The European Union is expanding its Digital Product Passport regime to cover automotive software, vehicle diagnostics data, and end-of-life traceability, accelerating the regulatory push beyond physical components ahead of compliance deadlines beginning in 2027.
Background
The Digital Product Passport (DPP) is anchored in Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR), which entered into force on 18 July 2024. The framework mandates a structured digital record-accessible via QR code, RFID, or NFC-containing a product's material composition, carbon footprint, repairability data, and end-of-life recycling instructions. Under the ESPR, the European Commission adopts sector-specific delegated acts defining precise data requirements for each product category.
The automotive sector faces DPP obligations from multiple regulatory directions simultaneously. The proposed EU End-of-Life Vehicle Regulation, currently in trilogue negotiations, includes dedicated provisions for a Digital Circularity Vehicle Pass and digital battery and component passports, intended to improve traceability and prevent improper disposal or illegal export. According to legal analysis by Hogan Lovells, the Battery Regulation (EU) 2023/1542 and the proposed End-of-Life Vehicle Regulation already include dedicated DPP requirements separate from but aligned with the ESPR framework.
Details
The first hard compliance deadline falls on the EV battery supply chain. From 18 February 2027, every electric vehicle battery, industrial battery with capacity above 2 kWh, and light means of transport battery placed on the EU market must carry a Battery Passport accessible through a QR code, under EU Battery Regulation (2023/1542). The Battery Passport must include state of health, capacity, carbon footprint, material composition, sourcing data for critical raw materials such as cobalt, lithium, and nickel, and end-of-life recycling instructions.
For automotive OEMs, the compliance burden extends across the supply chain. According to Informatica's DPP implementation analysis, 60-80% of the data required for an automotive OEM's Battery Passport must come from suppliers across multiple tiers, from Tier 1 battery cell manufacturers down to Tier 3 raw material miners and recyclers. Industry analysts estimate a 12-18-month implementation timeline for companies to establish the necessary data infrastructure. A survey cited by Supercode indicates 82% of companies are currently unprepared for DPP requirements, with the automotive supply chain facing particular exposure given the complexity of multi-tier data flows.
On the standardization front, the European Standardization Organisations CEN and CENELEC are developing harmonized standards to create a functioning IT ecosystem for DPP deployment, while industry consortia including OPC Foundation, Industrie 4.0, and DPP4.0 are working to ensure interoperability between data ecosystems. ISO/IEC Joint Technical Committee 5 on Digital Product Passports was launched in April 2026, with substantive deliverables expected from 2028. The EU Central DPP Registry is scheduled to go live on 19 July 2026, providing the infrastructure for market surveillance authorities to verify passport existence and authenticity.
The automotive sector also faces data governance complexity where DPP requirements intersect with existing EU data privacy rules. Under the ESPR framework, access to DPP data is tiered: some information is publicly accessible, while data such as detailed battery dismantling instructions and component-level diagnostics is restricted to notified bodies, market surveillance authorities, repairers, remanufacturers, and recyclers with legitimate interest.
Outlook
Vehicles as a product category are expected to face formal ESPR delegated act obligations in the 2028-2029 timeframe according to the Commission's ESPR Working Plan 2025-2030. However, the Battery Passport deadline of February 2027 means automotive OEMs and their Tier 1 and Tier 2 suppliers must have data infrastructure operational before broader vehicle-level requirements take effect. The ESPR Working Plan 2025-2030, adopted on 15 April 2025, sets indicative targets for delegated act publication across product categories, with vehicles listed in the second phase of the decade-long rollout. Companies that have not begun supplier data engagement and system integration risk market exclusion, as products sold in the EU without compliant DPPs after applicable deadlines face market exclusion through CE marking denial.
