Fundamentals · 8 min read

What data goes into a Digital Product Passport?

Identity, characteristics, evidence, lifecycle and governance — the five layers of a DPP data model.

Key takeaways

  • ●There is no single universal DPP template — each delegated act sets mandatory fields.
  • ●ESPR Annex III is a menu the Commission picks from per product group.
  • ●Treat a DPP as a maintained record with versions and permissions, not a static brochure.

A five-layer model

CIRPASS architecture work centres every passport on a unique identifier. A practical implementation model separates five layers:

  • Identity — product, model, batch or item; responsible economic operator; facility.
  • Product characteristics — materials, composition, performance and sustainability attributes.
  • Evidence — certificates, declarations, calculations and source records.
  • Lifecycle — repair, reuse, ownership events and recycling information.
  • Governance metadata — provenance, timestamps, versions, permissions and who may update what.

What ESPR Annex III allows

  • Unique product identifier and GTIN (or equivalent)
  • TARIC commodity code
  • Compliance documentation, declarations of conformity, technical documentation
  • User manuals, instructions, warnings and safety information
  • Manufacturer, importer, authorised representative identifiers
  • Facility identifiers
  • Information on durability, reparability, recycled content, substances of concern and environmental footprint (via Article 7)

Batteries: the most detailed example

The Battery Pass consortium organises around 90 attributes into seven themes: general information; compliance, labels and certifications; carbon footprint; supply-chain due diligence; materials and composition; circularity and resource efficiency; performance and durability. These are guidance groupings — the legal structure in Annex XIII splits data by access level instead.

What is not required

No general obligation exists to publish a full bill of materials, use blockchain, or serialise every item. Granularity (model, batch or item) is decided per product group.

Sources

  1. CIRPASS system architecture (D3.2)
  2. Battery Pass Content Guidance
  3. Regulation (EU) 2024/1781

Last reviewed 2 November 2026. Guidance only — not legal advice.