For each product, the Digital Product Passport must provide insight into composition, origin, environmental impact and life-cycle information. But that does not mean that each passport must be set up at the individual product level. According to the ESPR, the DPP will be linked via a unique identifier, with the level determined per delegated acts per product group. Think model, batch and item.
That distinction is not an administrative nuance. It directly impacts your IT architecture, data collection, supply chain governance and compliance costs.
Two approaches
A batch DPP or a unique DPP is determined in the Delegated Acts and depends on such factors as proportionality and technical feasibility. For relatively simple, homogeneously produced goods, information can be recorded at the batch level. For complex products with their own life cycle, a unique passport is necessary.
Batch DPP: for standardized mass production
A batch DPP is associated with a group of products with the same characteristics, identified through a batch or lot number. The assumption is that variation within the batch is negligible from a compliance and sustainability standpoint. This suits products with homogeneous composition, stable configuration and limited variation in raw materials.
Textiles and apparel is the most appealing example. A production run of 5,000 identical cotton T-shirts from the same factory can share one DPP. The relevant information, such as fiber origin, water use and chemical treatments, is identical for the entire batch. Thus, even tires of the same model and production period share similar properties. Rolling resistance, material composition and wear indicators can be recorded at the batch level. The same applies to aluminum profiles from one production run: same alloy, same production method, same CO₂ emissions per ton.
Unique DPP: for complex products
For complex products, a generic dataset is not sufficient. Here a unique DPP per product is required, linked to a serial number or digital identity. Consider products with variable compositions, multiple suppliers, a long service life and relevant maintenance or usage data.
Electric vehicle batteries are the most obvious example. Each EV battery has a unique combination of chemistry, software version and history of use. The “State of Health” is constantly changing. Therefore, the battery regulation explicitly requires an individual passport with dynamic data.
Laptops and smartphones, though mass-produced, contain variations in chips, memory and firmware. Software updates and repairs help determine longevity and justify an individual DPP. Building components such as elevators or HVAC systems are custom installed and maintained, with unique configurations per installation.
The gray area: hybrid models
In practice, much of the products are between batch and unique. A laptop model may be largely standardized, yet have different SSD vendors, variation in battery cells and firmware updates. This is where a hybrid model emerges: a basic batch-level DPP for design and materials, supplemented by a layer per individual product for use, repairs and updates.
Among the companies we assist, we see that this hybrid model is becoming increasingly relevant. The ESPR deliberately drives this: the delegated acts determine for each product group what level of granularity is appropriate.
What does this mean for your organization?
The choice between batch and unique is not a purely technical one. A batch DPP requires relatively simple data structures and PIM systems. A unique DPP requires lifecycle data, dynamic updates and links to IoT, asset management and service systems. You’ll notice that difference in your data architecture, in the traceability you demand from your supply chain, and in your cost per product.
The biggest mistake we encounter is approaching this as purely a compliance issue. In reality, it’s a design choice. Products that are batch capable today may shift to unique DPPs due to future requirements. Repair, circularity and reuse are driving toward individualization. The trend is clear: batch where possible, but unique where necessary. And that “where necessary” widens over time.
Therefore, make segmentation within your product portfolio now: which products remain batch-based, which require unique identification, and where does a hybrid model emerge? Not regulations, but the nature of the product ultimately determines the right approach.
Wondering where you stand? Our free Empact DPP Tool analyzes your existing product documentation and instantly shows you how much DPP data you already have.