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