regulations

EU Digital Circularity Vehicle Passport Is Now Law

Regulation (EU) 2026/1738 is now published. It makes the Digital Circularity Vehicle Passport mandatory for covered vehicles from 1 September 2032.

6/24/2026 · 10 min read · InfoDPP

The Digital Circularity Vehicle Passport Is Now Final EU Law

The EU’s new automotive circularity rules are now in force. Regulation (EU) 2026/1738 was published in the Official Journal on 24 July 2026. It entered into force on 13 August 2026, 20 days after publication, and most provisions apply from 1 September 2028.

The Regulation creates a Digital Circularity Vehicle Passport for covered vehicles. The passport obligation in Article 13 applies from 1 September 2032. This is a fixed legal date, not an indicative estimate from a working plan.

Legal status, 20 September 2026: Regulation (EU) 2026/1738 is in force. The passport obligation starts on 1 September 2032. Article 13(6), empowering the Commission to adopt implementing acts, has applied since 14 September 2026. The Regulation requires detailed technical, access, data carrier location and update rules to be adopted by 14 August 2030.

A Separate Passport Regime, Not an ESPR Delegated Act

The Digital Circularity Vehicle Passport does not originate in the Ecodesign for Sustainable Products Regulation. It is established directly by the sector-specific automotive Regulation.

That distinction matters. ESPR, the Battery Regulation and Regulation (EU) 2026/1738 use related digital product information concepts, but each instrument has its own scope, timetable and secondary legislation. A company cannot assume that compliance with one passport automatically satisfies another.

Article 13(1) requires alignment and interoperability with other vehicle-related environmental passports established under EU law and, where possible, integration with them. It specifically names the battery passport under Regulation (EU) 2023/1542, the Environmental Vehicle Passport (EVP) under the Euro 7 Regulation (EU) 2024/1257 and other relevant digital product passports under ESPR. Information already accessible through one of these passports must not be duplicated where interoperability is ensured.

Which Vehicles Are Covered

Article 13 primarily covers new passenger cars and light commercial vehicles in categories M1 and N1 that are placed on the EU market from 1 September 2032. The Article 13 passport duty does not apply to the heavy vehicle and trailer categories covered by the Regulation’s special scope extension in Article 2(3).

Article 2(4) also excludes L-category vehicles from Article 13, while Article 2(5) excludes special-purpose vehicles. Article 2(2) excludes small-series vehicles and other specified categories from the Regulation as a whole. Manufacturers and importers should check these provisions before assigning passport requirements to a model range.

What the Passport Must Contain

Article 13 does not create a generic marketing profile. It links the passport to defined regulatory information, including:

information needed to remove and replace vehicle parts and components under Article 11
information on parts and components containing lead, mercury, cadmium or hexavalent chromium where a legal exemption is used
the declaration of recycled content for plastics and other materials covered by Article 10
the official spare-parts catalogue for the vehicle type concerned

The passport must be free to access. Its data must use open standards and interoperable formats, remain machine-readable, structured and searchable, and avoid dependence on a single vendor. Under Article 13(4), the manufacturer must ensure that the required information is accurate, complete and up to date. Article 13(6) leaves the detailed access conditions, data protection and intellectual property safeguards to implementing acts; it does not itself set out a final matrix of user roles and permissions.

The Wider Automotive Timeline

The passport is one part of a larger regulatory programme:

Date	Requirement
13 August 2026	Regulation enters into force
14 September 2026	Commission empowerment for the Article 13 implementing act begins to apply
1 September 2028	Most provisions of the Regulation apply
1 September 2029	Extended producer responsibility and Article 11 removal and replacement information begin to apply
14 August 2030	Deadline for the Commission’s passport implementing acts
1 September 2032	Digital Circularity Vehicle Passport applies to covered vehicles; first recycled-plastic target applies to relevant new vehicle types
1 September 2036	Second recycled-plastic target applies to relevant new vehicle types

Article 6 sets recycled-content targets for the plastic in covered new vehicle types, not for the total vehicle weight. Plastic in types newly approved from 1 September 2032 must contain at least 15% recycled content by weight from post-consumer plastic waste, rising to 25% for types newly approved from 1 September 2036. Both calculations are subject to the exclusions in Article 6(3). At least 20% of each target must be met using plastic recycled from end-of-life vehicles or parts and components removed during vehicle use. The type-approval dates for these targets must not be confused with the market-placement date that triggers the passport obligation.

What Manufacturers, Importers, Repairers and Recyclers Should Prepare

Vehicle manufacturers

Manufacturers should map the legal source of every future passport field, not create an isolated QR code project. Start by linking the vehicle type to its parts, materials, substance exemptions, recycled-content evidence, removal instructions and official spare-parts catalogue, with a clear version history.

Supplier evidence needs equal attention. Recycled-content declarations and substance information are only reliable if the underlying evidence can be traced to a supplier, material, component and model version.

Importers

Importers need contractually reliable access to the same evidence for vehicles built outside the EU. A finished data export delivered shortly before market placement will rarely be enough if component-level claims must be corrected or audited later.

Repairers, dismantlers and recyclers

These operators are intended users of the passport. They should plan how their systems will identify a vehicle and retrieve its information without creating conflicting copies. Any ability to add or change passport information must follow the rules for third parties to be specified under Article 13(6)(c); the Regulation does not itself give every workshop unrestricted editing rights.

What Is Fixed and What Still Needs Secondary Rules

The Regulation number, publication, entry into force, general application date and the 1 September 2032 passport date are final. Article 13 also establishes the core content categories, the principle of free access, technical requirements and interoperability requirements.

The implementing acts must address the data carrier’s location, technical architecture, access conditions, data processing, updates by third parties and interaction with other passport systems. They must also address passport availability if the responsible manufacturer ceases to exist or stops operating in the EU. These are the implementation details to monitor ahead of the 2030 deadline.

Use the confirmed content requirements and dates to design the data model now, while keeping the technical implementation adaptable until the implementing acts and standards are final.

A Practical Minimum Data Model

Before the implementing acts are available, an automotive team can build a vendor-independent set of supporting records around the legal content already fixed in Article 13:

vehicle category, type, model and version identifiers
component and part identifiers linked to the relevant vehicle version
removal, replacement and dismantling information required by Article 11
restricted-metal exemptions linked to the affected part
recycled-content declarations with material and calculation scope
supplier declarations and supporting evidence with version history
the official spare-parts catalogue and its update history
links to applicable battery passports, Euro 7 Environmental Vehicle Passports and ESPR passports
access roles, publication state and a traceable update record

This is not the final technical schema. It is a foundation independent of any vendor that can be mapped to the implementing rules without rebuilding the underlying evidence.

Official Sources

Start preparing for DPP by organising the data for one product. Try OriginPass.eu to see how you can present it in a digital passport.

← Back to Blog