What does a digital product passport for tyres cost?
The law names no amount, the market does
The ESPR (Regulation (EU) 2024/1781) does not prescribe what a digital product passport may or must cost. Article 9 of that regulation describes which data a passport must contain and how it must be accessible via a data carrier such as a QR code, but says nothing about a tariff. The price of a passport is therefore not determined by Brussels, but by the party that compiles the passport for a manufacturer or importer, hosts it and provides it with a QR code. Anyone looking for a concrete amount in the legislation will not find it — it is a service that is procured on the market, just like labelling or certification, for example.
Obligation to a passport, no tariff
Article 9 of the ESPR describes the technical and substantive requirements for a digital product passport: what information it must contain, how long that information must remain available and via what type of data carrier it is disclosed. For anyone placing a tyre on the EU market, an obligation to have such a passport will arise in due course. For wholesalers and fleet management, this mainly means they will encounter an existing passport, not that they have to compile it themselves. What the regulation says nothing about: who bears the costs within the chain, which service provider is chosen, and what a reasonable tariff is for compiling and hosting. This is up to the commercial agreements between manufacturer, importer and the party that technically handles the passport.
No fixed date yet, so no obligation yet
For tyres, no delegated act has yet been published that sets out the product group-specific requirements, so there is no moment yet when the obligation for a passport comes into effect. According to the work plan of the European Commission for ecodesign (2025-2030), a delegated act for this product group is expected in the course of 2027. Only after publication of that act will it be clear from which date a passport for tyres becomes mandatory, and only then will it become clear for which tyre types and from which moment costs actually have to be incurred. Until that time, there is no legal obligation, and any investment in a passport is a voluntary, forward-looking choice.
What determines the costs in practice
Those who want to know now what the costs depend on are best advised to look at a number of factors that are already foreseeable independently of the final wording of the law. Firstly, the number of product types and variants: an importer with ten tyre models has a different task than an importer with hundreds of SKUs, because each passport is linked to a specific product. Secondly, the amount and quality of source data: the more technical, material and origin information is already structured and available from the manufacturer or importer, the less work it costs to process it in a passport. Thirdly, the duration of hosting: a passport must remain accessible for a certain period, and a longer hosting period entails different costs than a short one. Fourthly, the physical data carrier: applying a QR code to or on the product, for example on the tyre itself or the packaging, is a separate step in addition to compiling the data. Those wishing to prepare for this route would be well advised to first put their own product data in order, then inventory how many different product types need a passport, and only then request quotes from parties that compile and host passports — so that a comparison is made over equal numbers and equal periods.
Where that is stated: Article 9 of the ESPR
The substantive requirements for a digital product passport follow from Article 9 of Regulation (EU) 2024/1781 (the ESPR). These requirements are further specified per product group via delegated acts, which the European Commission adopts and publishes separately — for tyres this has not yet occurred. The general explanation of the ecodesign regulation by the European Commission confirms that the regulation is a framework law, whereby the concrete product group requirements (and thus also the practical scope of what a passport must contain) are determined via separate, later legislation. None of these sources contain a tariff, threshold amount or price indication — that falls outside the scope of the regulation.
Those who wish to prepare now can best put their own product data in order and follow the announcement of the delegated act for tyres, and in the meantime request an indicative quotation from a party such as tyrepas.eu based on their own number of product types — so that there are no surprises once the obligation actually takes effect.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
- European Commission — ecodesign regulation for sustainable products
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
A cost overview with concrete amounts cannot be provided here. The ESPR (Regulation (EU) 2024/1781) describes in article 9 what a digital product passport must be capable of and what it must contain, but does not mention prices — those are determined by the market of service providers, and by how much work it costs your company to supply the data itself. What can be done here: list the cost items a product passport is probably made up of, and where companies often spend more time and money than expected.
What is expected of you
Supplying data that is correct and complete
The obligation that involves the most work is not the passport itself, but the data that must go into it. For a company of 10 to 100 employees, this usually means: designate someone who finds out which product data already exist (technical specifications, test reports, material composition) and which are still missing. That is a different task for an importer who sources tyres from multiple manufacturers than for a manufacturer who already has its own production data centrally stored. The costs are mainly in internal hours, not in an invoice from a supplier.
A data carrier (QR code) on or with the product
Article 9 of the ESPR calls for a data carrier that refers to the passport. In practice, this is often the smallest cost item: adding a QR code to packaging, tyre or accompanying documentation is a production process adjustment, not an ongoing cost item. The bigger question is whether that QR code needs to be incorporated into existing print or label processes, and who coordinates that across multiple product lines.
Having the passport exist for ten years
A passport that is no longer accessible after two years has little use. Hosting, maintenance and security over a longer period are a recurring cost item, often in the form of a subscription to a platform. For a company of this size, this is usually not a matter of building and maintaining it yourself, but of outsourcing it to a party that has this as a core task — comparable to how accounting software or a CRM is procured.
Keep data up to date
A passport is not a snapshot. If a manufacturer updates a test report or an importer receives a new batch with different specifications, that change must be recorded somewhere. This is a process cost item: who is responsible for maintaining it, and how often does it happen? For companies with multiple locations, there is also the question of multiple locations of the same company being able to manage one passport, which can provide economies of scale compared to separate subscriptions per location.
Where things go wrong in practice
Underestimating the time to gather sources. Companies often budget only the subscription costs of a platform, and forget that assembling correct product data from multiple sources (manufacturer, own tests, import documentation) is the largest time investment.
Separate Excel files per product line. Without a central approach, separate files are created per tyre brand or size, managed by different people. That works until an update is needed, and nobody knows which version is the correct one anymore.
Not accounting for changes later. A passport is set up once and then not maintained, while specifications, test reports or suppliers change in the meantime. That results in a passport that no longer matches the physical product.
Ignoring costs of temporary uncertainty. Because the final date of the delegated act is not yet fixed, some companies wait with any preparation — and then have to set everything up in a short period afterwards, which is more expensive than staggered work. What can be done in the meantime is described on what you can already do while the rules are not yet final.
Choosing a platform without looking at the long term. A cheap basic subscription may turn out to be expensive later if data export, integration with your own systems, or hosting guarantees have not been included in your choice. What to pay attention to in that choice is worked out at what should I pay attention to when choosing a platform for the product passport.
What you can record
- An overview of existing product data per tyre line: which specifications, test reports and material data are already available, and which still need to be requested from the manufacturer or importer.
- A person responsible for maintaining the passport: who identifies changes in product data and who processes those in the passport.
- Agreements with suppliers or manufacturers about data supply: at what time and in what form they make product data available, so this does not have to be sorted out repeatedly.
- A copy of the supplied data outside the platform: so that your own administration is not entirely dependent on one external party. See also the considerations at must I keep a copy myself of the data contained in the product passport.
- A step-by-step plan for your own organisation: which departments (procurement, quality, logistics) are involved in supplying and maintaining data. An overview of those steps is at how do I approach the tyre product passport step by step.
Once the delegated act for tyres is published, this overview can be supplemented with more concrete cost items and any deadlines. Until then, it is mainly a matter of knowing which internal processes incur costs, regardless of which platform is used.
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.