what should I pay attention to when choosing a platform for the product passport

Pay attention to three things: storage, coupling and durability

When choosing a platform for the product passport, it ultimately comes down to three questions: where and for how long are the data stored, how is the passport coupled to the product, and what happens if the supplier itself stops or is taken over. The ESPR (Regulation (EU) 2024/1781) describes in article 10 and article 11 a number of requirements that a digital product passport must meet — on accessibility, on the data carrier, on who may view or modify which data. A platform that has these matters in order is a logical starting point. A platform that remains vague about these matters deserves a critical look, even if the rest of the offering seems attractive.

For tyre importers and wholesalers, not for the end user

This consideration applies especially to the party responsible for compiling and publishing the passport: the manufacturer, or the party acting on behalf of the manufacturer, such as an importer. Fleet managers and other tyre users do not choose a platform themselves — they read the passport that is already there, for example to check what the tyre passport offers for the fleet. For them, the choice of supplier is not an issue.

What also does not belong here: the question of whether a platform is mandatory. There is no legal obligation to choose a specific platform, and the ESPR does not prescribe a specific provider. What the regulation does stipulate are requirements for the result — accessibility, coupling with a data carrier, structure of the data — not the way in which a company organises that. A company with multiple locations can incidentally work with one passport per product across locations; see how multiple locations can manage one product passport for what is relevant in this regard.

No legal obligation yet, so no mandatory choice yet

There is currently no concrete obligation to already have a product passport for tyres. The delegated act that regulates this specifically for tyres still needs to be published; the ESPR work plan 2025-2030 mentions 2027 as the expected period for this, and until then there is no firm implementation date set for this page. As soon as that date is known, it will be mentioned here.

Until then there is no obligation to choose a supplier now — but making a choice can, and has practical advantages if it is done calmly rather than under time pressure. What there is to do in the meantime without waiting for the final rules is described on what you can already do while the rules are not yet final.

First the basic questions, then the price comparison

The first question to ask is how long the platform retains and keeps the data accessible, because a product passport must remain accessible during the relevant period — that is not a matter of a year or two, but a considerably longer period. Ask specifically about the number of years that has been committed to, and what happens to the data if the platform itself ceases to exist or is taken over by another company.

The second question concerns the data carrier: how is the QR code or other carrier created, coupled to the specific product or product group, and who is responsible if that carrier is damaged or becomes unreadable. Article 11 of the ESPR addresses the technical design and operation of that data carrier, and a supplier should have a clear answer to this, not just a technical demo.

The third question is who has access to which data, and how that is shielded. Article 10 describes requirements regarding, among other things, accessibility for different parties — supervisory authorities, market actors, possibly consumers — and a platform should be able to explain how that distinction works in practice. This ties in with the question of whether customers will be able to view data themselves before making a purchase; see whether customers can check the data of the product passport before they buy.

Thereafter come the practical matters: how the passport is compiled from your own product data, what that costs per product or per batch, and how that relates to your own administration. An overview of the cost items involved is on what a product passport for tyres costs. It is also advisable to ask how a platform handles a potential recall, since a well-linked passport can play a role in that — more on that is on how the product passport assists in a tyre recall. And regardless of which platform is chosen, it remains advisable to keep your own copy of the underlying data; what to consider in that regard is on whether a backup of your own passport data is necessary.

The basis for this: articles 9, 10 and 11 of the ESPR

Article 9 of the ESPR introduces the digital product passport as a mandatory element for product categories covered by a delegated act. Article 10 sets out the requirements that the passport must meet, including accessibility and data structure. Article 11 describes the technical design and operation of the data carrier through which the passport is accessed. These three articles together form the framework within which every platform — regardless of the provider — must operate, and they are therefore the starting point when assessing a supplier, even before the delegated act for tyres is in place.

Anyone who wants to start now would be best advised to begin with the retention period and the link to the data carrier as the first two questions to put to each potential supplier, and to combine that with a look at the step-by-step approach for the product passport for tyres to see how the choice of platform fits into the wider process.

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

The digital product passport is not something a company will build from the ground up on its own. The ESPR (Regulation (EU) 2024/1781) describes what a passport must be able to do and what technical requirements it must meet, but leaves the implementation to the economic operator. In practice, this means: choosing a platform that collects, stores and makes data accessible via a QR code or similar data carrier. That choice rests with the company itself, and the quality of that choice determines whether the passport will work as intended over the years.

What is expected of you

Accessibility throughout the full period

Article 10 of the ESPR sets requirements for the accessibility of the digital product passport: the data must remain available to the parties entitled to it, for the period that applies to the product category. For a company of 10 to 100 employees, this mainly raises a question of continuity: does the platform continue to exist, and what happens to the data if the supplier stops, is taken over, or the contract expires. This is not a legal question but an operational one: a passport that cannot be retrieved after five years does not meet what is expected, regardless of who was responsible for it.

Technical design that complies with the requirements of article 11

Article 11 of the ESPR describes the technical design and operation of the digital product passport: how the data carrier (such as a QR code) works, how data is linked to a unique product identifier, and how interoperability with other systems is ensured. For an importer or wholesaler, this means that not every platform is free to arrange this at its own discretion. A supplier who has no answer to how his system complies with these technical requirements places the risk with the company that has the passport drawn up.

Responsibility for the content remains with the economic operator

Article 9 of the ESPR makes clear that the digital product passport contains information about the product, and that information comes from the manufacturer, importer or other market actor in the chain. A platform may collect and display that data, but the accuracy of the content remains the responsibility of the party that supplies the data. This means that choosing a supplier does not mean that responsibility shifts with it. Those who confuse this risk discovering during an inspection that liability actually lies with their own company. What a supervisory authority requests in such an inspection is described on what does a supervisory authority request during an inspection of tyres?.

Where things go wrong in practice

A first situation: a company enters into a contract with a platform that stops its service after two years, without having agreed an export option for the stored data. The QR codes on sold tyres then point to a page that no longer exists.

A second situation: the supplier promises "full compliance with the ESPR", but cannot explain how the platform handles the unique product identifier from Article 11. During an inspection, the link between physical product and digital passport turns out not to be unambiguous.

A third situation: a wholesaler with multiple locations enters into a separate contract per location with different platforms, while the products are the same. This creates duplicate work and inconsistent data between locations. Whether and how multiple locations of a company can manage the same product passport, is therefore something to clarify in advance, not to repair afterwards.

A fourth situation: a company assumes that the platform automatically keeps a copy of the data and stops its own archiving. If the platform later modifies or deletes data without notifying, there is no longer any own evidence of what was once supplied. See also on this the question of keeping your own copy of the data in the product passport being sensible.

A fifth situation: when procuring a platform, only the price per passport is considered, without looking at what happens in a recall. A platform that lacks the functionality to quickly communicate with holders of a specific passport has little value in a recall action. How the passport can help in this regard is described on does the product passport help with a recall of tyres and how does it work.

What you can record

An overview of the technical requirements from Article 10 and Article 11 of the ESPR, set against what the prospective supplier actually offers — not what the supplier claims to offer, but what has been concretely tested.
Agreements on data transfer at the end of the contract: how and in what format the stored data can be exported if switching to a different supplier.
A documented division of responsibility between your own company and the platform: who is responsible for the accuracy of the source data, and who for technical availability.
An internal copy or export routine of all supplied data, independent of what the platform itself preserves.
An overview of your own company's location structure , so that it is clear in advance whether one platform works for all locations or whether separate contracts are needed.
A list of questions for prospective suppliers on continuity: what happens in case of takeover, insolvency, or discontinuation of the service.

Those who wish to place this choice within the broader approach will find an overview of the successive steps on how do I approach the product passport for tyres step by step?, and an indication of the costs associated with a platform choice on what does a product passport for tyres cost?. Because the delegated act for tyres has not yet been published, this is also a good time to look at what you can already do while the rules are not yet final — choosing a supplier does not need to wait for the final date, but preparation can already start.

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.