EU Vehicle Circularity Regulation (EU) 2026/1738

The second product passport in EU law

Vehicle manufacturing, components and end-of-life vehicles — Regulation (EU) 2026/1738 and the circularity vehicle passport.

What Regulation (EU) 2026/1738 covers

The regulation was signed on 8 July 2026, published in the Official Journal on 24 July and entered into force on 13 August 2026. It replaces the End-of-Life Vehicles Directive 2000/53/EC and the 3R type-approval Directive 2005/64/EC with a single directly applicable act covering vehicle circularity from design through to end-of-life treatment. Article 13 introduces the Digital Circularity Vehicle Passport.

One distinction worth making straight away. The phrase "digital product passport" does not appear once in the entire text. The circularity passport is a sibling instrument, not a variety of the ESPR passport. Article 13(1) does require it to be aligned, interoperable and, where possible, integrated with the battery passport under Article 77 and with passports under the ESPR. So the legislator is not building separate passports; it is building one connected layer of data.

See how the digital product passport works under the ESPR, what the Battery Regulation requires, and the full timeline of deadlines. If you make components rather than vehicles, see also what this means for sub-suppliers.

Core requirements

EU Vehicle Circularity Regulation (EU) 2026/1738

Circularity passport

From 1 September 2032 every vehicle placed on the market must have a Digital Circularity Vehicle Passport. Access to it is free of charge.

Interoperability by law

Article 13(1) requires alignment and interoperability with the battery passport and with ESPR passports. Information already accessible through one of them is not to be duplicated.

Recycled plastic

15% post-consumer recycled plastic by weight for new types approved from 1 September 2032, rising to 25% from 1 September 2036. At least a fifth of it must come from end-of-life vehicles.

No heavy metals, plus a parts catalogue

New types approved from 1 September 2032 may not contain lead, mercury, cadmium or hexavalent chromium. The passport also carries the official spare-parts catalogue for the vehicle type.

Key dates

13 August 2026

The regulation enters into force, on the twentieth day after publication. Article 53 starts applying on the same day — and it amends Annex I of the Battery Regulation.

14 September 2026

A tranche of some nineteen provisions starts applying, including Article 13(6): the Commission’s power to adopt the implementing acts for the passport.

1 September 2028

General application of the regulation.

14 August 2030

Deadline for the Commission to adopt the Article 13(6) acts: access conditions, protection of intellectual property, the location of the data carrier, and what happens to the passport if the manufacturer ceases to exist.

1 September 2032

The passport obligation itself. The same date carries the 15% recycled plastic requirement, the ban on the four heavy metals, and the 85% recyclability and 95% recoverability thresholds by mass.

The circularity vehicle passport

Question Mark Section Supporting Image

An electronic record for each vehicle, created by Article 13 of Regulation (EU) 2026/1738. It holds the Article 11 information, the parts containing lead, mercury, cadmium or hexavalent chromium under the Article 5(5) derogation, the declaration on the share of recycled plastic and the Article 10(1) materials, and the official spare-parts catalogue. Access is free of charge.

From 1 September 2032, for every vehicle placed on the market. The Commission’s power to write the technical rules, however, switches on as early as 14 September 2026, and the acts themselves are due by 14 August 2030.

No, and the difference is not cosmetic. The phrase "digital product passport" does not occur once in the text. The circularity passport is a standalone instrument that is legally required to interoperate with ESPR passports and with the battery passport, but it is not a variety of either. Describing it as "the DPP for cars" is wrong on the face of the regulation.

Scope phases in under Article 2: categories M1 and N1 from the outset, special-purpose M1 and N1 from 1 September 2029, and M2, M3, N2, N3 and O from 1 September 2031. Take care not to merge those dates with the passport obligation itself, which starts on 1 September 2032.

Article 13(1) names the Article 77 passport of Regulation (EU) 2023/1542 explicitly. Article 13(3) adds that where information is already accessible through it, that information is not to be duplicated in the circularity passport, provided interoperability is ensured. An electric vehicle will carry two linked records, not two independent ones.

The obligation sits with the manufacturer placing the vehicle on the market. The data, though, comes from the supply chain. If you make parts, you are not named in the regulation, but the data request will reach you through a contract, usually well before your customer’s deadline. We covered that [here](/blog/no-regulation-names-you-customer-wants-the-data).

A business team in a working meeting — consultation on implementing a digital product passport.
Centralised DataIntelligent Systems
Centralised DataIntelligent Systems
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