The most common mistake with the digital product passport for tyres is that companies see it as a one-time action: collect data, have the passport created, done. In practice, the passport is not a snapshot but a data stream that must remain accurate for ten years. If no one is designated internally to be responsible for this, there is a risk that data will be incomplete at the start and that no one will notice if something changes later.
This problem usually does not arise from unwillingness, but from the way companies currently handle product data. Procurement knows which tyre sizes and brands are coming in, the warehouse knows which batches are physically present, and administration has the invoices and certificates. Without someone bringing these three sources together, the information remains fragmented — precisely the kind of fragmentation that surfaces when compiling a passport.
Why this mistake is so common
At most SMEs, product information is not stored in one place. Some of it is in the purchase package, some in emails with the supplier, and some only on paper when a batch is received. As long as no one asks for that information, it goes unnoticed. As soon as a passport is needed that bundles data from the manufacturer or importer, it becomes clear that no one knows exactly what data exists, where it is, and who keeps it current.
This mistake is reinforced by the fact that the regulation itself is still under development. The delegated act that sets out the precise requirements for tyres is expected in the European Commission's work plan for 2027; the date when the passport becomes mandatory is not yet fixed after that. Companies often wait until everything is concrete, and put off designating a person responsible until it is 'really necessary'. That is precisely the moment when there is no time to get data in order.
What goes wrong in practice
The most common consequence is that data that is delivered on time is incomplete or inconsistent. A product code that is written differently in one system than in another, a certificate that exists but is not linked to the correct batch, or a supplier that has changed without this being recorded anywhere. None of these things is a major problem in itself, but together they make compiling a passport slower and more error-prone than necessary.
A second recurring pattern is that companies assume the manufacturer or importer will automatically provide all data completely. That may be the case, but the regulation distinguishes between roles in the supply chain, and exactly who must provide which information depends on your company's position in it. If you have not checked this for your own situation, you will only discover it when something is missing. review the concepts and roles carefully gives a clear picture of where you stand in the supply chain, without you having to become a lawyer first.
How to avoid the mistake
The core of the solution is simple, though it may sound too simple: designate someone within your organisation who knows what tyre data you have, where it comes from and how it stays current. This does not have to be a full-time task or a technical role. It is about overview, not execution. Once that person is known, it becomes much easier to compile data when needed and to signal in time if a supplier, certificate or product line changes.
It also helps to look now at how such a passport is compiled and hosted in practice, so you know what data you will be asked for later and from whom. see how the data is collected and hosted shows you which steps are involved, without you having to do anything yourself.
What this means for your own situation
Whether and how this error is relevant for your company depends on your role in the chain and the type of tyres you trade or use. An importer has different obligations than a fleet manager who has tyres fitted, and a wholesaler has different obligations than a fitting company with its own tyre stock. A short, targeted check makes that difference clear quickly. With get clarity on your situation with a few questions takes you a few minutes and gives an immediate indication, without you having to study the full regulation.
Please note that this article is intended to be descriptive and does not constitute legal advice. For a ruling on your own company's situation, we refer you to the official text of the regulation or to a lawyer.
Do you want to know where you stand concretely, or do you have a question that was not covered here? Take the free quick-scan or read the other topics in the most frequently asked questions about the tyre passport in peace — half an hour is usually enough to know whether, and what, changes for you.