What does a supervisory authority ask for during a tyre inspection?

What you must do concretely

What is expected of you

A market surveillance authority's inspection hinges on one simple question: can you demonstrate that the product complies with what has been agreed. Regulation (EU) 2019/1020 gives the authority the power to ask that question and to demand documents, samples or access. Regulation (EU) 2024/1781 (ESPR), Article 27, additionally sets out which obligations specifically rest with the manufacturer. For a company of 10 to 100 employees, this amounts to a number of concrete expectations.

Demonstrating that the product complies

The authority first and foremost asks for evidence, not promises. That means there must be something available — a file, a declaration, test results — with which a company can show that the findings about the product match what is claimed. For a mid-sized company, this often means that this information is not sitting in one person's mailbox, but is findable somewhere for whoever needs to request it tomorrow.

Cooperating with the request within the set deadline

Regulation (EU) 2019/1020 gives the authority the possibility to set a deadline within which information must be provided. For a company without a legal department, the practical side of this is that there is someone who knows where the requested documents are and who is authorised to share them, without having to go through three departments first.

Identifying the product itself in the supply chain

A manufacturer or importer must be able to state from whom a product was received and to whom it was delivered. This seems self-evident, but with tyre imports via multiple intermediaries, this is not always solvable by a simple look at the records. If you have multiple locations, you can easily run into this issue: can multiple locations of my company manage the same product passport is then not a theoretical question but one that determines whether the supply chain information is available centrally or fragmented.

Being able to take corrective measures

If a market surveillance authority establishes that a product does not comply, this typically involves a follow-up step: informing, adjusting, recalling. Regulation (EU) 2019/1020 describes this as part of surveillance, and Article 27 of the ESPR places this responsibility with the manufacturer. This directly touches on the question does the product passport help with a recall of tyres and how does it work — a passport that links the correct parties and batches makes it easier to determine which tyres are involved.

Where things go wrong in practice

A number of situations come up regularly in practice.

The information exists, but nobody knows where it is. Data about a production batch is in an email from three years ago, from an employee who has since left. When the authority asks, there is no time to reconstruct this.

The supply chain information stops at your own door. A wholesaler can say who the tyres were bought from, but no longer where they came from before that — whereas the authority's question may be directed precisely at that origin.

It is assumed the supplier has it, but nobody has confirmed that. An importer assumes that the manufacturer in the country of origin has the technical documentation, without ever having checked this. When a request comes in, the documentation turns out to be incomplete or cannot be obtained within a reasonable timeframe.

No contact point has been designated. During an inspection, a name and function are requested. A company that has never recorded this loses time on the question of who is actually responsible for the response.

Inventory and documentation are out of sync. Older inventory was purchased under different conditions than more recent batches, but in the records that distinction is no longer traceable. This is particularly relevant to the question what do I do with tyre stock already in place when the rules come into effect — without a clear distinction between batches, it is no longer possible to say which documentation belongs to which tyres.

What you can record

A number of things can be documented with limited effort, and make the difference between an inspection that runs smoothly and one that causes delays.

• An overview of suppliers and customers per product line or batch, so that the origin and destination of a batch of tyres can be quickly reconstructed.
• A designated contact person (with a deputy) who knows what documentation exists and where it is located.
• A file per product group with the underlying technical data, also if it was originally supplied by the manufacturer.
• A fixed location where this data is kept, separate from whether the supplier's platform does this too — the question must I keep a copy myself of the data contained in the product passport is relevant here, because dependence on a single party during an inspection can be a vulnerable point.
• A brief internal agreement on who within the company responds to a request from a supervisory authority, and within what steps that request is handled.

Anyone who arranges this now, even without all regulations being definitively worked out, is building a foundation that will be usable during an inspection. More information on this can be found at what can I already do while the rules are not yet final. And for those who still need to determine how this is practically set up, the process is described at how do I approach the tyre product passport step by step.