Each law, or each ESPR delegated act, sets whether a Digital Product Passport is kept per model, batch or item. Toy and detergent passports are per model, the battery passport is per battery from 18 February 2027, the construction passport per product type and vehicle passports per vehicle. Where two laws differ, the EU registry uses the most granular level.
What do model, batch and item mean?
A model is a version whose units share the same relevant technical characteristics and the same model identifier. A batch is a subset of a model made in one plant at one time. An item is a single unit. ESPR recital 33 gives these as the usual meanings.
Under Article 9(2)(d) of the ESPR, Regulation (EU) 2024/1781, each delegated act states “whether the digital product passport is to be established at model, batch or item level”. The unique product identifier follows that level.
Which level does each law set?
| Law | Passport level | Passport due |
|---|---|---|
| Batteries, Regulation (EU) 2023/1542, Article 77 | Each battery, including data from its use | 18 February 2027 |
| Detergents, Regulation (EU) 2026/405, Article 21 | Each model; batch or item where another law requires it | 23 September 2029 |
| Toys, Regulation (EU) 2025/2509, Article 19 | Each toy model; batch where another law requires it | 1 August 2030 |
| Vehicles, Regulation (EU) 2026/1738, Article 13 | Each vehicle | 1 September 2032 (circularity passport) |
| Construction products, Regulation (EU) 2024/3110, Article 76 | Each product type | No date yet |
| ESPR product groups | Set by each delegated act | No act adopted yet |
What if two laws set different levels?
The registry takes the finer one. Article 8(3) of Implementing Regulation (EU) 2026/1778 registers the passport “at the most granular level required by the relevant Union legislation”. At item level, batch and model identifiers are linked where they exist; at batch level, the model identifier is. Handmade and other unique products need no batch or model identifiers, says recital 14.
Example: a detergent also caught by a future law that requires item-level passports. Article 21(7) lets the detergent passport be issued per item. The registry then records it per item, with its model identifier linked, and its batch identifier where a batch exists.
The Commission’s registry user guide, version 1.03, says only item level is offered today because that is the battery level. The EU registry went live on 20 July 2026, but no passport can be registered yet.
Will steel and textile passports be per item?
That is undecided. A Joint Research Centre study of March 2026 recommends the heat number as the steel passport’s batch identifier, with item serial numbers optional for products such as coils. A May 2026 study recommends item level for textile apparel’s product identifier. Both are research recommendations, not law.
Sources: ESPR, Regulation (EU) 2024/1781, Implementing Regulation (EU) 2026/1778, Regulation (EU) 2023/1542, Regulation (EU) 2026/405, Regulation (EU) 2025/2509, Regulation (EU) 2024/3110, Registry user guide, JRC steel DPP study, JRC textile DPP study
For a manufacturer, GreenSutra’s DPP consulting starts by checking how its plants already number models, batches and units. The DPP guide compares the rules law by law.