Whether the digital product passport for tyres affects your company does not depend on whether you "work with tyres", but on the role you play in the chain. Those who place tyres on the market, hold a trade mark or import tyres from a country outside the EU generally face obligations under the regulation. Those who only purchase tyres, fit them or have them fitted for their own vehicle fleet are usually not the party required to provide the passport themselves.
The regulation targets what it calls "the manufacturer": the party responsible for placing a tyre on the market. If you are a fitter, vehicle fleet manager or office organisation that has tyres replaced, you are usually a user of the passport and not the party that must compile it. This distinction is at the heart of whether the subject applies to you, and it is a different distinction from the question of what a manufacturer actually is; we address that concept elsewhere. the concepts from the regulation in order
Who the obligations are intended for
The regulation is primarily aimed at manufacturers and parties who place tyres under their own name or brand on the EU market. This also includes those who import tyres from outside the EU and subsequently sell them: an importer often takes on the role of manufacturer in practice, even if the manufacturing itself takes place elsewhere. Wholesalers who resell tyres without changing their origin or composition generally have a different position than an importer, but they too may have to pass on data to those further down the chain.
Whether your company falls under one of these roles is not always clear at first glance. A company that has tyres manufactured under its own brand, for example for a vehicle fleet contract, can indeed become a manufacturer in this way, even without making a tyre itself.
When you are probably not the obligated party
A fitting company that fits tyres purchased by another company is generally not a manufacturer. The same applies to an office organisation or HR department that concludes a lease contract with a tyre service for the vehicle fleet: that organisation uses the passport but does not compile it. In these situations, the obligation lies with the party that actually placed the tyre on the market, and your own role is mainly that of a buyer who needs access to the data.
That does not mean the subject is irrelevant to you. Even as a buyer, it can be useful to know where to find a tyre's passport, for example for maintenance, warranty or reselling vehicles with tyres on them. The obligation to provide the passport then lies with another party, but you use the QR code and the data behind it.
What changes if you import yourself or purchase directly
Companies that import tyres themselves, even in small volumes, are well advised to check in advance whether they thereby take on the role of manufacturer. This is different from simply reselling tyres that have already been placed on the EU market by another party. In case of doubt, the difference between "reselling an existing product" and "placing on the market for the first time" is decisive, and that difference determines whether you must have a passport compiled yourself or not.
Those who discuss this with a software supplier or service provider should first be clear about what role their own company plays, so that the discussion does not focus on the technology before it is clear whether the obligation exists at all. how the data for a passport are compiled
The role determines the obligation, not the sector
A common misunderstanding is that 'being in the tyre business' in itself creates an obligation. This is not the case: two companies in the same sector, for example two wholesalers, may be affected differently depending on whether they have tyres manufactured under their own brand, merely resell them, or only use them internally for their own vehicle fleet. When assessing obligations, supervisory authorities look at the actual role in the supply chain, not at the company name or industry classification.
The delegated act that sets out the precise requirements and deadlines has not yet been published; it is currently expected around 2027 within the regulation's work plan, with application that could come into force around 2029. As long as that act is not in place, it is also not definitively established which product categories of tyres fall precisely under the obligation.
How to check this for your own company
Because the role in the supply chain is decisive and not the sector, it is worthwhile for most companies to check this concretely for their own situation rather than relying on what is said in the industry. A brief inventory of where the tyres come from, under what name they are sold and who is the first party in the EU to place them on the market usually already provides a good picture.
Would you like to see this laid out for your own company? With a few questions you can see where you likely stand, completely free of charge and without obligation. For the underlying concepts and the source in the official text you can consult the most frequently asked questions about the product passport ; for your own specific situation, a lawyer or the competent supervisory authority remains the appropriate course of action.