"Do I need a separate passport for every unit? Or is one per model enough?" — this is one of the most practical questions around the Digital Product Passport, and surprisingly few clear answers exist. Yet this single decision determines whether you will manage 50 passports or 50,000, which identifier goes into your QR code, and how much data maintenance awaits you every year. The good news: the system is more logical than it first appears — the three levels build on each other, so even the most granular option doesn't mean a thousand times the work. Let's clear it up together.
The three levels in one minute
Under the ESPR (the EU's Ecodesign for Sustainable Products Regulation), the Digital Product Passport can be created at three levels of detail — in regulatory language: granularity. If you're still at the basics, start with what a DPP is — here we focus specifically on the levels.
- Model level: all products of the same design share a single common passport. Every manufactured unit of one T-shirt model — say, the "Basic Tee, white, size M" — points to the same passport. If you have 40 models, you have 40 passports, no matter how many units you produce.
- Batch level (batch/lot): each production run gets its own passport. Paint or adhesive is the classic example: the March 2026 and June 2026 production batches may differ slightly in composition or raw-material sourcing, so each batch gets a separate passport. 40 models × 10 production batches per year = 400 passports annually.
- Item level: every single manufactured unit receives its own serialised passport. This is the world of electric-vehicle batteries: two batteries made on the same day, from the same batch, still live with separate passports, because their lifetimes — charging cycles, State of Health — evolve individually.
The rule of thumb: the more a product's fate varies unit by unit (lifespan, repairs, condition), the finer the level that is justified. Between two units of a T-shirt there is practically no data difference — between two units of an EV battery, that difference is the whole point.
Who decides? Not you — your category's delegated act
An important clarification: the level is not freely chosen by the manufacturer. The ESPR framework regulation only states that the passport is created "at model, batch or item level" — the specific level for each product group is prescribed by its delegated act. These acts will be published gradually between 2026 and 2030, and as a general rule each one is followed by at least 18 months of preparation time (the regulation allows a shorter period in duly justified cases) — for the full timeline, see ESPR deadlines.
Where final rules already exist, the picture is clear:
- Batteries — item level, already law. The EU Battery Regulation (2023/1542, Article 77) states that from 18 February 2027, every EV battery, LMT battery (e-bikes, scooters) and industrial battery above 2 kWh placed on the EU market receives an individual, per-unit passport, and as a general rule the QR code must be printed or engraved on the battery itself (where size or nature makes this impossible, it goes on the packaging and accompanying documents). The passport contains model-level data (chemistry, carbon footprint) as well as unit-specific data (condition, history). We cover the details in a dedicated article: the battery passport.
- Textilees — still taking shape, but the direction is visible. A preparatory study published in May 2026 by the Commission's research centre (JRC) outlines a layered approach for the textile DPP: most product attributes (composition, durability, care instructions) would live at model level, while production-dependent data (manufacturing site, proof of recycled content, chemical data) would sit at batch level — meaning the minimum granularity is expected to be the production batch, not the bare model. Item level currently appears as a voluntary, future-proofing option for textiles (resale, unit-level repair tracking). To be clear: this is not adopted legislation yet, and the final delegated act may change it — but it is a sensible planning assumption today (more in: DPP in the textile industry).
The lesson is twofold. First: follow the delegated act for your own category, because that is what sets the mandatory level. Second: the level is not always a single level — one passport can contain model-level fields alongside batch- or item-level ones. More on this in a moment.
What does this mean in practice? Let's do the maths
Let's take a concrete example of what the three levels mean if you manufacture 1,000 units per year of a single model, in 10 production batches:
| Level | When is it typical? | Number of passports (1,000 units, 10 batches) | Nature of data maintenance |
|---|---|---|---|
| Model | No meaningful data difference between units (most apparel, furniture, many electronics) | 1 | One-time completion + updates when the model changes (new material, new supplier) |
| Batch | Composition/origin varies by production run (paints, chemical products, textiles expectedly) | 10 | Recording the variable fields for each production run (batch number, plant, certificates) |
| Item | Each unit's life evolves individually (EV/industrial/LMT batteries — already law; high-value, repair-trackable products) | 1,000 | Serial-number generation at production + unit fields (production date, batch reference, later condition data) |
At first glance, item level may look daunting — a thousand times as many passports! But as you'll see below, the real extra work is a fraction of that, because the system is built on inheritance.
The GS1 connection: how a level becomes an identifier and a QR code
The three levels are not theory — they map directly onto product identification. In the ESPR ecosystem, the most common solution is the GS1 Digital Link: a web address with GS1's standard application identifiers (AIs) built into it. The logic is beautifully simple:
| Level | Identifier | GS1 Digital Link path (example) | What else is it good for? |
|---|---|---|---|
| Model | GTIN | /01/05990001234567 | Ordering, inventory management — the "barcode number" as a web address |
| Batch | GTIN + lot (AI 10) | /01/05990001234567/10/L2603 | Recall management, batch-level compliance |
| Item | GTIN + serial number (AI 21) | /01/05990001234567/21/SN000482 | Warranty, repair tracking, individual life history |
In other words, the same GTIN is the backbone at all three levels — batch and item level simply append further path elements. This also means that if you print model-level QR codes today and your category's act later mandates batch level, you don't need to build a new identification system: you attach the lot number to the same logic. We covered how QR codes and the Digital Link work in detail here: QR codes and the GS1 Digital Link.
The good news: the levels build on each other — it's not 1,000× the work
And here comes the most important practical insight: an item passport is not a standalone data sheet filled in from scratch. The passport data model is layered (on the passport's structure, see: the anatomy of a product passport):
- Model layer: the vast majority of fields — material composition, design characteristics, repairability, care instructions, declarations of conformity — belong to the model. You fill this in once, and every batch and every item inherits it.
- Batch layer: batch number, manufacturing plant, production period, batch-specific certificates. A handful of fields per production run.
- Item layer: serial number, production date, batch reference — for batteries, later condition data (SoH, cycle count). Typically 3–6 fields per unit, most of which can be generated automatically at production.
In numbers: if a battery passport consists of, say, 90 data fields, 80+ of them are model-level. So 1,000 item passports do not mean 90,000 manually completed fields, but 80 fields once, a few per batch, plus a handful of generated values per unit — and the latter is handled by import (CSV/API), not manual work. The real overhead of item level is not data entry but process: serialisation has to be built into production or the warehouse workflow, and QR printing has to be unit-unique.
One note on the other side of the coin: the level also affects access management. At item level, more sensitive, unit-bound data may appear (e.g. condition history) that not everyone should see — more on this in our article on access control and trade secrets.
Decision guide: which level should you start with today?
If your category's delegated act is not yet final, we suggest this order:
- Check whether a final rule already exists for your category. For batteries it does: item level, from 18 February 2027. There is no discretion there — you need to prepare for serialisation and unit-specific QR codes.
- If not, start at model level — but batch-compatible. Build your model passports (this work is never wasted, since every finer level builds on it), and define your production-batch numbering logic now, even if it doesn't appear in the passport yet.
- In textiles, plan for batch level. Based on the direction of the JRC preparatory work, it is a smart baseline assumption that the batch will be the minimum — if you think in a model + batch structure today, the final act will likely mean fine-tuning, not redesign.
- Move to item level voluntarily when there is business value in it. With unit-level passports you can also build warranty management, anti-counterfeiting protection and second-hand value creation — for high-value products this can pay off today, regardless of the obligation (see: the DPP as a competitive advantage).
- Issue your identifiers with GS1 Digital Link logic from the start. That way a later change of level is a path extension, not a system replacement.
The bottom line: the granularity question is not an obstacle but a design parameter. Once the model layer is in order, batch and item level are merely incremental steps.
How does Veridyn help?
In Veridyn, the three granularity levels are not an afterthought but the foundation of the system: you can manage model-, batch- and item- (unit-) level passports alike, and the finer levels automatically inherit the model's data — you only enter or import the unit-specific fields. QR codes are natively in GS1 Digital Link format (with GTIN, GTIN+lot and GTIN+serial paths), so standards-based identification is taken care of. The category-schema editor lets you work without coding, the public passport is displayed in all 24 EU languages, and layered access control ensures that sensitive item-level data is visible only to those entitled to it. And if you want to automate serialisation from your production process, there's the developer REST API (api-docs).
The best way to understand the levels is to see them in action: in the live demo you can view a model-level and an item-level passport in practice, no login required. If you'd like to know where you stand in your preparation, take the free DPP readiness test — or dive right in: registration starts with a free entry plan.