Yes, you can do part of the work around the digital product passport yourself. Collecting the product data that must appear in the passport — technical specifications, material data, test results, conformity information — is the responsibility of the company designated as a market operator. That is work you are familiar with: these are the same data that are already in your administration, your ERP system or with your manufacturer.
Where most companies run into difficulty is not in collecting but in processing it into a passport that meets the technical requirements: a fixed structure, accessible for ten years via a QR code that does not change, and accessible to both supervisory authorities and buyers. That requires a system designed for those requirements, and you will not build and maintain that in an afternoon alongside your regular work.
What you can reasonably provide yourself
Providing raw data is usually the part that fits best with your own organisation, because you already have the data in-house or receive it directly from the manufacturer. Think of article numbers, tyre sizes, production data, test certificates and the documentation you already keep for other purposes, such as product safety. If you already maintain this data internally in a structured way, you have a good foundation for this. read through the concepts and obligations per subject gives you an overview of which data categories the regulation distinguishes, so you know exactly what you need to collect before proceeding.
What mainly requires technical expertise
Compiling the passport itself, generating a permanent QR data carrier and keeping the information accessible for ten years are components that for a different reason are less straightforward to do yourself: they require not so much knowledge of tyres, but of data storage, security and continuity. A system must, for example, be able to withstand changes in software, server migrations and the risk that a supplier ceases to exist within that ten-year period. These are questions that go beyond running a website.
Why the line is not always clear
Some companies with their own IT department choose to build the technical part themselves as well. This is possible, provided the chosen solution demonstrably meets the requirements that the regulation places on the passport, including the retention period and accessibility for supervisory authorities. Practice shows that this is mainly feasible for companies that already maintain similar systems, for example for other product categories. For most importers and wholesalers, the investment in time and maintenance does not outweigh outsourcing that specific component.
The conversation with a supplier
Whether you choose to outsource everything or opt for an intermediate form, it is useful to clarify in advance who does which part: who supplies the raw data, who checks it for completeness, who is responsible for storage over the ten-year period, and what happens if one of the parties stops cooperating. read through how the data flows from manufacturer to passport shows which steps are involved and where the data transfer takes place. Record these agreements, even if you work with an external party that takes on most of the technical work.
What remains your responsibility
Even if you outsource the technical part, responsibility for the accuracy of the data supplied typically remains with the market participant that places the tyres on the market. A supplier can deliver the product passport technically correctly, but cannot assess whether the product data you supply is accurate. That verification remains within your own organisation, and that is precisely the part for which doing it yourself is often the logical choice.
Would you first like to get an impression of what falls under data submission in your situation and what is more a matter of technical support? With a few short questions you immediately see an indication of your situation, and in the answers to frequently asked questions you will find more about the division of roles between your company and your supplier. For your specific situation, it is advisable to consult a lawyer or the competent supervisory authority if you are in doubt.