Industry · Automotive & suppliers
No other sector is hit by the DPP in so many ways: battery passport from 18 Feb 2027 (fixed), iron & steel (act expected 2026), tyres and aluminium (expected 2027) – plus the new EU End-of-Life Vehicles Regulation with circular-economy requirements and a “Circularity Vehicle Passport” – trilogue agreement reached in late 2025, formal adoption pending. The OEMs are already passing these data requirements down to their suppliers today. Anyone supplying tier 1 to 3 should be able to answer.
01 — Situation
The Digital Product Passport reaches the automotive industry not as one law but as a bundle: the battery passport for traction/EV batteries becomes mandatory on 18 Feb 2027 – the first hard DPP deadline of all. In parallel run the ESPR product groups iron & steel (act expected 2026), tyres (expected 2027) and aluminium (expected 2027) – the core materials and components of every vehicle. In addition, the new EU End-of-Life Vehicles Regulation is coming: a trilogue agreement was reached in late 2025 (including a “Circularity Vehicle Passport” and recycled-content quotas for plastics), with formal adoption still pending – the direction is clear: recycled content and ease of dismantling are becoming vehicle-level topics.
For suppliers this means: exposure often comes not directly from Brussels but from the requirements specification. OEMs must be able to deliver passport and circularity data and cascade the requirements down to tier 1 through tier 3 – carbon data, material composition, recycled content, substances of concern. With Catena-X, the industry already has a data ecosystem for the standardised exchange of such supply-chain data.
Anyone answering requests for product carbon footprints and material data manually in Excel today will not keep up with the coming cadence. All dates in the DPP timeline.
02 — Fronts
Depending on your product portfolio, one or more of these regulatory lines will hit you – often staggered in time and with overlapping data requirements:
01
EV/traction batteries, LMT and industrial batteries > 2 kWh need a passport with carbon footprint, raw-material origin, chemical composition and recycled content. Cell, module and pack suppliers sit right in the middle of the data chain.
02
The material passports hit foundries, formers and component manufacturers as input-material data: melting route, carbon intensity, recycled content – figures OEMs are increasingly demanding in requirements specifications anyway.
03
Tyre manufacturers and the aftermarket get their own ESPR product group – with abrasion, durability and material data beyond today’s EU tyre label.
04
The upcoming regulation links vehicle design with the circular economy: recycled-content quotas for plastics, a Circularity Vehicle Passport, dismantling information. Formal adoption is pending – but the data requirements on suppliers are already taking clear shape.
If the answer is “with a few weeks of Excel work”, you are not alone – but exactly that is becoming a competitive factor. In a short call we will show you how suppliers become answer-ready.
03 — Approach
Map the parts portfolio against the battery passport, the steel/aluminium/tyre acts and OEM requirements specifications: which front hits you when – directly or via customer requirements?
Take stock of material, process and carbon data per part number – across ERP, MES, IMDS submissions and supplier data. Where is part-level linkage available, where only a plant average?
Pass data requirements on to your own upstream suppliers in a structured way – templates, contractual anchoring, prioritised by revenue and customer pressure.
A DPP-ready data model per product family, identifier logic (batch/serial), connection to ERP/PLM – and compatibility with exchange standards such as Catena-X where your customers demand it.
A real part as a pilot data record plus a defined process for customer requests – so the next OEM query costs days instead of weeks.
04 — FAQ
Fixed is the battery passport from 18 Feb 2027 for traction/EV batteries, LMT batteries and industrial batteries above 2 kWh. Expected, but not yet adopted: the delegated acts for iron & steel (2026) as well as tyres and aluminium (2027). For the new EU End-of-Life Vehicles Regulation a trilogue agreement has been in place since late 2025; formal adoption and concrete deadlines are pending – we deliberately quote no date here.
Very likely yes. First via the material passports: anyone supplying steel or aluminium components will see input-material data and pass-through obligations enter the chain. Second via the OEM cascade: data requirements on carbon, material and recycled content land in the requirements specification regardless of any delegated act.
IMDS is a valuable foundation for material composition and substance restrictions, but it does not cover what DPP rules additionally require: carbon footprint, recycled content, origin data, machine-readable passports with a standardised identifier. Existing IMDS data feeds into the DPP data model – it is a starting point, not an end state.
There is no legal obligation – Catena-X is an industry approach for the standardised exchange of supply-chain data. Whether joining makes sense depends on your customers: if your OEMs or tier 1 customers request data via Catena-X, you need compatibility. The real work – clean data per part – stays with you either way.
Three things: (1) map customer requirements and delegated acts onto your parts range, (2) build material and carbon data per part number instead of per plant, (3) establish a repeatable response process for data requests. Those who can deliver when the customer asks defend their place on the supplier panel.
Contact
Tell us briefly what you supply and which data requests your customers are already making – you will get an honest assessment of where you stand and what comes first.
Vincubate Ventures · Across the DACH region and Europe, remote & on site
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