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What is changing this year in supervision of the tire passport?

An overview of what is and is not changing this year in supervision of the digital product passport for tires, and why most developments are still ahead.

Short answer

For the digital product passport for tires, little is changing this year in the area of supervision and enforcement that is already concretely established. The delegated act that precisely stipulates which data are mandatory and when a tire must have a passport does not yet exist. As long as it does not exist, no specific supervisory regime for the tire passport can come into effect. Supervisory authorities have long been working with existing rules on product safety and market surveillance, and these remain in full force.

What is moving, however, is the preparation. The European Commission is developing the ecodesign work plan further, market players are already coordinating their processes, and software suppliers such as ourselves are setting up systems based on the text as it is now known. This is not a change in the rules themselves, but a shift from "waiting" to "preparing" at many companies in the chain.

What is and is not changing this year

The regulation is in place, the implementation is not yet

The Ecodesign Regulation for Sustainable Products (ESPR) is the framework within which the tire passport will eventually have to operate. That framework is fixed. What is still missing is the delegated act that specifically concerns tires: which data must be included, who provides them, and from which date this is mandatory. As long as that act has not been published, there is no concrete moment at which supervisory authorities can begin to check the tire passport itself. The Commission's work plan mentions an expected period, but an expectation is not a fixed date, and that date is not changing this year because it has not yet been established.

Supervision based on existing rules continues as normal

What already exists, and does not disappear this year, is the broader supervision of product safety and the accuracy of product information. Tires are already subject to rules that stand apart from the digital passport, such as requirements for labelling and safety. Supervisory authorities in the Netherlands and elsewhere in the EU have long been keeping an eye on this, and those powers do not change because the passport does not yet exist. For companies, this means that existing obligations remain in force, even while the specific passport process is still being worked out.

What supervisory authorities are expected to do once it is ready

Once the delegated act is in place, it is reasonable to expect that supervisory authorities will look at the things that are central to other product passports: is the QR code on the product, is the information attached to it correct, and is it clear who in the chain is responsible for which data. This is an assessment based on how market surveillance normally works in the EU, not an announcement of a concrete enforcement programme for tires. A more precise definition of roles such as manufacturer, importer and distributor can be found in the knowledge base, where each role is explained along with its corresponding responsibilities.

What this means for your company

For most companies in the tire chain, this mainly means: no new deadline has been added this year, but the preparation time becomes shorter as the delegated act draws nearer. Companies that are already putting their data in order, asking their software supplier about how a passport will be supplied later, and preparing their purchasing contracts accordingly, will be in a better position once the rules do become concrete. This is not an obligation that arises this year, but a practical choice that many companies are already making.

Anyone who wants to know how far their own organisation already stands in relation to what is happening in the sector can easily check that with a brief scan that maps your situation. This does not provide a legal assessment, but it does provide a concrete starting point for discussion within your company or with your supplier.

Where you keep an eye on this

Since the date of the delegated act is not yet established, it is more sensible to follow the development than to anticipate a specific enforcement date now. For the current state of affairs, the official text on EUR-Lex is the primary source, and for questions about application in your own situation, the competent supervisory authority or a lawyer remains the appropriate contact. On our own site we keep track of the sources and the latest state, including in the frequently asked questions about the tyre passport, so you do not have to figure out yourself which source applies for what.

If you want to know how we obtain our information and why we deliberately do not mention a date that has not yet been established, you can read that on the page where we explain where our information comes from. And if you would prefer to immediately see how the passport looks in practice for your products, then the knowledge bank with explanations per topic is a logical starting point.

This topic will change, and that is precisely why we continue to monitor it. Feel free to do the free quick-scan or browse through the knowledge bank to see what is already established and what is not yet established for your situation.

This article is general information and not legal advice.