A supplier is, in short, the party that makes a tyre available on the European market for the first time or places it on the market under its own name. This can be the manufacturer itself, but also an importer who brings tyres from outside the EU, or a company that has tyres produced under its own brand. In doing so, the regulation does not look at the size of your business, but at the action you perform: whoever makes a tyre available in the EU for the first time bears the obligations that come with that role.
For tyre importers and wholesalers, this is relevant because the supplier is the party responsible for ensuring that the digital product passport exists and is correct. Anyone who merely resells tyres that have already been placed on the EU market by someone else usually fulfils a different role in the chain, with different obligations. The distinction between those roles is precisely the detail on which most questions come in: one and the same enterprise can be a supplier for one product range and a distributor for another.
Why the distinction is difficult in practice
Tyres often go through multiple links: manufacturer, importer, wholesaler, dealer, fleet manager. A company that imports tyres from a country outside the EU and sells them under its own name thus often acts as a supplier, even if it has not changed anything about the tyre itself. That same company can for another part of its assortment only resell what a European manufacturer has already placed on the market — and then different responsibilities apply. The role is thus determined per product line, not once for the entire company.
This is also why the regulation itself is careful with this concept: the text distinguishes manufacturer, authorised representative, importer and distributor as separate roles, and attaches to each role its own set of obligations. Whoever consults the text itself will see that it is not a choice you make yourself, but a qualification that follows from what your company actually does with the product.
What this means for the product passport
If your company qualifies as a supplier, that is usually also the party from which the data for the product passport must come: technical specifications, composition, information on maintenance and end of life. If you are a distributor of tyres that another party has already placed on the market as a supplier, then that obligation rests with them, and your role is more to pass the passport to the next link in the chain, for example via the QR code on the tyre.
This distinction is precisely why many companies first want to know which role applies to which part of their assortment before engaging in a conversation with a software supplier or data processor. On a few questions that quickly show which role fits your assortment you will get a first indication of this, without having to work through the entire regulation first.
How this relates to the time when the passport becomes mandatory
The digital product passport for tyres is expected to become mandatory around 2029, but that date is not yet fixed: the work plan of the underlying regulation provides for a delegated act in 2027, and only after publication of that will the exact date be known. For the question of who qualifies as a supplier, that makes little difference — that distinction follows from the role your company already fulfils, not from the date on which the obligation takes effect. It is therefore useful to already know now what role applies to your company, so that you do not have to figure out in the last few months before implementation who in the chain supplies which part of the passport.
In the knowledge base, where such concepts are worked out per situation, you will find this distinction further explained, with the reference in the official text. You can also read how a supplier's data will be compiled into a passport, including who supplies which part.
What is not yet fixed
The precise content of the passport per tyre type, and the way supervisory authorities will check whether the correct party is marked as supplier, are matters that will be clarified further. For your own situation — for example, if you are unsure whether your company qualifies as a supplier, importer or distributor for a specific assortment — it is advisable to consult the official text or ask a lawyer to assess the precise classification. General explanations such as this cannot replace that assessment.
If you would like to see where your own assortment currently stands, you can do the free quick-scan or read the frequently asked questions about this role distribution Both provide an initial direction, without you needing an account right away.