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What documents do I need for supervision and enforcement of the tyre passport?

An overview of the documents that are relevant when a supervisory authority asks questions about the tyre passport, and why retention period is at the heart of the matter.

When supervision and enforcement concerning the tyre passport come up, it is not about one form that you put on a shelf. It is about a sequence of documents: proof of your role in the supply chain, the source of the data in the passport, proof that the QR code points to the correct passport, and — if a discrepancy is ever identified — the correspondence about it and proof of the corrective step you have taken.

The difference from a routine inspection on the shop floor is that enforcement often looks back. A supervisory authority conducting an investigation does not only ask what is currently stated on the tyre, but also whether the data from five years ago is still correct and whether you can demonstrate when and by whom something was amended. That is the detail that plays the biggest role in this subject: the documents must not only exist, they must remain traceable over a longer period than most companies are accustomed to under other regulations.

The difference between market surveillance and enforcement

Market surveillance is the ongoing inspection: a supervisory authority takes samples, scans a QR code, and checks whether the passport matches the tyre it is attached to. Enforcement is the step that may follow if something is not in order. Then the question shifts from "does this passport match" to "how did this come about, who knew about it, and what did you do about it". Which supervisory authority in the Netherlands is responsible for which part of this regulation varies by product category and is stated on the website of the relevant authority itself; that is not a question this article can answer.

The list: what documents are typically requested

As a basis, proof of your role in the supply chain counts: whether you are the manufacturer, importer, distributor or supplier of the tyre model in question. In addition, the underlying technical and environmental information processed in the passport is relevant, including where that data came from and who provided it. It is also important that you can demonstrate that the QR data carrier on the tyre actually points to the correct, current passport, and not to an outdated or incorrect version. Finally, as soon as there has ever been a report or signal, the file on it counts: what was reported, when, and what action followed.

These documents are rarely all in one place within a company. The technical data comes from the manufacturer or importer, the link with the QR code runs through the software company that hosts the passport, and correspondence about a possible discrepancy often lies with whoever contacted the supervisory authority. In the knowledge base on tyrepas.eu you will find what applies to your company per situation, so you do not have to figure out yourself which of these documents is relevant to your role in the supply chain.

Why retention carries more weight than presentation

In a routine inspection, it is about what you can show at that moment. In enforcement, it is about what you can reconstruct, sometimes years later. The tyre passport itself is hosted for a period of ten years, and the underlying documentation proving that the data in it were correct at the time of publication deserves in practice the same retention period. This also applies to tyre models that are no longer sold: a supervisory authority can still ask questions about a model that was withdrawn from the market years ago, as long as vehicles with that tyre are still on the road.

The way data and correspondence are securely stored digitally, and who has access to it, is described on the page on how data and access are secured. That is not a legal answer to the question of whether your retention practice complies, but rather a description of the technical side of retention.

What this means in practice for your business

Most businesses that deal with the tyre passport do not have this documentation as a separate file, but dispersed across email, an ERP system and the administration of a software supplier. It is therefore a necessary step to discuss with that supplier how the origin of data is recorded and how long it remains traceable. On the page how the information in a passport is created describes how this is arranged at tyrepas.eu, as a starting point for that conversation with your own party.

Whether supervision and enforcement apply to your specific business at this moment depends on your role in the supply chain and the type of tyre you sell or purchase. A lawyer or the competent supervisory authority can answer that question for your situation; this article only describes what applies in general terms.

Would you like to know first where your business stands exactly before you build up this file? With a few questions you can see immediately an indication of your situation, free and without obligation.

This article is general information and not legal advice.