The new vehicle rules look like recycling law. Read the data requirements.

Regulation (EU) 2026/1738 — circularity requirements for vehicle design and end-of-life management — enters into force on 13 August 2026. It generally applies from 1 September 2028 and replaces the existing ELV framework in stages, with transitional provisions keeping parts of the previous directives in force for longer.

At first glance it reads as a recycling rule: recycled content, dismantling, treatment. Read the obligations properly and something else emerges: for its vehicle-design and production obligations, it functions in significant part as a supplier-data regulation, embedded in and verified through EU type-approval.

First: several widely repeated claims don't match the adopted text.

We verified the regulation against the Official Journal text, article by article. Some circulating summaries are wrong on dates and mechanics that materially affect the planning horizon:

• "Circularity strategy within 36 months" — no such trigger exists. The duty applies from an absolute date, 1 September 2029 (Art. 9(1)), refreshed every five years (Art. 9(5)).
• "Recycled plastic rising to 25%" — close, but imprecise twice over. The requirement is post-consumer recycled plastic: at least 15% for new vehicle types type-approved from 1 September 2032, at least 25% from 1 September 2036 (Art. 6(1)). And the much-cited "20%" is not a share of vehicle plastic — it is the share of the applicable target that must be vehicle-derived recycled plastic, sourced from end-of-life vehicles or from parts and components removed during the use phase (Art. 6(2)). In practice: at least 3 percentage points of the 15% target, and 5 of the 25%.
• Steel and aluminium have no percentages in the act at all — the Commission is to set minimum shares through delegated acts due by 30 September 2028, applying no later than 14 August 2033 (Art. 6(7)–(8)).

None of these are exotic misreadings. They are what happens when summaries cite summaries. The text is the source.

The obligation files with the authority. The evidence comes from the chain.

For design and production requirements, enforcement runs manufacturer-to-authority: circularity is formally incorporated into the EU type-approval framework — Annex XI replaces the existing G13 entry in Regulation 2018/858 with a reference to Regulation 2026/1738, applying from 1 September 2032 (Art. 55).

The legal duties sit with the manufacturer — but what they require is data from the chain:

• for new vehicle types type-approved from 1 September 2032: collecting the necessary data through the full supply chain — particularly the nature and mass of materials used — with procedures to verify the correctness and completeness of supplier information (Art. 4(1)–(2))
• manufacturer declarations of recycled content for the listed materials, once the corresponding calculation methodology has been in place for twelve months (Art. 10(1)), supported in practice by upstream material data
• component and material coding nomenclature used by manufacturers and suppliers for labelling and identification of parts, components and materials (Art. 12(1))

If you supply the automotive industry: customer evidence requests will increasingly reflect the manufacturer's type-approval obligations as they phase in — rather than only when a vehicle reaches end of life. That is distinct from the direct coding obligation suppliers carry under Article 12(1) — and from the one design duty that reaches parts directly: the Article 5(4) substances ban applies to parts and components placed on the market for vehicle types type-approved on or after 1 September 2032.

One data spine, interoperable passport regimes.

From 1 September 2032, each in-scope vehicle placed on the Union market must have a Digital Circularity Vehicle Passport (Art. 13): removal information, recycled-content declarations, spare-parts data — with the manufacturer accountable for its accuracy.

The act requires that passport to be coordinated and interoperable with the battery passport under Article 77 of Regulation 2023/1542 (applicable from 18 February 2027), the vehicle environmental passport under Euro 7 (Regulation 2024/1257) and relevant ESPR passports — with specified Critical Raw Materials Act information incorporated into the DCVP at content level (Arts. 11(1)(d), 13(2)).

The act expressly anticipates reuse of overlapping information across passport regimes: where required information is already accessible through another passport, it must not be duplicated in the DCVP, provided interoperability is ensured. Operationally, that creates a strong case for structuring material and component data once — so overlapping requirements can be served without rebuilding the evidence base for each regime.

Three takeaways.

• Verify against the text. Several widely repeated claims about 2026/1738 do not match the adopted act.
• If you supply automotive, the practical effect reaches you through customer evidence requests tied to type-approval as the obligations phase in — map the data duties early.
• Structure the material-data spine once. The act itself anticipates reuse: the DCVP, the battery passport, Euro 7 and relevant ESPR passports, with CRM information carried at content level.