A digital product passport for tires is not a snapshot that is recorded once and then finished. The information in it — technical specifications, test reports, material sourcing, manufacturer declarations — should correspond with the actual tire that reaches the end user. If something changes about the product, the supplier or the underlying documentation, then in principle the content of the passport also changes. If that doesn't happen, then information is online that no longer matches what actually lies in the factory or warehouse.
What that concretely means depends on what has not been updated. An expired test report is something different from a changed article number, and an error in the rubber composition is again something different from a relocated importer. The regulation itself describes that the data in the passport must be current and correct; what actually happens in practice if that is not the case depends on the nature of the discrepancy and on the judgment of the supervisory authority that reviews it.
Why passports need attention especially after delivery
The moment a passport goes online usually receives the most attention: data is collected, checked and linked to a QR code on the tire. After that, the subject often disappears from the radar, while the product can remain in the supply chain for ten years or longer. During that period, testing standards can change, a manufacturer can issue a new declaration of conformity, or a distributor can name a different party as supplier. Anyone who does not pay attention to maintaining the passport runs the risk that the information at the time of an inspection no longer matches the product itself.
Which parties can have problems with this
Outdated data does not only affect the party managing the passport. A fleet manager who makes a purchasing decision based on the passport, a garage that replaces a tire, or a supervisory authority that carries out a sample check: they assume the information is correct. If it turns out not to be, that can raise questions about who in the supply chain was responsible for keeping the data up to date. That touches on the distinction between the role of manufacturer, importer and distributor, which is described separately in the regulation. Anyone who has not yet clarified that distinction for their own business will find more about it in the explanation per role in the tire supply chain.
The connection with existing product safety rules
The product passport is not separate from the rules that already existed about product safety. A tire that no longer meets the requirements with which it once came to market can come to the attention of a supervisory authority for other reasons, independent of the passport. Outdated or incorrect data in the passport can then reinforce that picture, but is in itself a different issue from the product safety of the tire. Companies that let these two tracks run into each other unnecessarily complicate their own process of figuring out who needs to take what action.
Who handles this in practice in the business
At an installation company, a distributor or a fleet manager, maintaining the passport is rarely assigned to one fixed function. Often it is the office manager who keeps the administration up to date, the purchaser who coordinates with suppliers, or the manager who carries the ultimate responsibility. It helps to agree in advance who signals a change with the supplier and who then has that change implemented in the passport. Without that agreement, updating too often remains on hold until someone happens to come across it.
How tyrepas.eu handles this
tyrepas.eu compiles the product passport based on the data supplied by the manufacturer or importer, and hosts the information for the specified period. If any of the underlying data changes, it is the responsibility of the supplying party to communicate this so that the passport can be updated. How exactly that supply works and which data is involved is described on the page about the platform's working method. For those who are uncertain whether their own situation requires an update, it is advisable to first consult the official text or the competent supervisory authority; this article describes the general approach, not the outcome for a specific company.
If you are not sure whether your current process provides for keeping the passport up to date, the free quick-scan with a few short questions provides a first indication of where you stand. For broader background on concepts such as supplier, market participant and the role that applies, is the overview of frequently asked questions is a good starting point.