How do I approach the digital product passport for tyres step by step?

What you must do concretely

What is expected of you

The digital product passport for tyres stems from Article 9 and Article 10 of the ESPR (Regulation (EU) 2024/1781). These articles describe what a passport must be able to do and what information it must contain, not how a company organises this operationally. This translation into practice is where most companies encounter problems. Below are the steps that follow from those obligations, with what they mean for a company with 10 to 100 employees.

Step 1: Determining whether the passport applies

Not every tyre and not every company will deal with the passport in the same phase. For an importer or wholesaler, the first question is simply whether the products they place on the market fall under the upcoming rules. This is not a legal exercise in itself, but a practical check that you can do with your own product list. Anyone in doubt will find on the page does the digital product passport apply to my tyres a starting point to answer that question.

Step 2: Establishing who provides the data

Article 9 of the ESPR stipulates that the passport is linked to the product and must be accessible via a data carrier (in practice a QR code). The data itself comes from the manufacturer or the importer who places the product on the EU market. For a company with 10 to 100 employees, this means that internally someone must know what data is available per product line, and from whom. For companies that import tyres from multiple manufacturers, this is often the first point where the approach stalls: the data is scattered across purchasing files, emails and spreadsheets, not in one system.

Step 3: Choosing how the passport is hosted and made accessible

Article 10 describes requirements for the passport itself: it must remain accessible for a certain period, and the data carrier must be affixed to or with the product. A company can build and host this itself, or engage a platform that offers this as a service. This choice involves practical questions: does the host remain in existence long enough, what happens if the service provider goes bankrupt, and how is the QR code affixed to a tyre that is already being produced in a factory in another country. Anyone who has to make this choice does well to look at what should I pay attention to when choosing a platform for the product passportbeforehand, because the obligations under Article 10 place responsibility for the availability of the passport with the person who places it on the market — not with the service provider.

Step 4: Structuring data and keeping it up to date

A passport that is filled in once and then no longer maintained does not meet the idea behind Article 10: the data must be correct as long as the passport is active. For companies with multiple locations, the question soon arises of who within the organisation is responsible for keeping the data up to date, and whether this happens centrally or per location. This is an organisational question that differs per company; on the page can multiple locations of my company manage the same product passport shows how this is often organised in practice.

Step 5: Informing the supply chain

Wholesalers and fleet managers are further down the chain and benefit from the passport mainly if the information is actually findable and usable. An importer setting up the passport therefore does well to think about who else needs to be able to work with it: their own customer, a fleet manager, or a supervisor. What a fleet manager can actually do with that data is described on what do I as a fleet manager get from the tyre passport.

Where things go wrong in practice

A number of situations come up regularly in practice.

Companies only start with the passport when the obligation already takes effect, while gathering data from older purchasing relationships with manufacturers that no longer exist or no longer respond takes much more time than expected.

The QR code is decoupled from the tyre itself, while Article 9 precisely asks for a data carrier that is linked to the product — a sticker on the box instead of on the tyre itself leads to discussion as soon as the tyre reaches the customer separately from the packaging.

A platform is chosen without consideration of what happens if the platform stops operating or is taken over, while the responsibility for data availability does not disappear with the supplier.

Facilities within the same company each use their own approach, resulting in the same tyre line appearing with different or contradictory data in the passport at two locations.

Stock purchased before the effective date is not included in the planning, while the question of what should be done with it requires a separate consideration — which is described on what do I do with tyre stock already in place when the rules come into effect.

What you can record

• An overview per product line of which manufacturer or importer supplies the source data, and via which channel (email, portal, EDI link).
• An internal agreement on who within the organisation is responsible for keeping passport data up to date, including a moment when this is checked.
• A selection document for the platform or host, including considerations regarding long-term availability — usable alongside the considerations on the page about choosing a platform.
• An agreement on how the QR data carrier is applied and by whom this is verified before the tyre leaves the facility.
• A separate copy of the data contained in the passport, independent of the supplier's platform; the considerations for this are on must I keep a copy myself of the data contained in the product passport.
• A protocol for what happens in the event of a recall and what role the passport plays in this, see does the product passport help with a recall of tyres and how does it work.
• A cost estimate for the initial setup and annual maintenance of the passport, as part of the budget — a starting point for this is on what does a product passport for tyres cost.