Vehicle circularity and end-of-life vehicles. This is the legal basis for VINPassport, and the regulation that establishes the Digital Circularity Vehicle Passport.
This page is a reader's summary of what the regulation requires and how VINPassport answers it. It is not the legal text and it is not legal advice. Every claim below links to EUR-Lex, the official EU law portal, which is free to read in all official languages. Where a date comes from secondary legal analysis rather than the operative articles, this page says so.
Every date and article number on this page was read from the Official Journal text directly, verified on 8 September 2026: entry into force from Article 59(1), general application from Article 59(2), the manufacturer circularity strategy from Article 9(1), and the 2032 passport deadline from Article 13(1). None of it rests on secondary analysis. Read the provisions on EUR-Lex yourself before relying on a date in a submission or a compliance claim.
The passport itself. This is the article VINPassport implements, and the source of the identity and environmental declaration fields: vehicle category, type approval, fuel type, emissions class, CO2 footprint, critical raw materials, dismantling time.
Drives slots 7, 12, 16, 23, 24, 26, 28, 30
Article 6 sets the targets and they rise: 15 per cent recycled plastic by weight for types approved from September 2032, 25 per cent from 2036, with at least a fifth of that coming from end-of-life vehicles. Article 10 is the declaration itself. A target that rises over time is a claim about a number, which is exactly what a bounded proof answers well.
Drives slots 8, 9, 10, 11
Directive 2000/53/EC on end-of-life vehicles, and Directive 2005/64/EC on 3R type approval. The three reuse, recycle and recover percentages in the panel are inherited from the second.
Drives slots 13, 14, 15
The passport must be “aligned, interoperable and, where possible, integrated with other vehicle related environmental passports established under Union law”.
Interoperability requirement, Regulation (EU) 2026/1738
The operative verb is interoperate, not absorb. VINPassport reads that as a reference rather than a copy. Slot 29 holds a battery passport identifier and stops there, so the battery's own claims stay in the battery passport where they are authoritative.
Restating them would create two records that can disagree, and a verifier who finds two answers has no way to choose between them. Battery state of health was considered for the panel and deliberately returned to the reserve for that reason.
Establishes the battery passport, mandatory from 18 February 2027. Its scope is the battery and not the vehicle: EV batteries at any capacity, light means of transport batteries at any capacity, and industrial batteries above 2 kWh. A manufacturer is caught because it places a battery on the market inside a vehicle, but this regulation gives the vehicle no passport of its own.
It is the interoperability target named by 2026/1738, and it is already implemented on the same stack, which makes a composition demonstration a realistic phase 3 goal rather than an aspiration.
Slot 29 is where the two records meet: a verifier follows the identifier into the battery passport and checks there, instead of trusting a copy held on our side.
Ecodesign for Sustainable Products explicitly excludes vehicles. Do not cite it as the basis for a vehicle passport.
ESPR is the EU's general Digital Product Passport framework, and it is the one most people reach for when they hear the phrase. Article 1(2) carves out vehicles within the scope of Reg 167/2013, Reg 168/2013 and Reg 2018/858, on the basis that vehicles are covered by sector specific law. Citing it here is a factual error, and an easy one for a regulator, an investor or a judge to catch. Regulation 2026/1738 is the correct and only citation for a vehicle level passport obligation.
That is not the same as saying ESPR is irrelevant. Article 13(1) requires the passport to be “aligned, interoperable and, where possible, integrated … with other relevant passports established pursuant to Regulation (EU) 2024/1781”. ESPR is excluded as the legal basis and required as an alignment target, both at once — so its Digital Product Passport stack is the data model to build against.
Read ESPR on EUR-Lex
Thirty-two slots at tree depth five. Twenty-six fields in use and six held in reserve, split by type so either kind of field can be added later without reordering the panel. Numeric fields must precede all string fields, and the ordering is frozen shared vocabulary: changing it would change every root. Numerics are scaled by one thousand into unsigned integers; strings commit to a digest of the exact string. The public label for any field is a digest of its name, never its value.
An earlier sixteen-slot panel was full on day one, and twelve credible fields had to be cut, several of them plausibly mandatory once the regulation applies in 2028. Filling thirty-two of thirty-two would repeat that mistake at a larger scale. Six reserved slots is roughly nineteen per cent headroom, split by type. Panel width is effectively permanent, because proofs relate documents of the same width only, so the choice was made now while nothing is anchored and it is still free.
Nothing on this page is legal advice. Where a claim rests on secondary analysis rather than the operative articles, it is marked as such above. If you are relying on a date for a submission or a partner conversation, read the final provisions on EUR-Lex first.