How does the QR code for the product passport get onto my tyres?

The QR code itself goes on the tyre, packaging or documentation

The QR code for the digital product passport is placed on the tyre itself, on the packaging, or in the accompanying documentation — which of these three will apply to tyres is determined by the delegated act that the European Commission still has to publish for this product group. Article 11 of the ESPR (Regulation (EU) 2024/1781) already sets out the general requirements that the code must meet: it must be durable, remain readable throughout the product's lifetime, and be linked to a unique product identification with which the passport is retrieved. The manufacturer or importer is responsible for applying the code to the product. Tyrepas.eu compiles the passport from the data supplied by the manufacturer or importer, hosts that passport, and provides the QR code that points to that passport — the application of that code to the tyre remains the responsibility of the manufacturer or importer themselves.

This is about tyres, not the existing energy label

This QR code obligation stems from the ESPR, the general framework regulation for digital product passports. It is a separate process from the existing energy label for tyres, which is based on a separate regulation and has been mandatory for longer. Do not confuse the two: the energy label concerns rolling resistance, grip and noise, and is separate from the digital product passport. Article 16 of the ESPR allows the Commission to require labels per product group in addition to — or in combination with — the passport, and Article 17 covers protection against counterfeit labels. Whether and how these two articles will be concretely applied to tyres in future remains to be determined; this will also be set out in the delegated act for tyres. What is described here is therefore the general technical obligation regarding the data carrier under Article 11, not a statement about a specific label for tyres.

No fixed date yet, but a timeline

There is no established date yet for when the QR code becomes mandatory for tyres. The ESPR itself is a framework regulation; the specific obligations per product group — including when tyres must comply — only come with the delegated act for that product group. According to the Commission's work programme for 2025-2030, the delegated act for tyres is expected in 2027, after which there is typically a transitional period before the obligation actually takes effect. On this basis, the digital product passport for tyres is expected to come into force around 2029, but this is an estimate based on the work programme and not a fixed date. Once the delegated act is published, the exact date will be known and which technical details are specifically applied to tyres. Until then, there is no obligation for tyres to display a QR code for a digital product passport.

How this is handled in practice

Those preparing for this typically follow this sequence. First, an inventory is made of which product data are already available — technical specifications, material composition, origin — and which are still missing, as those data will form the content of the product passport. Next, monitoring begins for when the delegated act for tyres is published, because that act will establish the exact requirements: where the code is placed on the product, which data are mandatory in the product passport, and from which date this applies. Once those requirements are known, the product passport is compiled from the supplied data and the QR code is generated that refers to it — this is the moment when a platform such as tyrepas.eu provides the code. The physical application of that code to the tyre, packaging or documentation remains a task for the manufacturer or importer thereafter, in compliance with the durability and readability requirements of Article 11. Only in this sequence — data in order, regulation monitoring, product passport and code generation, code application — does this align with how the obligation is structured.

The basis: Articles 11, 16 and 17 of the ESPR

Article 11 of the ESPR (Regulation (EU) 2024/1781) describes the technical design and functioning of the digital product passport, including the requirements for the data carrier — in practice usually a QR code — and the link with a unique product identifier. Article 16 provides for the possibility of prescribing a label in addition to the product passport per product group, and Article 17 protects against counterfeiting of such labels. Which of these articles are concretely applied to tyres and with which technical details is laid down in the delegated act for this product group, which has not yet been published.

Those wishing to prepare now can start by putting their own product data in order and by monitoring the publication of the delegated act for tyres via the official EU sources. Tyrepas.eu will update this page as soon as new information becomes 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

The QR code is the physical link between the tyre and the digital passport. Article 11 of the ESPR (Regulation (EU) 2024/1781) sets out that the passport must be accessible via a data carrier, and that data carrier must be on the product itself, on the packaging or in the accompanying documentation. For tyres, the practical implementation is usually: apply the code to the tyre. What this means can be broken down into a few separate obligations.

The data carrier must be physically present on or with the product

The QR code is not something that exists only on an invoice or website — it must be linkable to the product itself. For tyres, applying it to the sidewall makes the most sense, because that is where the tyre size and other specifications are already shown. For a company with 10 to 100 employees, this means a choice in the production process or upon import: is the code applied to the tyre by the manufacturer already, or is it applied in the distribution centre later (sticker, label, embossing)? That is a technical and logistical decision, not a legal one, but its consequences — readability, durability, positioning — do relate to the question of whether the passport is actually findable as Article 11 intends.

The code must point to a unique, findable identity

A QR code on a tyre is only useful if it leads to the correct passport, and not to a passport of a different model or size. This requires a system in which each product — or each product group, depending on how the data is structured — receives its own unique identification. How you set that up, and what role a tyre size plays in it, is explained in how do I give each product a unique identification code? and in how does the tyre size relate to the unique identification code?. For a wholesaler carrying dozens of sizes of the same model, this is often the first place where things go wrong: a QR code that works technically, but points to the wrong variant.

The data carrier must follow a standardised format

Article 11 allows for technical standards that keep the data carrier readable and interoperable, even outside a single retail system or platform. In practice, this often involves a system such as GS1 Digital Link, which links a QR code to a structured identification code. Whether that is relevant for your own assortment and how it relates to your own item coding is described in what is GS1 Digital Link and do I need it for the product passport?. For an importer already working with GS1 barcodes for logistics, this is usually an extension of an existing system, not a new system alongside the old one.

The distinction between the QR code and a marking or label must remain recognisable

Articles 16 and 17 of the ESPR address markings and the prohibition of markings that imitate or could be confused with a genuine marking. This is relevant once a tyre, in addition to the QR code for the passport, is also provided with other labels — an energy label, a brand mark, a proprietary quality sticker. The QR code for the product passport is separate from those markings and must not be designed or positioned in such a way that a user gains the impression that it is a mark or certification. For companies that design or have stickers printed themselves, this is a point to note in the design: the QR code is a reference to information, not a quality seal.

Where things go wrong in practice

A few situations recur among companies introducing the QR code for the first time.

The sticker with the QR code is placed on a part of the tyre that wears or becomes soiled quickly during normal use, causing the code to become unreadable within a few months. What actually happens in practice and who should do something about it is described in what should I do if the QR code on the tyre becomes unreadable or damaged?.

One QR code is used for an entire range of tyre sizes of the same model, without prior consideration of whether those sizes are sufficiently identical to share the same data. See on this can I use the same data for multiple tyre sizes of the same model.

An importer has the QR code applied by the manufacturer, but has no visibility into what information is behind it or who manages that information once the product is sold in Europe under a different name or brand.

The QR code is placed next to an existing quality mark with similar design, which means it is not immediately clear that these are two different things — the passport on the one hand, a quality mark on the other.

The passport is linked to a system that is not prepared for linking with your own inventory management, so that changes in assortment do not automatically flow through to the content behind the QR code. See Can I link the product passport to my ERP or inventory system?.

What you can record

An overview of which product groups or tyre sizes fall under the digital product passport, including the question of whether that is already certain for your assortment — see does the digital product passport apply to my tyres?
A description of the chosen identification system: which code per product, and how that code is generated
Agreements with the supplier or manufacturer about who applies the QR code, at which stage of production or import
A procedure for damaged or unreadable codes, including who is responsible for it
An overview of what information is behind the QR code, and where that information is hosted and maintained
A brief explanation of the design of the QR code in relation to other labels or marks on the product, so that the distinction is also clearly documented internally

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.