What data must I request from my tyre supplier?

What you must do concretely

What is expected of you

When you import, trade, or operate tyres in a vehicle fleet, the digital product passport gives you a role that goes beyond simply reselling. The ESPR (Regulation (EU) 2024/1781) establishes in Article 38 that actors in the supply chain must pass data on to the next party in the chain, and that starts with what you yourself collect from your supplier.

The data that the passport makes mandatory

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes what a digital product passport must generally contain and how it must be accessible. For a specific product such as a tyre, this is further specified by the delegated act that will be drawn up for the tyre sector — what a delegated act is exactly and why it determines what you must do, is explained elsewhere. In practical terms, for a company with 10 to 100 employees, this means you need a permanent point of contact who knows which data the manufacturer supplies per tyre type, and that those data do not remain scattered across emails and loose pdfs from different buyers.

Passing data on to the next link

Article 38 of the ESPR (Regulation (EU) 2024/1781) is the core provision on this subject: actors in the supply chain — so also an importer or wholesaler that is not itself a manufacturer — pass on the product information needed to complete the passport or allow it to function for the next party. For a mid-sized company, this means the role does not end at 'receive and store': the data must also be usable for the customer, the vehicle fleet manager or the next wholesaler in the chain.

Knowing who is responsible for what

For tyres manufactured in the EU, the initial responsibility for compiling the passport usually lies with the manufacturer. When importing from outside the EU, part of that role shifts to the importer, something that is further developed under what the product passport means when importing from outside the European Union. For a company with 10 to 100 employees, this is often the most difficult part: internally, someone must establish which supplier is the source of the data for which tyre line, especially if purchasing takes place through multiple channels.

Knowing whether the passport applies at all

Not every tyre type automatically falls under the same requirements at the same time. Before requesting data, it is useful to know whether the product passport already applies to the tyres being purchased and which product groups within the tyre sector fall under the ESPR. For a trading company with a broad assortment, this saves unnecessary data requests for products for which the obligation does not yet apply, or conversely: starting too late for a line that is already within the scope.

Where things go wrong in practice

A few situations come up repeatedly with companies that are just starting with this subject.

An importer asks the manufacturer for 'the documentation' without specifying which data are exactly needed for the passport. The manufacturer sends a technical datasheet intended for their own production, but which does not match what the passport requires. The result: two rounds of correspondence, delays, and a file that is still incomplete.

A wholesaler purchases from three different manufacturers, each with a different format and a different level of detail in their data. No one within the company has been given the task of comparing that data or checking it for consistency, so discrepancies only become apparent when a customer asks about them themselves.

A company has tyres manufactured at multiple factories under one of its own brand names and assumes that one of those factories will supply all the data for the complete passport. That is an assumption that does not automatically hold true — how data from multiple factories are combined into one product passport , requires a conscious agreement, not chance.

An importer receives data, but no one checks whether the figures and classifications provided by the supplier actually correspond with the physical product being delivered. Only during a sample check or following a complaint does it become apparent that a batch has been mislabelled.

A company delays requesting data until the obligation officially takes effect, and then discovers that its own supplier cannot quickly provide the requested data because they themselves are not yet prepared. What to do when a supplier does not provide the data is described under the options if a supplier does not provide the data.

What you can record

A number of matters can be put in order with relatively little effort, and prevents some of the above situations:

• A list per tyre type or product line of which supplier or factory provides the data, so that where there are multiple production locations it is clear who supplies which part of the passport.
• A fixed set of data that is requested, rather than a general request for "documentation" — this prevents a supplier from providing something other than what the passport requires.
• An agreement in the purchasing contract on the delivery of passport data, including who is responsible when the product changes. How that agreement might be structured is explained under recording passport data in a purchasing contract.
• A control point at which received data is compared with the physical product or existing specifications, as described under checking a supplier's data for accuracy.
• An internal overview of what is already known and what is still missing, per supplier and per product line, so that there is no need to search again for what has already been requested with each new order.

Such records take little time at the point when the purchasing relationship already exists, and save considerably more time when the passport actually needs to be compiled or presented.