What does the product passport mean if I sell tyres through an online marketplace?
Selling via a marketplace does not change the obligation, but it does change who is looking at it
Whoever offers tyres via an online marketplace remains responsible themselves for the product passport of those tyres — the channel through which the sale takes place makes no difference to that obligation in itself. Additionally, the marketplace itself acquires its own role under the ESPR: according to Article 35, platforms on which products are offered have separate obligations that are distinct from those of the seller. There are therefore two parties that must do something: the seller who must have the passport available, and the marketplace that must monitor this in its own role.
Who this applies to and who it does not
These rules apply to everyone who offers tyres via a platform: importers selling directly on a marketplace, wholesalers making it a sales channel, and smaller traders reselling tyres. For them, the obligations of distributors and traders under the ESPR apply as normal, regardless of whether the sale takes place via their own webshop, a physical store or a marketplace.
What does not fall under this: the marketplace itself does not become a party that must compile the product passport or verify its accuracy in terms of content. Article 35 concerns the role of the marketplace as a platform — not taking over the seller's responsibility for the content of the passport. That responsibility for content lies and remains with the manufacturer or importer who supplies the data, and with the trader who offers the product. Private sale of second-hand tyres between consumers is also a different matter from sale by a business via a marketplace; this page is about the latter situation.
When this comes into effect
No firm date has been set yet. The underlying ecodesign regulation (ESPR) is in force, but the delegated act that sets out the requirements specifically for tyres — including the point at which the product passport becomes mandatory — still needs to be published. According to the European Commission's work plan for 2025-2030, that delegated act for tyres is expected in 2027. Until that act is published and the transition period mentioned in it has elapsed, the passport obligation for tyres does not yet apply, and therefore neither does the question of how that should work via a marketplace. As soon as the delegated act is published, the date will be updated here.
What this concretely means for those selling via a marketplace
For those already selling tyres via a marketplace or planning to do so, it is most practical to look at this in the following order. First: who in the chain provides the passport. If the tyres come from a manufacturer or importer who has already had the passport drawn up, the task of the marketplace seller is mainly to display that passport — via the QR code or the associated link — with the offer. If the seller is the importer themselves, then compiling the passport is also their responsibility, regardless of the sales channel.
Next: what the role of the marketplace itself is. Article 35 sets out obligations for the platform provider, separate from the obligations of the seller. This means that a seller cannot assume that the marketplace will verify or take on the presence or accuracy of the passport for them — the marketplace has its own responsibility, the seller has theirs, and the two run alongside each other, not in place of each other.
Finally: the practical side of the offer itself. A product passport belongs to a specific product, and on a marketplace multiple variants (size, tread pattern, season) are often offered under one advert or else separately. Anyone selling multiple tyre types via one marketplace account would do well to check per product variant which passport belongs to it, rather than linking one passport to a whole range of similar products.
The legal basis: Articles 30, 31 and 35 of the ESPR
This classification follows directly from the ESPR (Regulation (EU) 2024/1781). Articles 30 and 31 describe the obligations of distributors and dealers — the parties that place products on the market without producing or importing them themselves. These obligations apply to the placing of products in general and make no exception for sales via an online channel. Article 35 furthermore specifically describes the obligations of online marketplace providers and search engines, as a separate category alongside manufacturer, importer, distributor and dealer. For the precise content of these articles, the official text of the regulation is the source; this page describes the main line, not the full text.
What to do
If you are already selling tyres via a marketplace or preparing to do so, it is best to check who in your own supply chain will supply the digital product passport — the manufacturer, the importer, or your own organisation — and set down that agreement before the obligation comes into force. Tyrepas.eu will update this page once the delegated act for tyres is published, with the then applicable date and conditions.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 35 (obligations of online marketplace providers and search engines)
- Regulation (EU) 2024/1781 (ESPR), Articles 30 and 31 (obligations of distributors and traders)
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
An online marketplace occupies a different position than a regular shop or wholesale distributor. The marketplace usually does not sell the tyres itself — that is done by the suppliers who offer their range on the platform — but it does provide the platform on which the sale takes place. The ESPR (Regulation (EU) 2024/1781) also makes this distinction: Article 35 specifically addresses the obligations of online marketplace providers and search engines, separate from the obligations that apply to distributors and dealers in Articles 30 and 31.
If you are the marketplace itself
For a company operating a platform on which third parties offer tyres, Article 35 of the ESPR applies. This article focuses on the role of the marketplace in making product information accessible to the consumer, including the product passport. In practical terms, for an organisation of this size, this means looking at how listings are set up: is there a mandatory field for the QR code or link to the passport, and is it checked whether that field actually points to a working passport, or to an empty page or an incorrect tyre type. The latter is a technical check point, not a substantive assessment of the accuracy of the data itself.
If you sell via the marketplace
If a company sells tyres itself via such a platform, it is not Article 35 that provides the starting point but the position that company holds in the chain. Anyone who imports, distributes or resells tyres falls under the obligations that apply to that role — regardless of whether this happens via their own web shop, a showroom or a marketplace. What obligations does a distributor or dealer of tyres have? describes what control and transmission of the passport is expected under Articles 30 and 31 of the ESPR. For a company of this size, this means in practice that the listing on the marketplace must display the same passport as the listing on its own website — the passport is linked to the product, not to the sales channel.
Knowing who holds which role in your chain
A third point that is often underestimated in practice: the obligation to display the passport does not rest with the marketplace if it is not itself the seller. A company that sells tyres on a marketplace remains responsible for providing the passport to that listing. Whether that company is a manufacturer, importer or distributor then determines how much of that passport it must compile itself. Am I an importer or manufacturer according to the ESPR? is the question that precedes it, and which determines which article — 30, 31, or another part of the regulation — applies to that specific sale.
Where things go wrong in practice
The listing refers to the wrong product. On marketplaces with large assortments, product pages are sometimes merged or reused for similar tyre types. A QR code or link that belongs to one size and one profile can end up on the page of a different model. The buyer then sees a passport that does not match the tyre that is actually delivered.
Multiple sellers on one listing, one passport. Marketplaces often allow multiple sellers to offer the same product under one product page ('multiple sellers, one listing'). If one of those sellers delivers a different brand or batch than the one the passport was drawn up for, the link is no longer correct, even if it was correct when the listing was created.
Unclear who provides the passport. When selling via a marketplace, there is sometimes the impression that the marketplace itself is responsible for arranging the passport, because it manages the technical platform. Article 35 addresses the role of the marketplace in making information accessible, not in compiling the content. That responsibility lies with the party that puts the tyre on the market or distributes it further.
Sale under own brand via the marketplace. A trader who offers tyres under their own brand name on a marketplace thereby assumes a different position than a party that resells the manufacturer's brand unchanged. What that means for the listing and the product passport is described at I sell tyres under my own brand — what obligations do I incur? — a situation that occurs relatively frequently on marketplaces, because private label is a common business model there.
No visibility into what changes when the listing is modified. Marketplaces regularly modify listings: different photos, merged variants, new category structure. A product passport link that was correct with the original listing can, after such a modification, no longer be associated with the correct product without anyone noticing.
What you can record
- Overview of which listings belong to which product passport. A simple link table between SKU, listing ID on the marketplace and the corresponding product passport makes it possible to quickly check whether a correct link still exists, even after modifications by the marketplace itself.
- Agreements with the marketplace on technical requirements. Many platforms set their own requirements for the format of the product passport field (for example, a mandatory QR code in a product image). It is worthwhile to define those requirements together with your own internal delivery procedure, so that a new employee follows the same steps.
- Checkpoint when creating or modifying a listing. A fixed checkpoint — for example: no listing live without a working product passport link — prevents a tyre from going online without a link.
- Recording of your own role in the supply chain. Whether a company acts as a distributor, trader or brand holder for a specific listing is not always the same for every product. Recording that per product line aligns with what is also described at Who is responsible for the digital product passport for tyres? and prevents disputes afterwards about who should have supplied which part of the product passport.
- Evidence of the data supplied to the marketplace. An export or screenshot of what was supplied at the time of publication, with date, is useful if a listing is later modified by the marketplace itself and the link changes as a result.
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.