The supplier formally registering the product and necessarily established in the Union (or EEA) is solely responsible for the data entered in the database and remains liable, whoever and wherever the data has been input.
Agreements between the importer or authorised representative and the manufacturer established outside the EU are not regulated in the context of the tyre labelling Regulation (EU) 2020/740 (nor of the Framework Labelling Regulation (EU) 2017/1369).
No operator established outside the EU/EEA shall be regarded as a supplier under Regulation (EU) 2020/740.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.