Anyone importing tyres from outside the European Union and subsequently placing those tyres on the EU market needs four types of documents in essence for the digital product passport: the identification data of the manufacturer outside the EU, the technical and performance data of the tyre model, proof that a party within the EU has been designated as responsible for the tyres, and the underlying conformity documentation that already existed under the existing product safety rules. These documents together form the basis for compiling the passport, whether you do this yourself or whether a party does it for you.
The detail that plays the biggest role in this subject is not the list itself but the question of who supplies which document. With a manufacturer based in the EU, that responsibility usually lies with a single party. Once the manufacturer is based outside the EU, an additional link emerges: the importer, or an authorised representative, must demonstrate that they are authorised to act on behalf of the manufacturer and that the data they supply are correct. When importing from outside the EU, supervisory authorities also specifically examine the traceability of that link, not only the tyres themselves.
The core: which documents are linked to the passport
The first document is the identification of the manufacturer: name, address and, if it exists, a registration number outside the EU. The second document consists of the technical data of the tyre model itself, such as dimensions, composition and the performance characteristics that also appear on the tyre label. The third document is the designation of the party within the EU that acts as the point of contact: this can be the importer, or an authorised representative appointed by the manufacturer. The fourth document is the conformity documentation already kept under the existing product safety rules, such as test reports and the declaration that the tyres comply with the applicable requirements. The passport does not add any new technical inspection to this; it unlocks data that in many cases already exist, only not yet bundled and not yet accessible via a QR code.
For those in doubt about which of these roles applies to their own business, it helps to first clarify their own position in the chain. see in a few questions which role fits your company provides an initial indication of this, regardless of which documents you subsequently need to gather.
Why importing from outside the EU requires an additional layer of documentation
When importing from outside the EU, a question arises that is less prominent in domestic manufacturing: who guarantees that the data supplied by the manufacturer also correspond to what is actually being imported. This is not a new question that the tyre passport introduces; it is a question that already exists under the general rules for product safety. The passport only makes that question more visible, because the data will soon be available via a QR code and thus easier to check for anyone who wants to, from your own purchasing department to a supervisory authority.
This means in practice that the file for an imported tyre model is usually thicker than that for a model already being produced within the EU for some time: an additional link is added, and that link must be supported by documents. Companies that already maintain an import administration for customs matters often already have part of this work in hand; the task is then mainly to link those documents to the correct tyre model in the passport, not to gather them again.
What is not yet fixed
The precise, EU-wide list of mandatory documents for the tyre passport is not yet finalised. It will follow from a delegated act that is expected in 2027 according to the ESPR work plan 2025-2030, after which the tyre passport practice should commence around 2029. Until that act is published, the list above is a description of what logically belongs to this role, based on how comparable product safety rules already work today. For the current, official text, the published regulation itself or the competent supervisory authority remains the designated source.
Anyone wondering whether this also applies to their own situation will find general answers to frequently asked questions in the overview of frequently asked questions. That overview does not replace legal advice, but it does help to sharpen your own question before you submit it to a lawyer or supervisory authority.
How you organise this in practice
It helps to create one file per tyre model in which the four types of documents are kept together, rather than having them scattered across procurement, quality assurance and import administration. Anyone already working with a software supplier for the existing product safety file can ask whether the same integration can also be used for the passport; that saves double work. And anyone who still needs to find out where their own data comes from and how it reaches a passport will find that on the page that explains how data is processed into a passport.
For a broader overview of all documents and concepts that belong to the tyre passport, sorted by situation, is the knowledge bank with all topics by situation a logical starting point. If you are still unsure whether, and in what role, your company falls under these rules, do the free quick-scan or browse through the topics in the knowledge bank; both will give you a concrete starting point within half an hour, without needing a subscription straight away.