ELV Regulation (EU) 2026/1738: the vehicle digital circularity passport
Regulation (EU) 2026/1738 of 8 July 2026 on end-of-life vehicles repeals Directives 2000/53/EC and 2005/64/EC and introduces a digital circularity passport for every vehicle. It applies from 1 September 2028, the passport becomes mandatory on 1 September 2032, and the implementing acts are due by 14 August 2030. Obligations, recycled content targets and deadlines in detail.
ELV Regulation (EU) 2026/1738: the vehicle digital circularity passport
Key takeaways
On 8 July 2026 the Parliament and the Council adopted Regulation (EU) 2026/1738 on circularity requirements for vehicle design and on the management of end-of-life vehicles. It was published on 24 July 2026. It repeals the End-of-Life Vehicles Directive 2000/53/EC and the recyclability type-approval Directive 2005/64/EC, replacing both with directly applicable rules.
Three dates matter in practice. The Regulation applies from 1 September 2028. Extended producer responsibility for vehicles starts on 1 September 2029. And from 1 September 2032 every vehicle placed on the market must have a digital circularity passport (Article 13).
That makes automotive the second sector after batteries whose product passport comes not from the Ecodesign Regulation but from its own sectoral act. The circularity passport is neither a second battery passport nor an ESPR passport: it is a passport of its own, with an explicit duty to fit the others.
If you need the fundamentals of the passport first, start with Digital product passport in 15 minutes.
What the ELV Regulation legally is
The full title states the Regulation’s dual character: it governs the design of vehicles and the management of end-of-life vehicles. It therefore rests on two legal bases - Article 114 TFEU (internal market) for the design part and, for Articles 14 to 36, Article 192(1) TFEU (environment).
It amends four other acts:
- Regulation (EU) 2023/1542 (Batteries) - Annex I is amended in accordance with Annex XII of the new Regulation; this Article 53 already applies from 13 August 2026,
- Regulation (EU) 2019/1020 (market surveillance) - Annex II points 10 and 11 are deleted,
- Regulation (EU) 2018/858 and Regulation (EU) No 168/2013 (type approval of motor vehicles and of L-category vehicles) - Annex II of both is amended, but only from 1 September 2032.
An end-of-life vehicle act touching the Batteries Regulation is not a detail: it is the point where the vehicle and battery regimes converge on the data side. If you already know the battery passport, its structure is in Battery passport: EU requirements and timeline.
Which vehicles it covers
Article 2 phases the scope in by vehicle category and date:
| From | Vehicles covered |
|---|---|
| 1 September 2028 | Vehicles and end-of-life vehicles of categories M1 and N1 (passenger cars and light commercial vehicles) |
| 1 September 2029 | Special purpose vehicles of categories M1 and N1 |
| 1 September 2031 | Categories M2, M3, N2, N3 and O (buses, heavy commercial vehicles, trailers), including special purpose vehicles |
| 1 September 2031 | Category L under Regulation (EU) No 168/2013 (motorcycles, mopeds, quads) |
Article 2(2) excludes, among others, small series vehicles, vehicles designed for the armed forces, vehicles for civil protection, fire services, police and emergency medical services (category L), vehicles of historical interest within the meaning of Article 3(7) of Directive 2014/45/EU together with the parts needed to preserve them, vehicles of special cultural interest recognised under the procedure in Annex II, and caravan trailers.
The vehicle digital circularity passport (Article 13)
This is the core of the Regulation for anyone working with product passports.
From when, and whose duty
From 1 September 2032 every vehicle placed on the market must have a digital circularity passport. The passport is accessible free of charge. Under Article 13(4), the producer placing the vehicle on the market is responsible for the information being correct, complete and up to date.
What the passport contains
Article 13(2) lists four items:
- the information referred to in Article 11 - the standardised information on removing and replacing parts, components and materials (Annex VI),
- information on vehicle parts containing lead, mercury, cadmium or hexavalent chromium under the exemption in Article 5(5),
- the declaration of recycled content of plastic and of the materials listed in Article 10(1),
- the official spare parts catalogue for the vehicle type concerned.
The fourth item is the most unusual. A legally mandated, freely accessible spare parts catalogue per vehicle type reaches into a business model rather than merely imposing a data duty - and it meshes with repair law, see Right to repair: the EU directive.
Technical requirements
Article 13(5) requires all information in the circularity passport to
- be based on open standards,
- be developed in an interoperable format,
- be transferable through an open interoperable data exchange network without vendor lock-in,
- be machine-readable, structured and searchable.
The prohibition of vendor lock-in is written into the legal text. Anyone selecting a vehicle data platform today should treat exportability as a legal requirement rather than a convenience.
Relationship to the other passports
Article 13(1) requires the circularity passport to be aligned with, interoperable with and where possible integrated into other vehicle-related environmental passports under Union law. It names:
- the battery passport under Article 77 of Regulation (EU) 2023/1542,
- the passport referred to in Article 3(68) of Regulation (EU) 2024/1257 (Euro 7),
- other relevant passports under Regulation (EU) 2024/1781 (ESPR).
Paragraph 3 matters for implementation planning: where the required information is already accessible through one of those other passports, it need not additionally be included in the circularity passport - provided interoperability is ensured. The Regulation does not demand duplicated data; it demands a data architecture.
What is still missing
The operational rules do not exist yet. Under Article 13(6) the Commission must adopt implementing acts by 14 August 2030 covering:
- the type and basic requirements of the technical solution for access, without excluding any particular technology,
- technical requirements for design and deployment, including alignment and interoperability with other passports, storage and processing of the information, and the availability of the passport after the responsible producer ceases to exist or ceases trading in the Union,
- input, modification and updating of information by third parties other than the producer,
- access conditions, including the right of access and the relevant data protection and intellectual property rules,
- the location of the data carrier or another identifier enabling access.
The empowerment itself already applies from 14 September 2026. In practice: the data requirements are in the law, the access technology comes later. Starting now means working on content, not on the data carrier.
Design requirements: rates, recycled content, dismantlability
Reusability, recyclability, recoverability (Article 4)
Every vehicle of a type type-approved from 1 September 2032 under Regulation (EU) 2018/858 must be designed to be at least 85 % reusable or recyclable by mass and at least 95 % reusable or recoverable by mass. To achieve this, producers must collect data from the entire supply chain - the nature and mass of all materials used - establish procedures to verify the accuracy and completeness of supplier information, and document the material breakdown.
Minimum recycled plastic content (Article 6)
| Type-approved from | Share of post-consumer recycled plastic |
|---|---|
| 1 September 2032 | 15 % by weight |
| 1 September 2036 | 25 % by weight |
At least 20 % of that target must be met with plastics recycled from end-of-life vehicles or from parts removed during the use phase - genuine closed-loop material within the sector, not arbitrary post-consumer feedstock. Elastomers from tyres and thermosets other than polyurethane foam used for upholstery are excluded.
The recycled content must have been recycled in a facility in the Union; from 14 August 2030 also in a third-country facility, provided it meets the requirements of Annex XIII. The Commission must adopt the calculation and verification methods by 31 August 2028, and by 30 September 2028 report to the Parliament and the Council on the expected effects on world trade and on the Union recycling and automotive industries.
Design for easy removal (Article 7)
For types type-approved from 1 September 2032, removal of the parts listed in Annex VIII Part C during the waste phase must not be impeded. Explicitly, electric vehicle batteries, their battery packs and electric drive motors must be easily and non-destructively removable and replaceable in both the use phase and the waste phase.
Declaration of recycled content (Article 10)
Separately from the Article 6 target there is a pure reporting duty. Producers must declare, for each new vehicle type, the recycled content of:
- neodymium, dysprosium, praseodymium, terbium, samarium, nickel, cobalt and boron in permanent magnets in electric drive motors,
- aluminium and its alloys,
- magnesium and its alloys,
- steel and its alloys,
- plastics.
The declaration must state, for each material share and for plastic components weighing more than 100 grams, whether the material was recycled from pre-consumer or post-consumer waste. The duty bites for types approved from the first day of the month twelve months after adoption of the relevant calculation methods, and it falls away for a material once an Article 6 target has become applicable to it. Type-approval authorities verify that the documentation was submitted and contains the information.
This list is the real data task. Recycled content per material and per component above 100 grams cannot be reconstructed after the fact - it has to originate in the supply chain. The methodologically identical problem is worked through in Calculating a product carbon footprint step by step.
Extended producer responsibility for vehicles
From 1 September 2029 producers bear extended producer responsibility for vehicles they make available on the market for the first time within a Member State’s territory - even where the vehicle was previously made available in another Member State. The scheme must be consistent with Articles 8 and 8a of the Waste Framework Directive 2008/98/EC.
The responsibility includes ensuring that vehicles which have become end-of-life vehicles are collected under Article 23 and treated under Article 26, and that waste managers meet the targets in Article 33.
Particularly relevant on the data side is fee modulation under Article 21. Where obligations are met collectively, producer responsibility organisations must adjust producers’ financial contributions taking account of at least:
- the weight of the vehicle excluding electric vehicle batteries,
- the recyclability and reusability of the vehicle type, based on the Article 4 information submitted to the type-approval authority,
- the time needed to dismantle the vehicle at an authorised treatment facility, in particular for parts that must be removed before shredding,
- the share of materials and substances that prevent high-quality recycling,
- the percentage of recycled content of the materials listed in Articles 6 and 10,
- the presence and quantity of substances referred to in Article 5(4).
Four of the six criteria therefore draw on exactly the data that belongs in the circularity passport. Here the passport is not a reporting duty but a cost item. The underlying EPR mechanics are described in Extended producer responsibility (EPR).
Treatment and targets
- From 1 September 2029 authorised treatment facilities must remove the parts listed in Annex VIII Part C before shredding or compacting, once the depollution measures under Article 28 are complete. Parts with reuse, remanufacturing or refurbishment potential must be removed non-destructively - unless the facility demonstrates disproportionate economic costs not offset by the expected revenue.
- From 1 January 2030 the Article 33 targets apply: at least 95 % of the average vehicle weight per year reused and recovered, and at least 85 % reused and recycled - in both cases excluding batteries.
- From 1 January 2032 an annual plastics recycling target of at least 30 % of the average total weight of plastics from end-of-life vehicles is added.
- From 1 September 2029 heavy and light shredder fractions containing non-inert waste may no longer be landfilled where they exceed the limits in Annex VIII Part G point 2(d) and (e).
For the last owner, handing over an end-of-life vehicle remains free of charge (Article 24), unless the vehicle is missing essential parts or contains waste that was added to it.
Timeline at a glance
| Date | What happens |
|---|---|
| 8 July 2026 | Regulation adopted (Strasbourg) |
| 24 July 2026 | Published in the Official Journal (OJ L, 2026/1738) |
| 13 August 2026 | Article 53 applies - amendment of Annex I of the Batteries Regulation |
| 14 September 2026 | Empowerments apply, including Article 13(6) (circularity passport) |
| 14 February 2028 | Commission report on substances of concern in vehicles |
| 31 August 2028 | Methods for calculating recycled content (Article 6(5)) |
| 1 September 2028 | Regulation applies; Directive 2000/53/EC repealed |
| 30 September 2028 | Commission report on world trade and industry impacts |
| 1 September 2029 | EPR, Article 11 information duty, mandatory removal before shredding, landfill ban; scope extends to M1/N1 special purpose vehicles |
| 1 January 2030 | Targets of 95 % recovery / 85 % recycling |
| 14 August 2030 | Implementing acts on the digital circularity passport due |
| 1 September 2031 | Scope extends to M2, M3, N2, N3, O and category L |
| 1 January 2032 | Plastics recycling target of 30 % |
| 1 September 2032 | Circularity passport mandatory; Articles 4, 6 and 7 bite; Article 55 applies |
| 31 August 2032 | Directive 2005/64/EC repealed |
| 1 September 2036 | Recycled plastic content 25 % |
| 31 December 2035 | Commission review |
What manufacturers and suppliers should do now
1. Map the Article 10 data list onto your own bill of materials
Neodymium, dysprosium, praseodymium, terbium, samarium, nickel, cobalt, boron, aluminium, magnesium, steel, plastics - and for plastics at component level from 100 grams up. The first honest question is not how high the recycled content is, but for which of these items a supplier attestation exists at all.
2. Fix supply chain clauses before the 2032 type approvals
Article 4(2) requires procedures to verify the accuracy and completeness of supplier information. Contracts that contain no data delivery duty and no audit right today will still be running in 2032 - renegotiation takes longer than a software rollout.
3. Check which data already sits in another passport
Article 13(3) allows you to skip duplicate capture where the information is already accessible through the battery passport or another named passport and interoperability is ensured. If you are building the battery passport by 2027 anyway, choose an architecture the circularity passport can sit on top of rather than beside.
4. Treat vendor lock-in as a disqualifier
“Transferable through an open interoperable data exchange network without vendor lock-in” is a requirement on the system, not on the record. An export format only your own vendor can read does not satisfy it.
5. Plan the spare parts catalogue as mandatory content
From 2032 the official spare parts catalogue for each vehicle type is part of the freely accessible passport content. For many organisations that is less a data problem than a decision worth taking early.
A general sequence for a rollout is in the DPP implementation checklist.
Frequently asked questions
Does the circularity passport replace the battery passport?
No. The battery passport follows from Article 77 of Regulation (EU) 2023/1542 and covers batteries; the circularity passport follows from Article 13 of Regulation (EU) 2026/1738 and covers the vehicle. Article 13(1) requires alignment, interoperability and, where possible, integration, and Article 13(3) avoids duplicate capture. Two legal bases, one data architecture.
Does the Regulation apply to vehicles built before 2032?
The Article 13 passport duty attaches to placing on the market from 1 September 2032, and the design requirements in Articles 4, 6 and 7 attach to type approval from 1 September 2032. The management obligations in Chapter IV - collection, treatment, targets - apply to end-of-life vehicles regardless of model year once they become applicable.
Does the circularity passport come from the Ecodesign Regulation?
No, it has its own legal basis in the ELV Regulation. ESPR (Regulation (EU) 2024/1781) is mentioned in Article 13(1) only as a reference point for interoperability. The practical difference: for vehicles there is no ESPR delegated act to wait for, because the deadline is already in the law. For the framework, see ESPR Regulation: ecodesign requirements.
What remains open until 14 August 2030?
The technical solution for access, the location of the data carrier, access rights, the rules for third-party entries, and the availability of the passport once the producer is gone. The contents under paragraph 2 and the properties under paragraph 5 are already fixed and can be planned against.
Does the Regulation cover motorcycles?
Yes. Category L vehicles under Regulation (EU) No 168/2013 are covered from 1 September 2031; small series L-category vehicles under Article 42 of that Regulation are excluded.
Read next
- Digital product passport in 15 minutes: what the DPP is and why the EU introduces it
- ESPR Regulation: ecodesign requirements
- Battery passport: EU requirements and timeline
- EU Battery Regulation: obligations and deadlines
- Right to repair: the EU directive
- Extended producer responsibility (EPR)
- Calculating a product carbon footprint step by step
- DPP implementation checklist
If you want to hold recycled content shares, dismantling information and substance data per vehicle type in one place and later expose them as a passport, myDPP shows how that data layer is built at product level.
Sources
- Regulation (EU) 2026/1738 of the European Parliament and of the Council of 8 July 2026 on circularity requirements for vehicle design and on the management of end-of-life vehicles (OJ L, 2026/1738, 24.7.2026): EUR-Lex 32026R1738
- Directive 2000/53/EC on end-of-life vehicles (repealed with effect from 1.9.2028): EUR-Lex 32000L0053
- Directive 2005/64/EC on the type-approval of motor vehicles with regard to their reusability, recyclability and recoverability (repealed with effect from 31.8.2032): EUR-Lex 32005L0064
- Regulation (EU) 2023/1542 concerning batteries and waste batteries, Article 77 (battery passport): EUR-Lex 32023R1542
- Regulation (EU) 2018/858 on the approval and market surveillance of motor vehicles: EUR-Lex 32018R0858
- Regulation (EU) No 168/2013 on the approval of L-category vehicles: EUR-Lex 32013R0168
- Regulation (EU) 2024/1781 (ESPR): EUR-Lex 32024R1781
- Regulation (EU) 2024/1252 on critical raw materials, Article 28: EUR-Lex 32024R1252