@tracepass/dpp-schemas 1.0.0 → 1.0.2

package/templates/tyres.json

@@ -133,7 +133,8 @@
         "article": "ESPR 2024/1781 Art. 9(2); ISO/IEC 15459",
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -243,7 +244,8 @@
         "article": "ESPR 2024/1781 Art. 9(2)",
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -352,7 +354,8 @@
         "article": "ESPR 2024/1781 Art. 9(2)",
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -568,7 +571,8 @@
         "article": "ESPR 2024/1781 Art. 9(2)",
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -674,7 +678,8 @@
         "article": "ESPR 2024/1781 Art. 9(2)",
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -769,7 +774,8 @@
         "article": "ESPR 2024/1781 Art. 9(2)",
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -1603,7 +1609,8 @@
         "article": "Regulation (EU) 2020/740 Annex II",
         "instrument": "32020R0740",
         "provision": "Annex II",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "It governs the tyre label's format and content. The production period is part of how a tyre type is identified for labelling and for the EPREL entry, not a datum the Regulation requires to be published as product data."
       },
       "aiHints": {
         "alternateNames": [
@@ -1712,7 +1719,8 @@
         "article": "ESPR 2024/1781 Art. 9(2)",
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -2180,7 +2188,8 @@
         "article": "ESPR 2024/1781 Art. 9(2)",
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -2289,7 +2298,8 @@
         "article": "ESPR 2024/1781 Art. 9(2)",
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -3905,7 +3915,8 @@
       "regulationRef": {
         "article": "ESPR delegated act (tyres)",
         "instrument": "32024R1781",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -4624,7 +4635,8 @@
         "article": "Regulation (EU) 2020/740 Annex I Part B",
         "instrument": "32020R0740",
         "provision": "Annex I",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "Part B defines the wet grip CLASSES, and what the Regulation requires is that the class appear on the tyre label and in the product information sheet, with the supporting data in the EPREL product database. The underlying index is the measured input to that class rather than the declared value."
       },
       "aiHints": {
         "alternateNames": [
@@ -5032,7 +5044,8 @@
         "article": "Regulation (EU) 2020/740 Annex I Part D; UNECE Reg. 117",
         "instrument": "32020R0740",
         "provision": "Art. 4 + Annex I (3PMSF snow-grip pictogram where applicable)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "Annex I Part D requires snow grip to be tested per Annex 7 to UNECE Regulation No 117, and a tyre meeting the minimum index is classified for severe snow use and carries the 3PMSF PICTOGRAM on the tyre label. The duty is discharged by that pictogram, not by publishing a value."
       },
       "aiHints": {
         "alternateNames": [
@@ -5139,7 +5152,8 @@
         "article": "Regulation (EU) 2020/740 Annex I Part E; ISO 19447",
         "instrument": "32020R0740",
         "provision": "Art. 4 + Annex I (ice-grip marking, C1 tyres, per ISO 19447)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "Annex I Part E requires ice grip to be tested by reliable, accurate and reproducible methods reflecting the state of the art, and a qualifying C1 tyre carries the ice-grip PICTOGRAM on the label. Like snow grip, the obligation is a mark rather than a published figure."
       },
       "aiHints": {
         "alternateNames": [
@@ -5247,7 +5261,8 @@
       "regulationRef": {
         "article": "Regulation (EU) 2024/1257 (Euro 7); UNECE TFTA methodology",
         "instrument": "32024R1257",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "Euro 7 (Reg (EU) 2024/1257) defines tyre abrasion as the mass of material lost and emitted into the environment, and provides for abrasion LIMITS per tyre class — but those limits and their measurement method come from UN WP.29, due 1 July 2026 for C1, 1 April 2028 for C2 and 1 April 2030 for C3, with a Commission delegated act only as a fallback. There is no limit to meet and no prescribed method to report against yet."
       },
       "aiHints": {
         "alternateNames": [
@@ -5355,7 +5370,8 @@
       "regulationRef": {
         "article": "Regulation (EU) 2024/1257; UNECE TFTA convoy method",
         "instrument": "32024R1257",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "A relative abrasion index depends on the same pending UN WP.29 method as the absolute rate. Until that method exists an index has no defined basis, and Euro 7 is a type-approval regulation that would bind the vehicle or tyre approval rather than a product passport."
       },
       "aiHints": {
         "alternateNames": [
@@ -5521,7 +5537,8 @@
       "regulationRef": {
         "article": "Regulation (EU) 2024/1257; UNECE WP.29",
         "instrument": "32024R1257",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "The method — convoy-on-road versus laboratory drum — is exactly what the pending UN WP.29 work under Euro 7 must settle. Naming a method today records the basis of a voluntary measurement rather than compliance with a prescribed one."
       },
       "aiHints": {
         "alternateNames": [
@@ -5875,7 +5892,8 @@
       "regulationRef": {
         "article": "Regulation (EU) 2024/1257 (Euro 7) - pending delegated act",
         "instrument": "32024R1257",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "Euro 7's recital ties tyre abrasion to the Union objective of reducing microplastics released into the environment by 30% by 2030, but the Regulation creates no emission CLASS for tyres. Any grading would follow the pending WP.29 limits."
       },
       "aiHints": {
         "alternateNames": [
@@ -6087,7 +6105,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(a); delegated act (tyres)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(a)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6196,7 +6215,8 @@
       "regulationRef": {
         "article": "ESPR delegated act (tyres)",
         "instrument": "32024R1781",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6305,7 +6325,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(a)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(a)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6414,7 +6435,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(a)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(a)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6523,7 +6545,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(b)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(b)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6629,7 +6652,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(b)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(b)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6734,7 +6758,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(b)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(b)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6839,7 +6864,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(b)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(b)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -7062,7 +7088,7 @@
           "REACH candidate list",
           "hazardous substances"
         ],
-        "expectedFormat": "Array of objects with substance_name, cas_number, concentration_percentage, component_location",
+        "expectedFormat": "Array of objects: [{substanceName: 'DEHP', casNumber: '117-81-7', concentrationPercent: 0.15, locationInProduct: 'Sidewall compound'}]",
         "extractionPriority": 8
       }
     },
@@ -7158,7 +7184,8 @@
       "regulationRef": {
         "article": "REACH evaluation; ECHA substance evaluation",
         "instrument": "32006R1907",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "REACH creates no general duty to publish a substance concentration as product data. Its disclosure duties are Art. 33 communication — to business recipients, and to consumers ON REQUEST within 45 days, for candidate-list substances above 0.1% w/w, with a minimum content of the substance NAME — plus SCIP notification to ECHA. Neither is discharged by publishing a concentration here. Check the current candidate list and Annex XVII entries before treating this field as compliance-bearing."
       },
       "aiHints": {
         "alternateNames": [
@@ -7481,7 +7508,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(a); PEF methodology",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(a)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -7590,7 +7618,8 @@
       "regulationRef": {
         "article": "ESPR 2024/1781; EU PEF Guide",
         "instrument": "32024R1781",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -7695,7 +7724,8 @@
       "regulationRef": {
         "article": "Regulation (EU) 2020/740 informational",
         "instrument": "32020R0740",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "Reg (EU) 2020/740 requires the fuel efficiency CLASS (Annex I Part A) on the label, in the product information sheet and in EPREL. A lifetime fuel-saving estimate is a derived marketing figure that the Regulation neither defines nor requires, and technical promotional material must show the label rather than substitute for it."
       },
       "aiHints": {
         "alternateNames": [
@@ -7799,7 +7829,8 @@
       "regulationRef": {
         "article": "Regulation (EU) 2020/740 informational",
         "instrument": "32020R0740",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "A derived estimate, not a regulated parameter. What Reg (EU) 2020/740 mandates is the fuel efficiency class on the label, the product information sheet and the EPREL entry."
       },
       "aiHints": {
         "alternateNames": [
@@ -8120,7 +8151,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(a); delegated act (tyres)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(a)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -8328,11 +8360,11 @@
       "sortOrder": 67,
       "defaultAccessLevel": "public",
       "regulationRef": {
-        "article": "Directive 89/459/EEC",
-        "instrument": "31989L0459",
+        "article": "Roadworthiness Dir. Annex I",
+        "instrument": "32014L0045",
         "kind": "legislation",
         "provision": "Dir. 2014/45/EU Annex I — roadworthiness test requirement on the vehicle in use",
-        "description": "Minimum tread depth is checked at periodic vehicle inspection; it is not a manufacturer disclosure. Dir. 89/459/EEC is superseded."
+        "description": "Minimum tread depth is a roadworthiness INSPECTION item — Dir. 2014/45/EU Annex I lists 'tyre tread depth not in accordance with the requirements' as a test defect, checked on the vehicle in use. It is not a tyre-manufacturer disclosure. Verified against the EUR-Lex text. (The previous citation, Dir. 89/459/EEC, is the historic tread-depth instrument and is not the operative one for this duty.)"
       },
       "aiHints": {
         "alternateNames": [
@@ -8651,7 +8683,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(c); UNECE Reg. 108/109",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(c)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -8966,7 +8999,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(c)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(c)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -9074,7 +9108,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(c)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(c)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -9290,7 +9325,8 @@
         "article": "ESPR 2024/1781 Art. 7(2)(c)",
         "instrument": "32024R1781",
         "provision": "Art. 7(2)(c)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -10540,9 +10576,10 @@
       "sortOrder": 88,
       "defaultAccessLevel": "public",
       "regulationRef": {
-        "article": "Regulation (EC) No 661/2009",
-        "instrument": "32009R0661",
-        "kind": "legislation"
+        "article": "Regulation (EU) 2019/2144 Art. 6",
+        "instrument": "32019R2144",
+        "kind": "legislation",
+        "description": "TPMS is required by Reg (EU) 2019/2144 (General Safety Regulation), which repealed Reg (EC) 661/2009 with effect from 6 July 2022; references to the old regulation are construed as references to this one. The duty binds the VEHICLE's type-approval, not the tyre, and is discharged through that approval rather than through tyre product data."
       },
       "aiHints": {
         "alternateNames": [
@@ -10963,7 +11000,8 @@
       "regulationRef": {
         "article": "ESPR 2024/1781 implementing acts",
         "instrument": "32024R1781",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -11071,7 +11109,8 @@
         "article": "ESPR 2024/1781 Art. 10",
         "instrument": "32024R1781",
         "provision": "Art. 10",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR Art. 10 governs the passport's TECHNICAL design — data carrier, unique identifiers, access rights, availability — not which product data must be published. The substantive obligation still arrives via an Art. 4 delegated act, and none is adopted for this category. Anticipated; voluntary today. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -11267,7 +11306,8 @@
         "article": "ESPR 2024/1781 Art. 10(3)",
         "instrument": "32024R1781",
         "provision": "Art. 10(3)",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR Art. 10 governs the passport's TECHNICAL design — data carrier, unique identifiers, access rights, availability — not which product data must be published. The substantive obligation still arrives via an Art. 4 delegated act, and none is adopted for this category. Anticipated; voluntary today. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -11375,7 +11415,8 @@
         "article": "ESPR 2024/1781 Art. 9-10",
         "instrument": "32024R1781",
         "provision": "Art. 9-10",
-        "kind": "legislation"
+        "kind": "legislation",
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [