The rules for the digital product passport come from a single European regulation that applies directly in each Member State without a country having to first transpose it into its own legislation. The technical content of the passport, the data that must be included in it and the way it is accessible via a QR code are therefore in principle the same throughout the EU.
What does vary by country is how supervision is organised. Each Member State appoints one or more supervisory authorities to check whether companies comply with the regulation, and each Member State determines how those authorities operate, how they set priorities and how they act in case of a shortcoming. For a company that sells tyres only in the Netherlands, that is usually one point of contact. For a company that also supplies in Germany, Belgium or France, there can be multiple authorities, each with their own way of working.
What the regulation makes uniform
The regulation itself leaves no room for Member States to add their own requirements to the passport or to ease them. A tyre that has a valid passport in the Netherlands in principle meets the same substantive requirements as a tyre with a passport in Spain or Poland. That is precisely the purpose of a regulation: one market, one set of rules, not twenty variants of the same document.
The official text of the regulation can be consulted in the same way by everyone via EUR-Lex, regardless of which country you are based in. If you want to check what is literally stated, you do not have to search for a different version per country. In the knowledge base organised by subject the source in that text is cited for each topic, precisely to enable that traceability.
What varies by country
The difference is in the implementation, not in the rule. Member States appoint their own market surveillance authorities, and these may fall under a different ministry, have a different name and work to a different rhythm than their counterpart in a neighbouring country. The way in which a shortcoming is handled, for example through a warning, a remedial period or another measure, is also a national competence within the European framework.
Supervisory authorities in different Member States do exchange information with each other, including through European market surveillance cooperation systems. This means that a signal in one country can also become known in another country, but it says nothing about how quickly or in what way that country will respond to it. For a company that supplies internationally, it is therefore useful to take into account that the same question about the same passport can be received in two countries in a different way.
Why this may be relevant to you
If your company only operates in the Netherlands, this difference will change little in what you have to do: the passport must be correct in content, period. If you also supply customers in other Member States, it is important to know that you may have to deal with more than one supervisory system, even though it concerns exactly the same product and the same data.
This is also one of the points it is worthwhile to discuss with your software provider or IT partner: how is the passport provided if you supply in multiple countries, and what country-specific points of attention are known in this regard. With a few questions you can get a clear picture in five minutes you can get an initial picture of what is relevant to your own situation, without this yet being a statement on how a supervisory authority in a specific country will act.
What is established and what is not
The delegated act that establishes the exact content of the tyre passport has not yet been published; the ESPR work plan mentions 2027 as the expected timeframe. Once that act is in place, it will also become clearer how implementation in each Member State will be arranged in detail. Until then, it is prudent not to treat assumptions about supervision in a specific country as established fact.
For more information about how we obtain our information, please read the page about the source of our information. For your own situation, especially if you supply internationally, it remains advisable to consult the competent supervisory authority or a lawyer if in doubt.
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