The 2026 eCoC Timeline: How July 5 and November 29 Fit Together

The short answer

The EU did not uniformly amend Regulation (EU) 2018/858 Article 37 to replace July 5, 2026 with November 29, 2026.

The accurate statement is:

The structured electronic CoC legal duties took effect on July 5, 2026. Member states then applied a coordinated operational transition ending no later than November 29, with countries able to switch earlier when ready.

November 29 also has a separate legal meaning. Annex XVIII of Implementing Regulation (EU) 2025/1706 applies from that date and changes Euro 7 / OBM-related CoC fields. That field milestone is not an amendment postponing Article 37.

Why there are two dates

July 5: the legal milestone

The consolidated Regulation (EU) 2018/858 provides that:

Article 37(1) requires the manufacturer to provide the structured electronic CoC without undue delay after manufacture;
Article 37(9) requires member states to be able to exchange electronic CoCs from that date;
Article 36(2) removes the general paper-accompaniment duty once the eCoC is provided under Article 37;
Article 12(2) supports VIN-based access through the relevant systems.

EUR-Lex has not replaced the July 5 date in these provisions with November 29.

November 29: the operating transition boundary

Romania's RAR published an account of the 168th Motor Vehicles Working Group stating that member states coordinated an implementation transition ending no later than November 29, 2026. Countries may switch earlier as their systems and administrative processes become ready.

That is why national authorities have published different scopes and cutovers within the same period: they are implementing a coordinated transition, not waiting for a new uniform legal date.

A source-based timeline

Date	Type	Verified event
2021-02-05	Legislation	2021/133 established XML, IVI, EUCARIS, and any-EU-NAP exchange
2023-01-01	Application	2021/133 began to apply
2024-05-01	Implementing detail	2024/1061 introduced manual entry or IVI XML upload for specified small-series cases
2025-07-05	Application	2024/1061 security, unique-identifier, and access rules began to apply
2025-07-16	Technical release	EUCARIS Core SU-U74 added IVIRetrieve and IVINotification
2025-10-24	Technical release	SU-U75 added IVI Single Stage and Multi Stage support
2026-02-24	Technical release	SU-U76-1 added IviCorrections
2026-03-23	Operating status	The Netherlands connected IVI2.0 – IVIRetrieve
2026-05-06	Coordination	A transition ending no later than November 29 followed the 168th working group
2026-06-30	National arrangement	Sweden moved its e5 authority readiness date to November 29 and confirmed it would not operate a manufacturer NAP
2026-07-05	Legal milestone	Article 37 manufacturer-provision and member-state exchange duties took effect
2026-07-10	Live procedure	Ireland published automatic EUCARIS retrieval by VIN
2026-08 / 09	Official plan	Romania planned a new CIV process and NAP; these remain planned until production is confirmed
2026-11-29	National and field milestones	Dutch and Swedish cutovers; Annex XVIII of 2025/1706 also starts to apply
2026-11-30	National milestone	Ireland accepts only IVI 2.0 for applicable new M and N vehicles

Paper is not a permanent parallel obligation

Article 36(2) means that once the manufacturer provides the structured eCoC, it can be exempt from the general duty to accompany the vehicle with a paper CoC. It does not support a permanent “paper plus electronic, neither can substitute for the other” rule after 2026.

Some countries continue to accept or require paper during transition. National small series and special duplicate cases may also involve paper. Those are country or exception rules and must not be presented as a uniform EU obligation.

There is also no first-party basis for stating that the absence of an eCoC automatically blocks a separate “CO₂ certification” procedure. eCoCs carry vehicle and emissions data and affect registration and supervision, but they should not be marketed as an unsupported single CO₂-certification gate.

How Chinese OEMs should plan

Do not replace a delivery matrix with one countdown. Track at least:

vehicle category and approval route;
production date;
the authority granting the whole-vehicle type approval;
the available NAP and its onboarding status;
registration-country VIN retrieval and paper transition;
whether separate EU and UK routes are required;
the applicable XSD, MessageBook, ICM, and signing-rule versions.

The delivery goal is end-to-end proof before the first production batch: data mapping, negative validation, signing authority, certificate registration, NAP / VCA receipts, downstream VIN retrieval, corrections, and evidence export.

Official sources

Verified through July 30, 2026. National operating status and NAP onboarding may continue to change.