What do I do with tyre stock already in place when the rules come into effect?

What you must do concretely

What is expected of you

The ESPR provides in Article 1 that the regulation applies to products placed on the market or put into service. Article 18 indicates how product groups — including tyres in due course — are prioritized and scheduled for a delegated act. What this concretely means for inventory already in stock is not stated in so many words in these articles: the delegated act for tyres must still be published, and only then will it specify from which point a product passport becomes mandatory and how existing inventory is handled in this context. This is explicitly not yet established. What a company can meanwhile reasonably be expected to do is primarily to maintain an overview and not blindly rely on a date that may yet shift.

Know what you have in stock

For a company with 10 to 100 employees, this means in practice: a stock administration that shows per batch or lot when a tyre was produced, purchased and placed on the market. Without this overview, it is impossible to determine afterwards which inventory falls under an old situation and which under new rules. This overview is also the basis for being able to demonstrate later when a batch was already in circulation.

Following the planning laid out in Article 18

Article 18 describes how the Commission prioritizes product groups. For an importer or distributor, this means that own planning — purchasing, inventory build-up, contracts with manufacturers — must be structured with a certain margin. Not because the date is already set, but because the order and timing of the delegated act for tyres may still change. Anyone who now builds up large inventories without taking this into account runs the risk that part of that inventory will later still fall under the new obligations.

Aligning with what is already known

Even though the definitive date is missing, the contours of the product passport (data from the manufacturer, hosting, QR data carrier) are already somewhat established in the broader ESPR framework. A company can choose to already inventory which data are available per tyre type now, so that a later link to a passport does not result in a backlog. What can I already do while the rules are not yet final? goes into more detail on what is practically achievable in this respect without getting ahead of ourselves.

Where things go wrong in practice

Inventory without production date. At many distributors, the date of production or first sale is not consistently recorded. If afterwards a distinction must be made between "old" and "new" inventory, the evidence is then missing.

Purchasing in anticipation of an incorrect date. Some companies are already building large inventories based on expectations of 2027 or 2029 as fixed dates. Both years are currently forecasts, not established facts. Inventory decisions based solely on those expectations could turn out to be wrong in retrospect.

Unclear information between locations. At companies with multiple sites, inventory is sometimes recorded differently per location, with the result that there is no central overview of what is stored where and since when. That problem also affects the question can multiple locations of my company manage the same product passport, because a central passport system only works properly if the underlying inventory data are also centrally correct.

Destruction of inventory without recording. Inventory that no longer sells is sometimes simply disposed of without recording when and why. That can raise questions later, especially if it involves batches that may still have fallen under transitional rules. The question may I still destroy unsold tire inventory addresses this specific point further.

No link between purchase file and sales administration. Tire importers who maintain purchasing and sales in separate systems may later struggle to trace a batch from manufacturer to end customer. That is not only a problem for a possible passport, but is also already relevant for questions about recalls, as discussed under does the product passport help with a recall of tyres and how does it work.

What you can record

• An overview per batch or consignment: production date, date of first placing on the market in the EU, supplier and destination.
• Purchase invoices and delivery notes demonstrating the date of placing on the market, archived per batch rather than in chronological order only.
• An internal document recording the assumptions on which inventory decisions were based (for example: expected date of the delegated act), so that it can later be traced why a choice seemed logical at a particular moment.
• Agreements with manufacturers or suppliers on which data they can already provide, even though there is not yet a passport obligation — this prevents everything from having to be requested later.
• An overview of facilities and their own inventory records, as a stepping stone towards a central system.
• Documentation of disposed of or destroyed inventory: date, reason, quantity.

For companies wishing to know how this recording fits into a broader trajectory towards the product passport, provides How do I approach the digital product passport for tyres step by step? an overview of the order in which these kinds of preparations practically come together. And those wondering whether this label will still apply to their own product portfolio will find initial guidance at Does the digital product passport apply to my tyres?