A tyre passport inspection does not concern a single document, but an integrated whole: the passport itself as it can be consulted via the QR code, the data on which that passport is based, and the records showing which party supplied which data and when. Supervisory authorities examine whether the passport is current, accurate and traceable, and whether the party that compiled the passport can demonstrate where the data came from.
The detail most often overlooked in this context is that the tyre passport does not replace existing product safety documentation. A tyre must, apart from the digital passport, still comply with the rules that already existed, such as type approval and the associated technical documentation. The passport provides access to information, but it is not a new declaration of conformity and not a replacement for existing certificates. Those who confuse these aspects run the risk that during an inspection the passport is correct, but the underlying documents are incomplete, or vice versa.
The list of documents that may be relevant
In practice, this concerns a number of categories of documents that exist alongside each other. First, the dataset contained in the passport itself: technical characteristics, material composition where applicable, and information about origin and end-of-life processing. Second, the source files used to supply that data, usually provided by the manufacturer or importer. Third, the correspondence or contract that sets out who is responsible for keeping that data current. Fourth, the existing product safety documentation that was already mandatory independently of the passport. And fifth, where applicable, proof of the role a company fulfils in the supply chain, for example as a supplier or as a party placing tyres on the market.
These last two categories are often forgotten because they are not visible in the passport itself. This is precisely what a supervisory authority looks at, because the passport on its own says little about whether a company has correctly determined its role in the supply chain. What a supplier precisely is and what obligations come with it are described in the regulation itself; those uncertain about their own role are well advised to check this against the official text or discuss it with a lawyer.
Why traceability is the core concept
The regulation asks not only for data, but for data whose origin can be established. This means that a company must not only be able to show the end result, but also the step before it: who provided the information, at what time, and has it been changed since then. For companies that have the passport compiled by a third party, there is a practical point to note here: traceability must also work when data has been supplied via an intermediary. how the data for a passport is built up shows how this is arranged in practice.
Because the delegated act that sets out the precise requirements has not yet been published, it is not yet definitively clear which documents will be required and for how long they must be retained. The ESPR work plan mentions a delegated act for tyres around 2027, with an expected entry into force of the obligation around 2029. Once that act is published, this will be supplemented here; until then it is advisable to start inventorying which documents a company already has in-house, rather than waiting until the details are known.
What this means for the conversation with a software supplier or service provider
For companies outsourcing the composition of the product passport, it makes sense to ask in advance how the supplier handles traceability: is it recorded where each piece of data comes from, and can that record be requested during an inspection. That is a different conversation than questions about price or delivery time, but equally important. with a few questions have it estimated.
The classification of documents above is a general overview and is neither exhaustive nor binding; which documents are needed in a specific situation depends on the company's role in the supply chain and the type of tyre. For those wishing to investigate that on a case-by-case basis, an overview of the relevant concepts and obligations is available in the knowledge base, elaborated per subject. For your own situation, an assessment by a lawyer or the competent supervisory authority remains the recommended course of action.
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