may I simply enter the technical data from the manufacturer's catalogue into the passport

Catalogue data can serve as a basis, but not automatically

Catalogue data from the manufacturer usually form the starting point, but adoption without verification is not without risk. A manufacturer's catalogue is made to sell a tyre, not to fill a product passport. The figures in it — rolling resistance, grip on wet road surface, noise level — often do come from the same measurements that are also relevant for the passport, but the question is whether they were established in the correct manner and whether they belong to the correct tyre size and variant. Whoever compiles the passport remains responsible for the accuracy of what it contains, even if the source of a figure lies elsewhere.

Which data this is relevant for, and which is not

This applies especially to performance values that have been established using a standardised method: rolling resistance, wet grip, rolling noise, and similar technical specifications that also appear on the tyre label. For those values, it applies that they have been measured according to a set test, measurement or calculation method, and a catalogue figure that has been determined in a different way does not automatically align with that. For purely descriptive data — such as tyre size, tread name, or seasonal type — adoption is less sensitive, because there is no measurement method behind it that could differ. How that distinction plays out precisely for each data point is linked to which data will be in the product passport for tyres; not every figure in a catalogue has the same status. This also applies differently to data on composition or origin of material, for which a separate substantiation is usually required separate from what appears in a sales catalogue.

What is already established now, and what is not

A fixed date on which this obligation applies to tyres is not yet established. The ESPR itself (Regulation (EU) 2024/1781) is the framework within which product groups, including tyres, are further detailed via a delegated act; that act for tyres is expected around 2027 according to the work plan 2025-2030. Until that act is published, it is not established which exact measurement method is mandatory for each value, and therefore also not to what extent catalogue data align with it. What is established, however, is the principle in Article 39 of the ESPR: values that are provided under the regulation must be determined according to reliable, accurate and reproducible methods, which take account of generally recognised measurement methods. That principle does not change, even though the precise elaboration for tyres has not yet been published.

How to approach this in practice

The first step is to check whether the catalogue data already specify according to which standard or method they were established; if that specification is missing, that is a signal not to adopt them automatically. A second step is to check whether the figure applies to precisely the tyre size and variant that goes into the passport, because catalogues sometimes summarise an entire product line under one representative value, while the passport must be specific per variant. A third step is to establish whether the measurement method used by the manufacturer matches what is mandatory for the passport according to the regulation; for that, the page about the method by which values must be measured provides more guidance. Where doubt exists, it is common practice to ask the manufacturer or importer on what basis the catalogue data originated, rather than simply transferring the value. For values that also appear on the tyre label, a comparison with it can be an additional check point — see also how the tyre label relates to the product passport. In case of doubt about specific performance values such as rolling resistance or noise, the pages about the rolling resistance class and rolling noise in decibels provide more background on how those values are precisely established.

The basis in Articles 5 to 7, 39 and 40 of the ESPR

Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) establish that products must comply with performance and information requirements that are elaborated per product category, and that the information provided on this subject must be documented in the prescribed manner. Article 39 adds to this the requirement that measurements and calculations are carried out in a reliable, accurate and reproducible manner, which puts a catalogue value without a known measurement method in a difficult position. Article 40 of the ESPR addresses the prevention of circumvention and deterioration of performance, and is relevant because it indicates that a passport must reflect the actual performance, not a more favourable value presented from marketing materials. Together, these articles mean that the source of a figure does matter, even if the exact technical specification for tyres is still to follow from the announced delegated act.

Companies that are now already collecting tyre data would be well advised to document for each catalogue file according to which method the values have been determined, so that this source can later easily be checked against the requirements that will apply with the delegated act.

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

What is expected of you

A catalogue sheet from the manufacturer is a helpful starting point, but it is not automatically a valid source for the product passport. The ESPR sets requirements for the manner in which technical values are determined and substantiated, not only for the values themselves. This means that an importer or wholesaler who takes over catalogue data must be able to rely on something more than trust that the manufacturer will have measured it correctly.

Data must be determined according to the prescribed method

Article 39 of the ESPR (Regulation (EU) 2024/1781) prescribes that test, measurement and calculation methods are reliable, accurate and reproducible and are consistent with the methods established for the product in question. For a company with 10 to 100 employees, this concretely means: when taking over a catalogue value, the question should be asked according to which method that value was determined, and whether that method is consistent with what is prescribed for tyres. A catalogue sheet that only shows a figure without mention of the method does not provide certainty on that point. More on the methodology itself is described on the page about the method by which values for the passport are measured.

The content of the passport must be consistent with the information requirements

Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) determine that products must comply with performance and information requirements that are filled in per product category via delegated acts. This directly affects what must appear in a tyre's passport. A catalogue is usually written for commercial purposes and does not automatically cover every piece of data that the passport will request. Which fields these are precisely is described on the page about the data that goes into the product passport for tyres. It is advisable to place that list alongside a catalogue sheet before anything is taken over, rather than assuming that the catalogue happens to contain everything.

Data must not be tailored to a more favourable result

Article 40 of the ESPR (Regulation (EU) 2024/1781) focuses on the prevention of circumvention and deterioration of performance, for example through software or design choices that make a test turn out more favourably than the product performs in use. For an importer who takes over data from a catalogue, this means that an apparently favourable value is not automatically a reliable value. While there is no possibility to monitor test conditions at the manufacturer, this does not relieve a company of the question of whether the stated value is plausible in relation to comparable products. Where deviations are noticed, enquiry to the manufacturer is a more logical route than to pass the value on to the passport without further consideration.

Where things go wrong in practice

A number of situations come up regularly in practice.

An importer adopts the rolling resistance value from an Asian catalogue without it being clear whether that value was determined according to the method prescribed in the EU. A passport is created with a figure, but without substantiation of the test method. How that value can be properly checked against the method is explained on the page about the rolling resistance class of a tire.

A wholesaler uses catalogue data that was prepared for a different seasonal type than the product actually being imported. Summer tyres and winter tyres have different characteristics and sometimes different specifications to be reported, and a catalogue sheet prepared for one type cannot be used for the other without verification. That difference is detailed on the page about the specifications for seasonal tyres.

A company adopts a noise value expressed in decibels without verifying whether the measurement method matches the method applicable to the passport. Rolling noise is determined and recorded in a specific way, as described on the page about rolling noise in decibels; a catalogue figure measured in a different way does not fit in without further adjustment.

A supplier uses catalogue information on rubber composition that was prepared for marketing purposes, with vague terms such as "high-quality rubber compound", while the passport requires more specific data. What exactly is expected for that is set out on the page about recording data on rubber composition.

A company assumes that a tyre label value (as shown on the packaging) can be copied directly to the passport without modification, whereas the passport and label do not have exactly the same function or scope. The distinction between them can be found on the page about the relationship between the tyre label and the product passport.

What you can record

For a company that processes catalogue data into a passport, it is practical to document a number of matters in writing, even if there is no legal obligation for a specific document yet:

An overview of which catalogue data have been adopted, per product group or type number, stating the source (which catalogue, which version, which date).
A note on the test method mentioned by the manufacturer for each adopted value, and whether that method matches the prescribed method.
Correspondence with the manufacturer or importer in which the test method was requested, if this does not appear from the catalogue itself.
A comparison between the catalogue data and the fields required by the passport, so that it is clear which data are missing and still need to be requested.
A note against each value that deviates noticeably from comparable products, stating the reason why that value was nevertheless adopted or specifically requested.
Version control of the catalogue itself, so that if the manufacturer's data are changed later, it is clear which version was used for the passport at that time.

This record is not intended as additional bureaucracy, but as a basis for being able to demonstrate afterwards why a particular value is in the passport and where it comes from. Those who follow this route are usually in a stronger position than those who adopt a catalogue sheet directly without further verification.

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.