Whether the tire passport applies to your company does not depend on whether you use or purchase tires. It depends on the role you play in doing so. If you purchase tires from a European distributor or manufacturer that already provides the tires with a passport, you are typically a user: you do not need to create anything, you only need to be able to consult the passport. If you source tires yourself from outside the EU, or if you put your own brand on them, the responsibility may shift to you.
The core question is therefore not "do I have a fleet", but "who puts this tire on the European market first". Whoever does that must also ensure that the data is there. For most installation companies, transport companies and offices with their own company vehicle fleet, that role lies with the supplier. But there are situations in which that is not so obvious.
When you are probably only a user
If you order tires from a Dutch or European supplier who sells them under their own name, that supplier is usually the one who must supply the data and have the passport hosted. In that case, you are purchasing a product that already comes with the passport, just as you now already receive a label or certificate. Your own task is then limited to being able to show the QR code or the data location when asked, for example during maintenance, resale or an inspection.
This is the situation in which most fleet managers and installation companies find themselves: they mount, use or maintain tires, but do not place a new product on the market. In that case, what changes for you is mainly the question of which documents you receive and keep, not the question of whether you yourself must supply data.
When the responsibility may lie with you
The situation changes as soon as you are the first party to make the tire available within the European Union. This can occur if you purchase tires directly from a manufacturer outside the EU and import them yourself, even if that is exclusively for your own fleet. Physical use for own vehicles does not automatically make the import itself unimportant for the question of who is responsible.
The same applies if you have tires manufactured under your own brand name or private label, even when another party actually makes them. And it can arise in arrangements where a group of companies resell or repackage tires amongst themselves before they reach the end user. In such cases, it is not automatic that the original manufacturer remains responsible; the regulation looks at who performs which action, not at who has the company name on the building.
Rental and leasing: a separate question
Tires that you rent or lease to third parties remain essentially the same product as tires that you use yourself. The distinction between "placing on the market" and "using" does not change because there is a rental or leasing agreement between them. More important is whether the tires are already provided with a passport somewhere in the chain, and whether you as a lessor add anything to that, for example by offering them under your own name. For companies that supply tires as part of a lease contract with vehicles, the question therefore lies mainly with the source of the tire, not with the leasing contract itself.
Doubt is a signal to investigate, not to guess
Most doubt arises with companies that both purchase and have part of their assortment produced under their own name, or who occasionally import directly alongside their regular purchases from a European wholesaler. In those cases, the distinction between "I use only" and "I place on the market" is not always clear at a glance. A fixed purchasing procedure with the same supplier consistently usually provides more certainty than changing purchasing channels.
For that reason, it is useful to look at where the role lies per purchase line, not per company. A company can be a user for one assortment and a supplier for another. the concepts examined per situation provides an overview of this, and in a few questions see where you probably stand shows which role fits your purchasing method. If you also want to know how we arrive at that indication, you can read that on the page about where the information comes from.
For your own situation
This article describes the general line as the regulation sets it out, not the assessment of your specific purchasing arrangement. If you are unsure whether that creates obligations for your company, the official text on EUR-Lex is the starting point, and a lawyer or the competent supervisory authority is the right party to assess your situation.
If you want an indication without obligations, take the free quick-scan or browse through the topics in the frequently asked questions about the tyre passport to see which question comes closest to your own situation.