must I keep track of repairs or maintenance of a tyre in the product passport

What you must do concretely

What is expected of you

The ESPR regulates in Article 9 and Article 10 what a digital product passport must be able to do and which data belong in it. Repair and maintenance data of an individual tyre, arising after sale, are a separate category in it: the passport that is compiled via tyrepas.eu is built from the data that the manufacturer or importer supplies when placing the product on the market. What happens after that with a specific tyre at an individual user is a different matter than what is recorded when the passport is created.

The passport contains product information, not necessarily a usage log.

Article 9 of the ESPR describes the digital product passport as a set of data about a product that is accessible via a data carrier (in this case a QR code). Article 10 sets out which categories of data play a role in it: product characteristics, composition, performance, and the like. For a tyre, this concerns matters such as rolling resistance, grip and rolling noise — the data that also appear on the tyre digital product passport end up. A log of repairs or maintenance carried out on one specific tyre is a different type of data from the product characteristics described in the regulation. For a company with 10 to 100 employees, this means in practice that the passport created via tyrepas.eu is based on the data of the manufacturer or importer at the time the product is placed on the market, and does not automatically grow with what happens to an individual tyre afterwards.

The delegated act for tyres must still show what is laid down product-specifically

Articles 1 and 2 of the ESPR make clear that the regulation is a framework law: the concrete, product-specific requirements are worked out per product group in delegated acts. For tyres, that act does not yet exist. Whether it will include an obligation to record repair or maintenance data (such as tread depth measurements, repairs following a puncture, or tyres that have been renewed through retread) cannot be determined at this time from the text that is available. For a fleet manager or wholesaler, this means that plans for the longer term (2027-2029) must take this uncertainty into account, without already investing in systems that may not be necessary.

Distinction between what is required to be recorded and what a company wants to keep itself

Apart from what the ESPR will ultimately prescribe for tyres, many fleet managers and tyre specialists have long been keeping their own maintenance records: tyre change data, tread measurements, repairs. This is a business process that is separate from the legally mandatory digital product passport. A company can choose to link such a record to the QR code of the passport, but that is its own decision and not an obligation that follows from Article 9 or Article 10. This also touches on the question how up to date the data in the digital product passport must beproduct characteristics supplied by the manufacturer are different from events that occur during the lifespan of a tyre.

Where things go wrong in practice

Maintenance log is confused with the product passport. A fleet manager assumes that the product passport automatically keeps a history of tyre changes and repairs, and does not set up its own internal record. If there is a need for this later — for example in a warranty matter — that information is not available, because the passport does not fulfil that role.

Anticipating an obligation that does not yet exist. A tyre importer builds, on its own initiative, an extensive system to record repair data per tyre and link it to the QR code, on the assumption that this will become mandatory. If the delegated act ultimately sets different requirements, or no requirements at all for repair data, that investment will have proven partly superfluous.

Unclear about who maintains the data after sale. When tyres are sold to a garage business, it becomes unclear who is responsible for updating data after installation: the importer who had the passport created, or the garage that installs the tyre and later repairs it. Without an agreement, this remains unaddressed.

Confusion between product characteristics and usage data during audits. During an inspection or customer enquiry, 'the data in the passport' is requested, and confusion arises between the product characteristics supplied by the manufacturer (as discussed in the rolling resistance class or wet grip) and the maintenance history that a user keeps themselves. These are two different things that do not automatically sit in the same system.

Repair data is treated as commercially sensitive without verification. A garage business refuses to share repair data with the fleet park owner as a precaution, without checking whether that data actually falls under an exemption. This touches on the broader question whether business-sensitive data on tyres must be made public, which is separate from the question of whether repair data should or should not be part of the statutory passport.

What you can record

• An internal record of maintenance and repairs per tyre or per vehicle, separate from the digital product passport, including date, type of repair and responsible party.
• An agreement with garages or tyre service points about who maintains which data after purchase and installation.
• An overview of which data is already mandatory in the passport (based on manufacturer data), so that this is not confused with own records.
• A note of the date on which the delegated act for tyres is published, to see whether it contains any requirements about repair or maintenance data.
• A reference to the organisation's own procedures for tread measurement and tyre change, linked to fleet management, so that this data remains internally traceable without being presented as part of the statutory passport.