The European Union is expanding its Digital Product Passport framework to cover automotive software, diagnostics records, and telemetry data, imposing new traceability and data governance obligations on vehicle manufacturers and their supply chains ahead of phased implementation beginning in 2027.
Background
The EU's Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) entered into force in July 2024, establishing the legal foundation for the Digital Product Passport - a structured digital record designed to consolidate lifecycle, sustainability, and compliance data for products sold in the EU market. Under this framework, the European Commission issues product-specific delegated acts defining the exact data fields, access rules, and compliance timelines for each sector.
The automotive industry now faces a layered set of overlapping passport obligations. The Battery Regulation (EU) 2023/1542 mandates a digital Battery Passport for all electric vehicle batteries and industrial batteries above 2 kWh capacity from 18 February 2027, making it the first legally binding product passport. According to law firm Hogan Lovells, the Battery Passport serves as a live pilot for the broader DPP rollout across other sectors.
Separately, the proposed EU End-of-Life Vehicles (ELV) Regulation introduces a mandatory "Circularity Vehicle Passport," described by the European Commission as a digital tool for accessing information on vehicle composition, component traceability, and recyclability. According to Circularise, the proposed regulation also includes an Environmental Vehicle Passport, which must capture battery health and degradation metrics, real-world emissions data, and lifecycle environmental impacts - data sets that directly intersect with vehicle diagnostics and software-defined vehicle architectures.
Details
The European Commission's ESPR Working Plan 2025-2030, adopted on 15 April 2025, confirms the phased priority list for DPP delegated acts, with vehicles formally indicated in the 2028-2029 wave of sectoral obligations. However, the automotive sector is already subject to DPP requirements through the Battery Regulation's February 2027 deadline, and tyre-specific delegated acts are expected to be finalized in 2027, with mandatory compliance 18 to 24 months after publication, according to analysis from MyProductPassport.
The scope of data capture is extensive. According to Informatica, 60-80% of the data required for DPP compliance must come from suppliers across multiple tiers, many of which operate with differing technical capabilities. A typical automotive OEM sources from hundreds to thousands of direct suppliers across dozens of countries, according to Fiegenbaum Solutions, making interoperable data formats a prerequisite rather than an option.
For over-the-air (OTA) software updates - a growing feature in modern vehicles - the DPP framework intersects with existing cybersecurity mandates. UN Regulation No. R156 on Software Update Management Systems (SUMS) has been in force for new vehicle type approvals in the EU since 2022, requiring documented OTA update integrity, authentication, and rollback processes. DPP data requirements are expected to extend this obligation by mandating that software version histories, diagnostic trouble codes, and update logs become part of the persistent vehicle data record accessible to regulators and authorized parties.
The EU Central DPP Registry is scheduled to go live on 19 July 2026, according to Hogan Lovells, creating the foundational infrastructure into which sector-specific passports - including the Battery Passport and, later, vehicle-level passports - will feed. Industry analysts at Informatica estimate a 12-18 month lead time to build the data infrastructure necessary for DPP compliance, underscoring the urgency for OEMs and Tier-1 suppliers that have yet to begin implementation.
Bosch has publicly launched a cloud-based Digital Battery Passport solution combining static vehicle data with dynamic telemetry, designed to support EU Battery Regulation compliance. Major automakers including Audi and Kia are also running active pilot programs to establish data collection processes across their supply chains, according to Informatica.
Outlook
With the EU Central DPP Registry set to go live in July 2026 and Battery Passport compliance mandatory by February 2027, the timeline for foundational automotive data governance is effectively immediate. ISO/IEC Joint Technical Committee 5 on Digital Product Passports, launched in April 2026, is expected to deliver its first global standards framework from 2028, further shaping how diagnostic, telemetry, and software update data must be structured and shared across borders. Supply chain professionals and procurement leads at OEMs and Tier-1 suppliers face the dual challenge of building interoperable data architectures while managing compliance across a regulatory landscape that will continue expanding through 2030.
