# 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

- [CIRPASS system architecture (D3.2)](https://cirpassproject.eu/wp-content/uploads/2024/06/D3.2v1.9.pdf)

- [Battery Pass Content Guidance](https://thebatterypass.eu/assets/images/content-guidance/pdf/2023_Battery_Passport_Content_Guidance.pdf)

- [Regulation (EU) 2024/1781](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng)