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From Legal Obligation to Technical Specification: The EU Digital Product Passport Standards Explained

The European Commision (DG GROW) has confirmed the publication schedule for the eight harmonised European standards that will define how Digital Product Passports (DPPs) become interoperable in the frame of the European DPP System Framework. The first six standards passed the voting process beginning of April and are set for publication at the end of May 2026, with the remaining two following in Q3 2026. For operators preparing for DPP obligations, this is a critical milestone.

The Standards That Will Define DPP Compliance

The Digital Product Passport is the central instrument of the EU's Ecodesign for Sustainable Products Regulation (ESPR), which came into force in July 2024. Under ESPR, a wide range of products on the EU market will require a DPP. Mandatory requirements begin on 18 February 2027 for batteries demanded by the EU Battery Regulation that enforces interoperability with the EU DPP System Framework. Other product sectors  like iron and steel, packaging, and construction materials following in 2028, and ICT products, tyres, aluminium, and textiles in 2029.

ESPR creates the legal obligation to issue a DPP. JTC 24's standards define how DPPs become interoperable in the DPP System Framework,  not what data it must contain, which will be defined be corresponding delegated acts to come.  The EU DPP System Framework defines the technical architecture through which that data is structured, stored, accessed, and verified. These standards will be the baseline against which system design is assessed. The eight standards cover the full technical architecture of a compliant DPP system:

What's Coming Next: A Calendar of Confirmed Milestones

The publication of the CEN/CENELEC (JTC 24) standards is only one piece of a rapidly accelerating regulatory programme. Based on the latest guidance from DG GROW, the confirmed timeline now extends well into the end of the decade:

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Looking further ahead, a new technical committee, ISO/IEC JTC 5 Digital Product Passport, is scheduled to begin work in September 2026 that shall standardise cross sectoral and cross system interoperability of DPPs at the international level, a framework with potential to be a global benchmark.

The Battery Passport: No Extensions, No Exceptions

The first hard deadline remains 18 February 2027, when the Battery Passport becomes mandatory under the EU Battery Regulation. Some companies still assume a delay or grace period; the Commission has been explicit there will be none. Some technical points; battery carbon footprint, recycled content, and certain methodological elements, will need further clarification through additional standardisation and secondary legislation, but the core obligation is fixed.

A wider body of secondary legislation is also taking shape, with delegated and implementing acts in development covering service provider rules and certification, battery passport access rights, recognition of due diligence schemes, industrial battery carbon footprint methodology, EV battery carbon footprint label classes, and recycled content calculation and verification. For battery manufacturers and their supply chains, every one of these instruments will shape day-to-day compliance.

Who Needs to Pay Attention and Why Third- party backup matters

The scope is broad. Millions of European companies are expected to be required to issue Digital Product Passports in the coming years, spanning automotive and energy storage to fashion, consumer electronics, and construction. For manufacturers with supply chains across multiple tiers and geographies, the time required to gather, verify, and structure primary upstream data means preparation cannot wait.

The publication of the JTC 24 standards is the moment ambiguity ends. The technical specification is being fixed, and infrastructure that does not align with it will need to be rebuilt. It is not enough to collect sustainability data and attach it to a product identifier, that data must be structured, authenticated, stored with defined persistence, and accessible through compliant APIs. 

One requirement deserves particular attention. The standards make explicit that every DPP must be backed up through a certified, independent third-party provider. This is not an optional safeguard, it is a structural feature of the system, designed to ensure DPPs remain accessible for the full lifetime of a product, even if the original economic operator ceases to exist. For manufacturers, the practical implication is direct: in-house infrastructure alone will not satisfy the requirement. Choosing a proven, compliant DPP partner is now part of the regulation, not a commercial preference.

Circulor: Contributing to the Standards, Designed Around Them

At Circulor, our regulatory team has been closely following JTC 24's work since the committee's inception in December 2023 and contributing by reviewing during public consultations across the full stack of standards. As technical lead for the Battery Pass Consortium and a recognised contributor to the JTC 24 enquiry process, we have helped shape the regulatory framework now reflected in the engineering of our platform. The standards have not required Circulor to change course, because the course was set with these requirements in mind.

The Window for Getting This Right Is Narrowing

The JTC 24 publication schedule is a signal, not a starting pistol. The companies best positioned for compliance are those already building the supply chain relationships, data processes, and technical infrastructure a credible, standards-aligned DPP requires. Regulatory deadlines are fixed. The standards are imminent. The DPP Registry will go live in July. The question for every manufacturer in scope is no longer what will be required, but whether their current approach will meet it.

The EU's Digital Product Passport Standards Are Here. What They Mean.

Press Releases

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LONDON, 12 February 2026 – Circulor, the global leader of enterprise Trust & Assurance and Digital Product Passport solution, has partnered with Tees Valley Lithium (TVL), one of the UK’s and Europe’s most strategically important lithium refining projects, to deliver a digital tracking platform that records material inputs and outputs across the refinery and enables the measurement of recycled content at a batch level. 

This capability allows TVL to evidence where feedstock is sourced from, how it is processed, and the recycled content contained in each batch of product. From 2027, EU Battery Regulations will require digital battery passports for batteries placed on the EU market, including verified information on material origin and recycled content.

“We are delighted that Tees Valley Lithium has chosen Circulor to support the implementation of its Digital Product Passport and to establish and prove the provenance of its lithium products. Knowing and proving where mined and recycled feedstock comes from and how it moves through the supply chain is now a regulatory and commercial expectation.”

From 2031, the EU Battery Regulation mandates a minimum recycled lithium content of 6% in batteries placed on the EU market. TVL is designing its operations to exceed this requirement from first production, targeting 20% recycled content, supported by on-site lithium recovery, access to recycled feedstock and batch-level digital tracking.

By embedding this capability early, TVL is positioned to meet future regulatory requirements and customer expectations without impacting refinery operations or project delivery.

The Partnership with Circulor enables digital tracking of the origin of feedstock at batch-level and recycled content, ensuring full compliance with the EU Battery Regulation requirements for batteries placed on the EU market.

“By partnering with Circulor to deliver full supply-chain traceability, we are embedding recycled content and transparency into our production from day one. These collaborations strengthen the resilience of the UK’s battery materials supply chain and position Tees Valley Lithium at the forefront of low-carbon, sustainable lithium refining in Europe.”

As battery manufacturers prepare for Digital Product Passports to become mandatory, this partnership demonstrates how transparency, recycled materials and regulatory compliance can be built into supply chains from the very beginning rather than retrofitted later. Circulor is proud to support Tees Valley Lithium as it develops Europe’s first independent lithium hydroxide refinery and helps set a new standard for responsible battery materials production.

Circulor partners with Tees Valley Lithium to deliver traceable recycled lithium for their battery supply chain

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The BatteryPassReady project which started at April this year officially kicked off its comprehensive stakeholder engagement with their supporting partners last Tuesday. This marks the next chapter in Europe's journey toward mandatory digital battery passports. Building on the success of the original Battery Pass Consortium, this second-phase initiative brings together over 80 supporting partners, including manufacturers, technology providers, standards bodies, and research organizations, to turn regulatory requirements into industry-wide reality.

 is designed to prepare the entire battery value chain for compliance with the EU Battery Regulation. While the first Battery Pass project laid the conceptual and technical groundwork, this new phase tackles the practical challenges of full-scale implementation. The focus is on developing robust data verification processes, establishing clear communication protocols with the central EU Digital Product Passport (DPP) registry, and ensuring interoperability across the industry.

This is where theory meets practice. As the EU Battery Regulation comes into force, manufacturers, suppliers, and technology providers need proven frameworks they can deploy at scale. BatteryPassReady aims to deliver exactly that; bridging the gap between regulatory compliance and operational reality.

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Circulor served as technical lead for the original Battery Pass Consortium and has already demonstrated what's possible by launching the world's first production vehicles with digital battery passports through our work with Volvo Cars in June 2024. We've officially applied to join BatteryPassReady as a supporting partner and look forward to contributing our real-world deployment experience to this critical next phase.

Want to learn more about our Battery Passport solution? 

BatteryPassReady launches stakeholder engagement to prepare industry for EU Battery Passport implementation

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This month, China's expanding their export controls on critical materials potentially reshaping global supply chains, their emerging 15th Five-Year Plan will define the next wave of industrial competition, and there is growing resistance to the European’s 2035 combustion engine phase-out. 

With enforcement deadlines tightening and geopolitical tensions rising, the question is no longer whether regulations will impact your business, but how prepared you are to navigate them. From supply chain traceability to battery passports, we're breaking down what's happening now, and what you need to do next.

China tightens grip on critical materials

China’s Ministry of Commerce has announced 

, related technologies and equipment, effective Nov 8, just before the 90-day US trade truce expires. Even if framework deals with the US stops export controls, China could still weaponise its dominance on critical minerals. Companies must obtain a licence to export products containing trace amounts of Chinese REEs and those derived using Chinese technology, regardless of where production occurs.

China’s new rules target lithium-ion cells/ packs at ≥300 Wh/kg and key production equipment. With most EV batteries below that, the squeeze lands on next-gen chemistries (silicon-dominant, lithium-metal, solid-state) and by broader licensing to Chinese-origin materials, magnets, and overseas tech, they also affect LREEs.

China begins mapping out its 15th five-year plan

The 14th plan reshaped global competition, using industrial policy and subsidies to propel EVs, lithium-ion batteries and solar, disrupting industries in Europe and the US, stoking trade tensions. Now China’s Central Committee has begun drafting the 

, set for March 2026, emphasising high-quality, innovation-driven growth, technological self-reliance and a greener, more secure energy system. Pushing to “accelerate the development of industrial clusters” in new energy, new materials, aviation/aerospace and the low-altitude economy. It also aims to lift domestic demand, build a unified national market, and bolster advanced manufacturing, semiconductors, new energy and digital technologies.

Germany joins Italy in calling for changes to the 2035 zero emission mandate

, in coming months. Germany and Italy have joined together to push for changes to ban new petrol and diesel cars from 2035. They argue that the current law unfairly penalises carmakers and should recognise other low-emission technologies, not just electric vehicles. Demanding that cars running on renewable fuels, such as biofuels or synthetic e-fuels, should still be allowed after the deadline.

Circulor Founder Named to the 2025 TIME100 Climate List

TIME has recognized our founder, Douglas Johnson-Poensgen, in the Innovator category of its 2025 TIME100 Climate list, highlighting Circulor’s impact on building sustainability into the supply chain through traceability and battery passports. 

Volvo has already achieved its 2025 CO₂ targets for new cars, driven in part by proactive traceability strategies and the introduction of the world’s first battery passport in the EX90. 

Navigating the EU Battery Regulation with PROVE

Circulor’s PROVE platform enables businesses to meet the EU Battery Regulation's stringent requirements by tracing and evidencing supply chain activities in real-time. 

November 2025 Newsletter: Regulations Tighten and Shift to Implementation. What You Need to Know for 2026

News

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— TIME has named Circulor founder Douglas Johnson-Poensgen to the 2025 TIME100 Climate list in the Innovator category, recognising 100 of the world’s most influential leaders driving business toward real climate action.

The TIME100 Climate list celebrates innovators, executives, scientists, and policymakers who are accelerating progress on decarbonisation. This year’s list highlights those turning climate ambition into measurable results — a mission central to Circulor’s work.

“This recognition validates the pioneering work we’ve done in critical minerals traceability and battery passports, it’s a testament to the Circulor team, our customers, and partners who’ve helped make supply chain transparency and decarbonisation achievable at scale.”


Circulor provides full visibility into the sourcing, production, and embedded emissions of critical materials across complex industrial supply chains. Its traceability platform enables manufacturers to meet regulatory requirements, achieve ESG goals, and build trust through verifiable data.

Under Douglas’s leadership, Circulor has become the global leader in traceability for electric vehicle batteries and other critical materials, supporting the transition to more sustainable and accountable industry practices.

The full TIME100 Climate 2025 list is available at: 

Circulor Founder Named to 2025 TIME 100 Climate List

TUV partnership

LONDON, 26 May 2025 - TÜV Rheinland Greater China (referred to as "TÜV Rheinland"),  the international independent third-party testing, inspection, and certification organization signed a strategic cooperation agreement with Circulor, the leading global supply chain traceability provider on in-depth cooperation in digital services, such as digital product passports, supply chain traceability and management, and global regulatory compliance. 

Together, they will help enterprises handle global sustainability regulatory requirements, while enhancing compliance capabilities and demonstrating international market competitiveness.

With the strong performance of China's “New Three” industries of electric vehicles, lithium batteries, and photovoltaic products, global supply chain management and sustainable product development have become key factors for enterprises to expand into overseas markets. Especially after the official implementation of the EU Battery Regulation (EU) 2023/1542 and the Sustainable Product Eco Design Regulation (EU) 2024/1781, compliance requirements such as material traceability, carbon footprint transparency, and sustainable design are increasingly strengthened, and enterprises face unprecedented compliance and data management challenges.

In this context, TÜV Rheinland and Circulor have established a strategic partnership to jointly provide integrated solutions covering supply chain traceability, product eco-design verification, and passport data verification for global customers. Both parties will jointly develop innovative services for future needs, including digital product passport services based on the EU Batteries Regulation and Ecodesign for Sustainable Products Regulations, supply chain management platform solutions for international regulations or customized enterprise needs, and collaborate to develop new markets through the establishment of technical exchange and cooperation mechanisms.

"Our strategic partnership builds on our existing relationship with TÜV Rheinland. Together with their global influence and reach, we jointly support enterprises with the practical implementation of digital product passports and supply chain traceability - enabling Chinese enterprises to expand and trade internationally in the face of growing regulatory requirements across multiple markets.”

Xia Bo, Senior Vice President of Solar & Commercial Products at TÜV Rheinland Greater China said, "Through this strategic cooperation, we hope to provide full process and full lifecycle digital compliance services for enterprises in the battery value chain, especially in supply chain management, to help Chinese manufacturers and exporters accelerate their internationalization efforts while enhancing their competitiveness in the international market.”

In the field of digital battery passports, TÜV Rheinland can provide technical support and services such as regulatory interpretation, digital battery passport generation, and passport content technical support, committed to providing sustainable and implementable digital compliance solutions for enterprises. 

In the future, TÜV Rheinland and Circulor will leverage their respective professional capabilities and technological advantages to jointly explore global market opportunities and lead the high-quality development of the battery industry.

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Representatives from Circulor, Asia Pacific Vice President Yue Jin Tay, Client Partner Aloysius Lim, TÜV Rheinland Greater China Senior Vice President of Solar Energy and Commercial Product Services Xia Bo, Sustainable Business Manager Lin Li, and Strategic Business Development Manager Ding Shufen attended the signing ceremony.

Circulor and TÜV Rheinland reach strategic cooperation to jointly promote digital sustainable compliance services

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— Circulor, the global leader in supply chain traceability and sustainability solutions, is pleased to announce the appointment of Giles Palmer as Chief Executive Officer.

Giles Palmer is renowned for founding Brandwatch, a digital consumer intelligence company, in 2006. Under his leadership, Brandwatch grew into a global enterprise, culminating in its acquisition by Cision in 2021 for $450 million. Following the acquisition, Giles served as Chief Growth Officer at Cision, where he was instrumental in driving strategic initiatives. Most recently, he was the CEO at Cint Group AB, a leader in digital insights and research technology.

At Circulor, Giles will leverage his extensive experience in scaling technology companies to accelerate the company’s mission of making global supply chains more transparent and sustainable. His appointment marks a significant milestone, especially as Circulor expands its global footprint and technological capabilities.

“I am thrilled to join Circulor at this pivotal time,” said Giles Palmer. “The company’s commitment to responsible sourcing aligns with my personal values, and I look forward to leading the team to drive impactful change across industries.”

Doug Johnson-Poensgen, Circulor’s Founder and long-serving CEO, will transition to the role of President. Under Doug’s leadership, Circulor grew from a startup to a global leader in supply chain traceability and battery passporting. 

Circulor gives organizations full visibility of their supply chains. The London-headquartered company offers the most mature, proven, and complete technology software solution to track materials with high environmental and human rights impacts as they change state within manufacturing and recycling supply chains. With Circulor, businesses can follow the physical flow of critical materials from extraction to final production, as well as associated ESG characteristics and embedded carbon across Scope 1, 2, and 3 emissions. The tech company was founded in 2017 and has offices in the UK, Ireland, the U.S., Germany, Singapore, and Australia. The company has been named a 

Circulor appoints Giles Palmer as Chief Executive Officer to lead the company’s next phase of growth 

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 a leading manufacturer of advanced battery systems, today announced a strategic agreement with 

, the leading supply chain traceability provider, and 

. (NYSE: ROK), the world’s largest company dedicated to industrial automation and digital transformation, to deliver next-generation battery energy storage solutions. This collaboration solidifies Acculon’s commitment to responsible sourcing and sustainability with Circulor’s pioneering traceability and digital battery passport solutions and Rockwell’s state-of-the-art manufacturing expertise to accelerate compliance with existing and emerging regulatory standards.

As the demand for next-generation energy storage grows in pursuit of firm, diverse, and clean power, transparency and responsible stewardship become more and more essential. The EU Battery Regulation’s due diligence and digital battery passport requirements, by February 2027, highlight the importance of supply chain traceability and require a shift for companies to prioritize and prove responsible sourcing of critical minerals. This level of product transparency is also required to garner market incentives and meet increasing market import and trade restrictions.

In response, this strategic agreement enables a verifiable data trail for the origin of key materials such as sodium, lithium, copper, nickel, and graphite, as well as the embedded carbon emissions, from source to final battery manufacturing at Acculon’s Ohio facility. Together, they will also implement battery passports for a range of commercial and industrial applications for their customers, providing unprecedented levels of transparency and enabling them to meet upcoming compliance obligations.

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“Acculon Energy is thrilled to partner with Circulor and Rockwell as we advance our commitment to responsible energy storage innovation. Europe is an important export market for Acculon, and working with the best-in-class for traceability is an important step in our entry. Beyond Europe, we aim to give our global customers visibility into the resiliency of the sodium and lithium supply base we’ve put together.”

By incorporating traceability from cell selection through production, the collaboration proves Acculon’s commitment to responsible development and manufacturing, scaling the partnership as Acculon scales output. 

"As the demand for battery energy storage accelerates, so too does the need for accountability in how these systems are built,” 

says Douglas Johnson-Poensgen, CEO and founder of Circulor. 

“We're proud to work with Acculon Energy and Rockwell Automation to prove that transparent, traceable, and responsible supply chains are not only possible, but essential to a resilient energy future."

“Rockwell Automation is proud to support innovative manufacturers like Acculon Energy as they embrace digital transformation,” 

said James Glasson, vice president, Rockwell Automation. 

“By connecting intelligent manufacturing systems with trusted traceability data, we’re helping Acculon scale with confidence and compliance in mind.”

Acculon, along with Circulor and Rockwell’s combined strengths, will deliver significant benefits for consumers of energy storage products navigating the rapidly evolving and increasingly complex market expectations for secure, resilient, and responsible supply chains. This partnership sets a new benchmark for supply chain integrity, product transparency, and compliance readiness in battery energy storage.

Acculon Energy designs and manufactures advanced battery modules and packs—specializing in sodium and lithium-ion—for commercial and industrial applications. Based in Columbus, OH, Acculon brings decades of energy storage expertise to deliver safe, scalable, and efficient solutions that go beyond UL safety standards: safety and quality are core pillars in everything we do. By integrating cutting-edge AI and IoT technologies, Acculon is helping lead the transition to next-generation energy storage, powering smarter, safer, and more sustainable systems, from start to scale. For more information, visit us on 

Rockwell Automation, Inc. (NYSE: ROK), is a global leader in industrial automation and digital transformation. We connect the imaginations of people with the potential of technology to expand what is humanly possible, making the world more productive and more sustainable. Headquartered in Milwaukee, Wisconsin, Rockwell Automation employs approximately 27,000 problem solvers dedicated to our customers in more than 100 countries. To learn more about how we are bringing the Connected Enterprise to life across industrial enterprises, visit  

Circulor gives organizations full visibility of their supply chains. The London-headquartered company offers the most mature, proven, and complete technology software solution available to track materials with high environmental and human rights impacts as they change state within manufacturing and recycling supply chains. The tech company was founded in 2017 in the UK, with offices in the US, Germany, Singapore, Ireland, and Australia. The company has also been named a Technology Pioneer and a Global Innovator by the World Economic Forum, Global Cleantech 100, and won DIGITALEUROPE's 2022 Future Unicorn Award.

Acculon Energy partners with Circulor and Rockwell Automation to enhance supply chain transparency in Energy Storage

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Yesterday, the European Commission released simplification measures for a number of policies, including a proposal to give the battery industry more time to comply with the Due Diligence requirements of the EU Batteries Regulation. 

Assuming and anticipating that this proposal is accepted by the European Parliament and the Council, the new deadline to fulfil and verify the due diligence requirements will shift from August 2025 to August 2027, and the Commission will provide final guidance in July 2026. This gives European Member States time to establish third-party notified bodies and economic operators time to ensure their batteries comply. 

It’s important to be clear that the core requirements of the EUBR and its due diligence obligations (Chapter VII) are not changing—the timeline is simply shifting. 

The EU Batteries Regulation, as already enacted into force in August 2023, still requires: 

Companies shouldn’t see these additional two years as something to squander. As the Commission highlights in its proposals, it takes time to analyze and adjust supply chains, and digitalization remains a critical commitment of theirs to uphold high standards of operations and products, while streamlining and accelerating effective reporting for both companies and authorities. 

In the spirit of European and business competitiveness, we must remember that supply chain transparency and resilience is core to mitigating risks and improving economic strength. 

The ability to differentiate suppliers and products based on high standards is a competitive advantage for Europe, especially when pursuing reindustrialization and investment in batteries and critical minerals. The EUBR and OECD Guidelines have already prompted other markets to follow suit, so whether for this policy or a growing number of others, as well as financial and business obligations, the time to start is now. 

If you'd like to learn more about Circulor's Material Traceability and Battery Passport solution please fill in the form below and we will be in touch. 

While timing may change—EUBR requirements have not

Commentary

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Environmental policies frequently require the automotive industry to shift as regulations change.

Traceability is a key area of focus for Government organisations across the world who are conscious of reducing the carbon footprint produced by the automotive industry. One sector of the industry which may be overlooked by some for its environmental impact is the tyre industry. The tyre industry is at a key moment, facing growing regulatory pressures alongside an increasing need for efficiency, traceability, and sustainability to be optimised.

The upcoming EU Deforestation Regulation (EUDR) represents a key shift for the tyre industry, demanding increased levels of supply chain due diligence. However, although the compliance deadline is fast approaching, many tyre manufacturers are far behind when it comes to implementing the necessary traceability frameworks.

Just Auto spoke to Dominique Scheider, EMEA industry strategy and marketing manager for transportation, Rockwell Automation and Douglas Johnson-Poensgen, CEO of Circulor, to learn more about the upcoming EUDR regulation and why some within the industry are lagging behind.

JUST AUTO: Tracing tyres and the EU Deforestation Regulation

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