The European Union is pressing ahead with mandatory Digital Product Passports (DPPs) for the automotive sector. The first binding requirements for vehicle batteries take effect on 18 February 2027, with broader obligations covering software, diagnostics data, and vehicle components expected under forthcoming delegated acts.
Background
The DPP framework is anchored in Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR), which entered into force in July 2024. ESPR establishes the legal basis for mandatory digital lifecycle records across product categories. Under the regulation, a DPP is a structured, machine-readable digital record linked to a physical product. It consolidates verified data on materials, environmental impact, repairability, and end-of-life handling, accessible via standardized data carriers such as QR codes or RFID tags.
The automotive sector faces obligations under several converging instruments. The EU Battery Regulation (Regulation (EU) 2023/1542) mandates a Battery Passport for all industrial and electric vehicle batteries with a capacity exceeding 2 kWh placed on the EU market from 18 February 2027. Separately, the proposed End-of-Life Vehicle Regulation introduces a dedicated vehicle DPP - the Environmental Vehicle Passport - covering component materials, recyclability data, and CO₂ performance metrics. The EU Data Act, which came into full effect on 12 September 2025, adds a further layer, requiring OEMs to make vehicle-generated data accessible to users and authorized third parties, including independent repair shops and insurers.
Compliance Challenges for OEMs and Tier-1 Suppliers
The data integration demands are substantial. According to Informatica, 60-80% of the information required for an automotive DPP originates from suppliers across multiple tiers, many of which operate with incompatible data systems. A typical automotive OEM sources components from 500 to 5,000 direct suppliers across 30 to 50 countries, according to Fiegenbaum Solutions. Product data is frequently fragmented across ERP, PLM, and supply chain management systems, with no unified source of truth.
Industry analysts estimate a 12 to 18 month timeline to build the data infrastructure necessary for DPP compliance, placing pressure on manufacturers that have not yet launched programs. The EU Central DPP Registry is scheduled to go live on 19 July 2026, according to Hogan Lovells, providing the foundational registry for unique product identifiers ahead of the first binding deadlines.
Interoperability remains a central technical concern. The CIRPASS-2 project delivered the EU DPP Core Ontology in March 2025, now serving as the reference framework for sector pilots in textiles, electronics, tyres, and construction. GS1 Digital Link, using GTINs as unique identifiers, has been recognized as a valid identifier pattern under ESPR. The newly established ISO/IEC Joint Technical Committee 5 on Digital Product Passports, announced on 20 April 2026, is expected to deliver global interoperability standards from 2028.
For connected vehicles specifically, the EU Data Act requires OEMs to enhance data transparency and implement robust cybersecurity controls. Third-party DPP service providers - platforms that host passport data and manage access - will be subject to certification schemes under delegated acts. According to Hogan Lovells, such certified providers must "ensure compliance with access rules, standards, and cybersecurity obligations." Data sovereignty adds further complexity: EU GDPR mandates European data localization, while other jurisdictions impose conflicting storage requirements, forcing multinationals into difficult architectural trade-offs.
Industry associations including Germany's ZVEI and VDMA, as well as AmCham EU and JBCE, have voiced support for the DPP's objectives while cautioning against excessive compliance complexity, high costs, and legal uncertainty - particularly for smaller suppliers and globally integrated supply chains.
Outlook
The European Commission is expected to adopt delegated and implementing acts under ESPR defining detailed DPP data requirements between 2027 and 2028. At that point, automotive software versioning and diagnostics data are anticipated to come within scope. Products sold in the EU without compliant passports face market exclusion through denial of CE marking. As the first automotive deadline - the Battery Passport - draws closer, OEMs and Tier-1 suppliers face mounting pressure to establish interoperable data pipelines capable of scaling to cover additional vehicle systems once sector-specific delegated acts are finalized.
