Strictly from a legal perspective, nothing is changing this year in your tire purchasing contracts. The delegated act that makes the obligation for a digital product passport for tires concrete has not yet been published; the European Commission's work plan for 2025-2030 mentions 2027 as the expected moment for this, and the date when the obligation actually takes effect will only be fixed once that act is in place. What is changing, however, is that an increasing number of suppliers, manufacturers and wholesalers are getting ahead of that obligation in the way they draw up new contracts.
This getting ahead is mainly reflected in three types of agreements: who supplies the data that will eventually need to be included in a passport, who is responsible if that data is incorrect, and who pays for maintaining it throughout the tire's lifetime. For a procurement department, this means it can be worthwhile to include these points already in contracts that are concluded or renewed this year, even though the legal obligation does not yet exist.
Why document something now that is not yet mandatory
Tires purchased this year often remain in use for many years. A tire that comes into stock now or is fitted in a vehicle fleet can still be in circulation when the delegated act is published. If you agree in the contract now who is responsible for supplying and keeping product data current, you avoid discussion when that obligation does come into force. This is not a legal necessity, but a practical choice that fits the nature of the product.
It also plays a role that the tire market has long been working with mandatory product information through the existing tire labeling regulation for fuel efficiency, wet grip and noise emissions. That data overlaps in part with what will eventually go into a digital product passport. Contracts that now clearly set out who supplies these labeling data provide a basis to build on once the passport obligation becomes more concrete.
Which clauses procurement departments are already seeing shift this year
In practice, we see three types of changes recurring in new or renewed contracts. First, a provision on data transfer: who supplies which technical specifications, in what format, and within what timeframe after delivery. Second, a provision on amendments: what happens if a manufacturer adjusts a specification later, and who notifies whom. Third, a provision on the duration of the obligation: since a passport will in future need to remain accessible for ten years, some contracts are already setting out what happens if a supplier ceases operations or switches software partner.
None of these points are legally required to be included this year. However, they are increasingly being discussed between procurement and supplier, precisely because the regulation itself makes clear the direction in which obligations are heading. Those who want to know more about what such a passport looks like in practice and which parties play a role in it will find an overview in the knowledge base with explanations per topic.
What is not changing this year
It is just as important to state what will not change this year. There is no new reporting obligation, no new fine and no new supervisory authority specifically for the tyre passport, simply because the underlying regulation does not yet exist. Supervisory authorities in the Netherlands and other EU Member States are currently monitoring existing rules on product safety and labelling of tyres, not on a passport obligation that still has to be established. Those who wish to check how the existing rules relate to what is still to come can best inquire about this with their own legal advisor or with the supervisory authority relevant to the sector.
For companies that are already drawing up procurement contracts now, the practical question is therefore not 'what do I need to change this year', but 'what agreements do I make now so that I don't have to renegotiate later'. A good conversation with the software supplier about how data is recorded and transferred is part of this. More on exactly how that data is collected and where it comes from can be found on the page where the information in a passport comes from.
Form your own initial picture
Whether your company needs to record anything already depends on your role in the supply chain and how your current contracts are structured. You can get a free initial indication of this with the product scan that maps out your situation in a few questions. If you have doubts about a specific clause or contract form, that is a question for a legal advisor or the competent supervisory authority, not something that can be answered in general information.
If you want to follow developments around the tyre passport without constantly searching for them yourself, check out the other topics in the knowledge base or do the free quick-scan. Practical questions that come up frequently are also clearly listed together on the page frequently asked questions about the tyre passport.