must I enter different data in the passport for winter tyres than for summer tyres

What you must do concretely

What is expected of you

The question of whether a winter tyre requires different data than a summer tyre is fundamentally a question about which product group requirements apply, and those requirements become concrete only once the delegated act for tyres is published. The ESPR itself (Regulation (EU) 2024/1781) establishes in Articles 5 to 7 how those requirements come into being: for each product group, eco-design requirements and information requirements are to be set, and a tyre is not simply "a tyre" — winter tyres, summer tyres and all-season tyres can be treated as separate categories within that framework. Until that implementation is published, there is no authoritative source stating that the passport of a winter tyre must show different fields than that of a summer tyre. What is already established, however, is the structure within which that choice will eventually be made.

Following the product group classification once it is established

In practical terms, for a company of 10 to 100 employees, this means that the classification by tyre type is not something to determine for yourself right now. The delegated act will indicate whether winter tyres receive their own set of information requirements — think of performance in low temperatures — or whether they fall under the same basic set as other tyre types, with possibly a few additional characteristics. An importer who now procures winter tyres and summer tyres would be well advised to follow the classification of their supplier or manufacturer once it becomes known, rather than setting up a passport structure on the basis of their own assumptions. What is in any case already relevant in this regard: which data will be included in the product passport for tyres describes the basic set that is envisaged for tyres, regardless of season type.

Article 10 as framework for the technical content

Article 10 of the ESPR describes the requirements to which the digital product passport as a whole must comply: the passport must be linked to a specific product or product group, and the content must align with the requirements established for that group. For a company that has passports compiled, this means that the technical core of the passport — rolling resistance, noise, grip — only differs between tyre types if the delegated act itself indicates that difference. As long as that act has not been published, it is not possible to anticipate a separate dataset for winter tyres. The methodology behind core values as the rolling resistance class of a tire and wet grip is also relevant to follow, because test methods for winter tyres sometimes assume different conditions than for summer tyres — that is also something on which the sectoral rules should provide clarity.

Making a distinction between what is established and what is still to come

For internal organisation, the distinction between "already mandatory" and "still to be determined" is practically important. Articles 5 to 7 of the ESPR make clear that performance and information requirements per product group are established via delegated acts — not via the basic regulation itself. This means that a company that is already preparing passports now does so on the basis of the generic structure from Article 10, supplemented by what is meanwhile known about the expected content for tyres. A separate set of data specifically for winter tyres is among the things that still need to be determined, and thus not among the things that can already be laid down as an obligation.

Where things go wrong in practice

A wholesaler divides his internal data system into "winter" and "summer" with different fields, based on an assumption about what the delegated act will contain — and must restructure that afterwards once the actual requirements differ.

An importer adopts the classification of one manufacturer as a standard for all brands, while another manufacturer may classify winter tyres differently or provide additional test values that do not correspond one-to-one.

A fleet manager expects that the passport of a winter tyre automatically displays a temperature indication, while that data — if it becomes mandatory at all — is only determined with the definitive product group requirements and is therefore not guaranteed to be present in every passport.

A company decides to add "seasonal" fields to the passport on its own initiative, without checking whether that aligns with how the rolling resistance class of a tire ultimately per tyre type must be measured and reported — with the risk that the company's own addition does not align with the official data structure once it appears.

A dealer assumes that winter tyres by definition receive a different rolling noise profile in the passport, while how I record the rolling noise of a tyre describes that the measurement method itself is determining, not the seasonal type.

What you can record

• An overview of the company's own product portfolio, broken down by tyre type (winter, summer, all-season), so that upon publication of the delegated act it quickly becomes clear which products fall under which possible subcategory.
• Contact moments with manufacturers or suppliers about how they classify winter tyres and which technical data they typically provide with them.
• An internal log of the source and date of each data point entered in a passport, so that if there is a later adjustment it is clear what the original basis was — relevant in combination with the question of whether and how data can be adjusted after a product passport has already been published.
• An overview of which data are considered commercially sensitive in the event of additional technical specifications for winter tyres, in preparation for the question of whether such data must be made public, as described in commercially sensitive data on tyres.
• An agreement on the update frequency of passport data per tyre type, so that when test methods or classifications change, it is quickly clear which passports need attention, in line with what is described about how up to date the data in the digital product passport must be.