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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.

· 10 min read · InfoDPP

The Digital Circularity Vehicle Passport Is Now Final EU Law

The EU’s new automotive circularity rules are no longer awaiting publication. Regulation (EU) 2026/1738 was published in the Official Journal on 24 July 2026. It enters 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.

Current status, 3 August 2026: Regulation (EU) 2026/1738 has been adopted and published. The legal obligation and application date are confirmed. The Commission must still define detailed technical, access, location and update rules through implementing acts 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.

The automotive rules do, however, require interoperability. Where relevant, the vehicle passport must be interoperable with, and where possible integrated into, the battery passport, the permanent-magnet passport under the Critical Raw Materials Act and ESPR digital product passports. Information should not be duplicated if it is already available through another interoperable passport.

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).

The Regulation also contains specific scope rules and exemptions for certain special-purpose, small-series and other vehicles. Manufacturers and importers should therefore determine the legal category and applicable provisions before mapping 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:

  1. information needed to remove and replace vehicle parts and components under Article 11
  2. information on parts and components containing lead, mercury, cadmium or hexavalent chromium where a legal exemption is used
  3. the declaration of recycled content for plastics and other materials covered by Article 10
  4. the manufacturer’s official catalogue of spare parts

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. Access rights will differ by information type and user role, which is one of the areas the Commission must specify in implementing acts.

The Wider Automotive Timeline

The passport is one part of a larger regulatory programme:

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

The recycled-plastic targets are also precise. New vehicle types subject to the rule must contain at least 15% post-consumer recycled plastic by weight from 1 September 2032 and 25% from 1 September 2036. At least 20% of the plastic counted toward each target must come from end-of-life vehicles or parts removed during vehicle use.

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. The useful foundation is a versioned link between vehicle type, parts, materials, substance exemptions, recycled-content evidence, removal instructions and the official spare-parts catalogue.

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 workshop, dismantling and treatment systems will resolve a vehicle identifier, retrieve information according to access rights and record updates without creating conflicting copies.

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 fixes the core content categories, free access principle, technical qualities and interoperability direction.

The implementing acts still need to define operational details such as the data carrier’s location, technical architecture, detailed access rights, data processing, updating and the interaction with other passport systems. This is the area to monitor through 2030.

That makes the correct readiness strategy straightforward: use the confirmed legal content and dates to design the data model now, while keeping the technical delivery layer 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 neutral evidence model around the legal content already fixed in Article 13:

  1. vehicle category, type, model and version identifiers
  2. component and part identifiers linked to the relevant vehicle version
  3. removal, replacement and dismantling information required by Article 11
  4. restricted-metal exemptions linked to the affected part
  5. recycled-content declarations with material and calculation scope
  6. supplier declarations and supporting evidence with version history
  7. the official spare-parts catalogue and its update history
  8. links to applicable battery, permanent-magnet and ESPR passports
  9. 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


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