The most common mistake companies make with the digital product passport for tyres is assuming that their role in the chain is self-evident, or that another party will fill that role. An importer thinks the manufacturer will supply the data, a wholesaler thinks the importer has already arranged the passport, and a fleet manager assumes this is the supplier's responsibility. These assumptions are understandable, but they mean that no one in the chain feels responsible at the moment it actually matters.
The regulation distinguishes different roles, such as manufacturer, importer, distributor and authorised representative. Which role applies to a company depends on what that company actually does with the tyre: manufactures it themselves, imports it from a country outside the EU, or resells it within the EU. Moreover, the same company can have a different role for one product range than for another. A company that both imports tyres itself and resells them to a wholesaler combines two roles at the same time.
Why this mistake is so common
The confusion usually arises because the terminology in the regulation does not correspond one-to-one with how companies refer to themselves in practice. A company that internally calls itself a "supplier" or "dealer" does not automatically recognise itself in a legal term such as distributor. As a result, the question "is this applicable to us" is asked too late, often only when a customer or a supervisor asks about it.
A second cause is that the role in the chain can shift once business activities change. A wholesaler that today only sources within the Netherlands may next year order directly from a manufacturer outside the EU. At that point the role changes, and with it what the company is expected to do. Companies that have determined their role once and do not review it again run the risk that the situation has changed in the meantime without their administration having kept up.
What goes wrong if the role is incorrect
If a company misjudges its role, there is a good chance that the associated tasks fall to no one. Data that should have been supplied by the importer remain incomplete because the importer thought the manufacturer had already done this. For the parties further down the chain, such as the wholesaler or fleet manager, this is often not immediately visible: they only see a gap in the information when something goes wrong with a delivery or when a supervisor asks for evidence.
It is therefore not so much the role itself that causes problems, but the absence of a clear, shared agreement about who performs which role within a chain of multiple companies. Without that agreement, tasks can be duplicated, or not done at all.
How to prevent this
A first step is to determine your own role based on what the company actually does, not based on how the company refers to itself internally. This means looking at the origin of the tyres, the manner of importing and the parties to which supplies are made. in a few questions see which role fits your situation provides an initial direction here, without this being a legal opinion on your specific situation.
A second step is to document that role in agreements with suppliers and customers, so that everyone in the chain knows who supplies which part of the data. This is also a topic that comes up in the conversation with a software supplier about the tyre passport, because the supplier often needs to know on behalf of which role the data is being supplied before the passport can be compiled.
A third step is to periodically check whether the role still applies, especially when business activities change. A role that was correct two years ago may no longer be correct now.
What this is not
This explanation describes a common pattern, not an assessment of an individual situation. Whether a particular role applies to a business, and what obligations come with it, is set out in the official text of the regulation and is assessed by the competent supervisory authority or a lawyer. For an overview of the different roles and concepts, and where they are mentioned in the regulation, is the knowledge base with explanations per concept a suitable starting point.
Anyone who wants to know what such a data flow looks like in practice once the role has been established will find that in the explanation of where the information in the passport comes from. And for the questions that entrepreneurs most frequently ask about roles and responsibilities in the chain, there is the overview of frequently asked questions.
If you want to know where your business currently stands, the free quick-scan is a low-threshold first step: no account required, and within a few minutes an indication you can work with.