For the digital product passport for tyres, you essentially need three types of documents: the technical data about the tyre itself (materials, performance values, dimensions), the documents proving who is responsible for placing it on the market (the economic operator), and proof that this data comes from somewhere and is therefore traceable. Without that traceability, a passport is essentially a list of claims, and that is precisely what supervisory authorities look at.
Which documents these are concretely depends on your position in the supply chain. An importer placing tyres under its own brand on the EU market needs different documents than a distributor reselling tyres from an established manufacturer. In both cases, the principle applies: the data must demonstrably come from the source, not from a loose spreadsheet that someone compiled at some point.
The technical foundation: what goes into the passport
The core of the passport consists of data that typically already exists at the manufacturer: the composition of the tyre, the materials used, the performance values that also appear on the EU tyre label such as fuel efficiency, wet grip and noise level, and information about repair, reuse or recycling at the end of life. This data usually comes from test reports, technical datasheets and declarations that the manufacturer already draws up for other purposes, such as CE marking or the tyre label itself.
The detail that is often overlooked with tyres is that these technical documents do not automatically form a passport by themselves. They must be combined into one whole that meets the requirements of the regulation, and linked to the correct QR data carrier. Who does that combining and how that link works technically is explained in the section on where the data in a passport comes from.
Who supplies the data, and why that is recorded
The regulation distinguishes roles in the supply chain: the manufacturer, the importer and the distributor can each be in a different position with respect to the same batch of tyres. For the passport, this means that you not only collect the technical data, but also record who has supplied which part. This is not a bureaucratic addition; it is the basis on which a supervisory authority can check whether a claim in the passport is correct and who it comes from.
For a company that itself imports tyres from a country outside the EU, this usually comes with documentation about the origin of the batch and the identification of the responsible party within the Union. For a distributor reselling tyres from a European manufacturer, the question is often simpler: what documents has the manufacturer already made available, and are they complete enough to process without gaps in the passport.
Proof of origin: the common thread in this file
On almost every topic related to the tyre passport, the same question comes up: where does this data come from, and can that be demonstrated? This applies to performance values, to material composition and to the identification of the economic operator. A passport that displays data but does not show where it comes from is missing the element that the regulation seeks to enforce: traceability throughout the entire supply chain.
In practice, this means it is wise to be able to point to a source for each piece of data: a test report, a manufacturer's declaration, an invoice confirming the origin of a batch. This does not need to be separate administration alongside what you already have; it is mainly about ensuring that existing documents are preserved and remain linked to the correct tyre batch, rather than disappearing scattered in various places.
What you can prepare now
Even with a delegated act that has not yet been published, part of the work is not dependent on the precise date. You can now already map out which technical documents your suppliers routinely send, which documents you already have regarding origin and responsibility, and where there are gaps in your administration that you will need to fill later. Anyone wanting to refine that overview can consult the knowledge bank with elaborated topics per situation to see which documents belong to their own role in the chain.
Because the exact requirements per delegated act may differ, and because the division of roles is not equally clear for every company, it is advisable to consult a lawyer in case of doubt about your own situation or to consult the text of the regulation itself via the official source. A competent authority ultimately assesses the concrete situation, not a general checklist.
Do you want to quickly see which documents seem relevant for your company, without having to go through a file immediately? Take the free product scan in a few questions or check the frequently asked questions about what is and is not needed for the product passport to see roughly where your company stands.