What is a digital product passport for tyres?

What you must do concretely

What is expected of you

A digital product passport is, in short, a digital file attached to a product and which can be consulted via a data carrier — usually a QR code. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes that the passport makes product data accessible to those who have the right to it: supervisory authorities, market operators in the supply chain, and in certain cases the consumer. For tyres, this means that in future, alongside the physical tyre, there will also be a digital file containing the information prescribed by the legislation. What exactly must be included in that file varies by product group and is laid down in a delegated act — what a delegated act is and why it determines what must happen read separately.

Ensuring that a passport exists

Article 9 of the ESPR describes that the passport must exist before the product is placed on the market. For a company with 10 to 100 employees, that mainly means: determining who in the supply chain creates that passport. For imported tyres, that role often lies with the manufacturer or with the importer who receives the data from the country of origin. For own brands or private label, it is less obvious who collects the data and has the passport drawn up.

Ensuring that the data carrier is on or with the product

Article 10 of the ESPR describes requirements for the data carrier: it must be physically accessible with the product, even after it has gone through the supply chain. For a wholesaler, this means that the QR code on the tyre, the packaging or the label remains in place during storage, transport and sale — not only upon first delivery from the factory.

Ensuring that data remains current and accessible

The passport is not a snapshot at the time of sale, but must be accessible for the duration of the product's life. That affects hosting, who manages the data, and what happens if a supplier ceases to exist. For fleet managers who keep tyres in use for years, this is one of the points where practice most often falls short: a passport that no longer opens after a few years does not meet the objective of Article 9.

Knowing which information who may see

Not all information in the passport is intended for everyone. A supervisory authority may have access to different data than a consumer who scans the QR code in the shop. Who may access which data from the product passport is therefore a question that deserves separate attention, especially for companies that themselves supply data and want to know what becomes visible to the end user.

Where things go wrong in practice

The QR code becomes detached from the product. A sticker on a tyre that is damaged or comes loose during storage, fitting or transport, leaves a passport without an accessible data carrier. In bulk storage of tyres at a wholesaler, this is a real risk, especially if the sticker is on the packaging and not on the tyre itself.

Nobody knows who creates the passport. When importing tyres through multiple channels — manufacturer, foreign trader, European importer — it is not always clear who is responsible for assembling the passport. That problem is more acute the longer the supply chain is, and directly affects the question whether the product passport applies to own tyres.

Data is supplied once and then no longer maintained. A passport that is correct at launch but is not updated when changes are made to composition or specification, deviates from what Article 10 of the ESPR describes regarding the up-to-dateness of data.

Special tyre types are forgotten. Casings, retreaded tyres and test batches may fall under the rules differently than regular new tyres. Those who fail to make that distinction run the risk of creating passports where that is not necessary, or conversely of omitting them where they should have been created — those differences are set out in casings and retreading and in test tyres and trial batches.

Confusion about tyres on new vehicles. Tyres fitted as original equipment on a new car or truck follow a different route than tyres sold separately in trade. Anyone working in the tyre industry who also delivers vehicles risks confusing these two — see who draws up the product passport for tyres on a new vehicle.

What you can record

• An overview per tyre type of who in the supply chain draws up the product passport: manufacturer, importer, or your own company.
• Agreements with suppliers on which data they provide, in what format, and how often these are updated.
• A procedure for the data carrier: where the QR code is applied, and how it is checked that it remains readable during storage and transport.
• A list of which data are included in the product passport, aligned with what the regulation requires — an overview of which data belong in the product passport for tyres is a good starting point for this.
• A data retention agreement on hosting and accessibility of the data throughout the expected lifetime of the tyre, including what happens if a supplier or platform ceases operations.
• An internal responsible person who keeps track of when the delegated act for tyres is published and what that means for your own planning — relevant to the question when the product passport becomes mandatory for tyres.