Each supplier is responsible for registering tyre types, units of which it places on the market.
Each importer placing on the market tyres of a manufacturer located outside the EU/EEA, is considered as a supplier, independently of the fact that an authorised representative has been designated.
The product registration works as follows:
(a) the first time a supplier makes available a unit of a tyre type on the Union market, it must have already registered all required information in EPREL, as stated in the applicable rules. This is the case even if units of the same tyre type have already been placed on the Union market by another economic operator.
(b) If two separate suppliers place on the market units of the same tyre type, there should be two separate registrations in EPREL. The QR code on the label of each tyre unit unequivocally points to the registration and, thus, to the specific supplier.
In summary: a tyre can be placed on the EU market by any of the following categories of economic operators: EU/EEA manufacturers, authorized representatives and importers in the case of manufacturers not established in the EU/EEA. In case more than one economic actor acts as an importer, each of them is to fulfil the supplier’s obligations in relation to those units of the tyre type they first place on the EU market.
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.