delegated act that still needs to be published. According to the European Commission's work plan for 2025-2030, that delegated act for tyres is expected in 2027. Until that act is published, there is no obligation for tyres to display a digital product passport upon import, and Article 15 has no practical significance for this product category. As soon as the delegated act is published and a date is fixed, it will be mentioned here.

What this means for those importing tyres

For the importer bringing tyres into the EU from a country outside the EU, the most practical first step is to establish whether he actually qualifies as an importer under the ESPR — this is not always the same as the common trade meaning of the word, and is set out in the question of whether someone is an importer or manufacturer under the ESPR. Those holding that role can then look at what Article 29 of the ESPR asks of importers: to check whether the product is accompanied by the required information and whether the manufacturer has fulfilled his obligations before the product is placed on the market. This is an obligation that applies before the border, not something that is sorted out at the customs desk.

For a manufacturer established outside the EU, there is also the question of who is the contact point within the EU and arranges the passport; Article 28 of the ESPR addresses the role of an authorised representative in this regard, and the practical side of it is described at the question of who arranges the product passport if the manufacturer is located outside the EU. An importer who wants to have this in order for his tyres in advance should check whether his products will fall under the product passport obligation — this is set out in whether the digital product passport applies to specific tyres — and to orient itself on what a product passport substantively is, via the explanation of what a digital product passport for tyres is. This creates a picture of what, once the obligation takes effect, must accompany a shipment — instead of this only becoming apparent at the border.

Where this is based on: Articles 15, 28 and 29 of the ESPR

Article 15 of the ESPR (Regulation (EU) 2024/1781) gives customs authorities the authority to carry out controls on products falling under this Regulation, with attention to the digital product passport as part of that control. Article 29 lays down what is required of importers before a product is placed on the market in the EU, including the verification of accompanying information. Article 28 regulates the role of an authorised representative where the manufacturer is established outside the EU. For tyres specifically, these provisions must still be supplemented by a delegated act; until one exists, the general framework provided by these Articles remains in place.

Anyone currently importing tyres would be well advised to start by determining what role he has under the ESPR — importer, manufacturer or otherwise — and from there consider which of the above obligations will apply to his situation once the delegated act for tyres is published.

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

Customs control on the basis of the digital product passport

Article 15 of the ESPR (Regulation (EU) 2024/1781) provides that customs authorities may carry out controls relating to the digital product passport when products are brought into the Union. Customs thus receives a role that goes beyond the traditional control of tariff, origin and value: the presence and accessibility of the passport are also part of the picture that can be examined. For a tyre importer of 10 to 100 employees, this means in practice that a shipment of tyres upon import is not only assessed on the standard customs documents, but that it can also be asked whether there is a functioning passport behind the QR code or other data carrier. Anyone who has already worked with What is a digital product passport for tyres? has the basis for this already in place.

Obligations of importers when placing products on the market in the Union

Article 29 of the ESPR describes the obligations of importers. From this it follows, among other things, that an importer ensures that the product is accompanied by the required information, including the digital product passport where applicable. For a company that sources tyres from a country outside the EU, this means that the passport is not something that only becomes relevant when selling to the end customer, but already plays a role at the moment of import. Anyone in doubt as to whether that role of importer actually applies to his own company will find further background on this in Am I an importer or manufacturer according to the ESPR?.

Authorised representative as intermediary

Article 28 of the ESPR covers the authorised representative: a party that can be designated by a manufacturer outside the EU to carry out (part of) the obligations on behalf of that manufacturer. For companies that import tyres from a manufacturer that does not itself have an establishment in the EU, this is a relevant figure, because the question 'who takes care of the passport' does not automatically fall to the importer himself. This arrangement is developed further in My manufacturer is located outside the European Union — who then arranges the product passport?.

Where things go wrong in practice

A common situation is that a company has the traditional customs documents (invoice, packing slip, certificate of origin) in order, but has not thought about the question of whether a digital product passport for the tyre types in question is already mandatory at the time of import. Because the obligation is filled in product group by product group via delegated acts, it is possible that part of the assortment already falls under the obligation and another part does not.

A second situation arises when the QR code or data carrier is present on the tyre or packaging, but the product passport itself is no longer accessible behind it — for example because hosting has been discontinued or the data have not been updated. During an inspection focused on the accessibility of the product passport, a non-functioning link is a different issue than a missing QR code, but the effect on the inspection can be comparable.

A third situation applies to companies that import tyres via an intermediary and assume that "the supplier will take care of that". Whoever formally acts as importer within the meaning of Article 29 bears the obligations attached to it themselves, regardless of what has been agreed with the supplier. This assumption also occurs with companies that have tyres manufactured under their own brand; what this means for their own role is described in I sell tyres under my own brand — what obligations do I incur?.

A fourth situation is that an authorised representative outside the EU has been designated, but at the level of the importing party in the EU it is not clearly established who actually carries out which part of the product passport process. During a customs inspection, it is then not immediately clear who can be held accountable for a missing or incomplete product passport.

A fifth situation is that a company assumes that the rules are applied identically throughout the EU, whereas implementation and inspection practice may differ per Member State. More information on this is provided in Do other rules apply to the product passport in other EU countries.

What you can record

An overview per tyre type of the moment when the obligation to provide a digital product passport comes into force, so that upon import it is clear which consignments already fall under the scheme and which do not.
A fixed procedure to check before each import whether the QR code or other data carrier functions and refers to a current product passport, instead of discovering this subsequently during an inspection.
A written agreement with the manufacturer or, where applicable, with the authorised representative on who compiles, hosts and keeps the product passport up to date — including what happens if the manufacturer itself has no party in the EU.
An internal responsible person or team who acts as a point of contact for customs enquiries about the product passport, so that this is not sorted out ad hoc at the moment when a consignment is held.
A file with supporting documents on what information has been added to the product passport and when, so that in the event of a dispute over the accuracy of data it is clear who has supplied which part; this is consistent with the question of who is liable if there is an error in the data of the product passport, see who is liable if there is an error in the product passport data.
A check as to whether your own role in the chain (manufacturer, importer, distributor) has been correctly established, as the obligations upon import differ by role; see also Who is responsible for the digital product passport for tyres?.

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.