Yes, you can take on part of the work on the digital product passport yourself: gathering data, organizing it and checking it for completeness is work that already happens in many businesses for other purposes. But whether you can put together the passport entirely yourself depends on who in the supply chain is responsible for which information, and on technical requirements that are not yet all finalized.
The core of the answer is this: the passport consists of two layers. The first layer is the content — the product data that comes from manufacturing or import. The second layer is the technical implementation — keeping the passport accessible for ten years and equipping it with a QR data carrier that meets the requirements. In theory, both layers can be filled in by you, but in practice you will run up against boundaries that do not depend on your effort.
What you can prepare yourself
As an importer, wholesaler or fleet manager, you often already have much of the necessary information in-house: type approvals, technical data sheets, origin data and documentation that you keep anyway for purchasing or warranty purposes. Gathering and organizing that data is a task you can take on yourself, and it saves time further down the process if that data is already structured and ready. Also, designating someone within your organization to oversee the overview — who has which tyres, from which supplier, with which documentation — is something you arrange yourself, regardless of which party ultimately puts together or hosts the passport.
What is beyond your own scope
The regulation places the responsibility for the accuracy of the product data with a designated party in the supply chain, often referred to as the provider. Who exactly that is varies depending on the situation and you do not determine it by building the passport yourself — it follows from the role you fulfil in the supply chain. Furthermore, the regulation sets technical requirements for the data carrier and for the duration and manner of hosting, requirements that are aligned with what other parties in the EU will soon have to be able to read. Putting a QR code on a tyre yourself does not solve that if the underlying data does not meet the correct format or does not remain accessible long enough. For who exactly fulfils which role, there is a separate overview based on the legal text itself; reading the concepts and roles carefully gives an initial picture of this without you having to dig through the full text.
The role of a service provider such as tyrepas.eu
Because the technical side — hosting, data carrier, format — is separate from the substantive data you provide, many businesses choose to separate those two: provide the data themselves, and have storage and QR linking handled by a party set up for that purpose. That is not an obligation, but rather a practical consideration: guaranteeing for ten years that a passport remains accessible, even if your own systems change, is different from creating a passport once. If you want to first see what that looks like concretely in your situation, then a brief scan with a few questions gives an initial indication, and an explanation of where the data comes from shows which part of the process stays with you and which part is taken over.
What is not yet fixed
The exact technical requirements for tyres — which data format, which fields are mandatory, and from which moment onwards — follow from a delegated act that has not yet been published. The work plan of the European Commission mentions 2027 as the expected time for this, with expected application around 2029, but this is not yet fixed. As long as that act is not in place, no one can say with certainty which part of the work is entirely to be done yourself and which part requires technical support. As soon as the act appears, that overview will be updated here.
Where you check this
For your own situation — who is the responsible person in your specific chain, and what obligations follow from that — the official text on EUR-Lex is the starting point, possibly with a lawyer or the competent supervisory authority involved. This article describes the regulation in general terms and is not advice about your own business.
Do you want to quickly see where you stand for yourself, without having to understand all the rules straight away? Do the free quick-scan or read the other topics in the frequently asked questions about the digital product passport through.