Do I Need to Create a Separate Digital Passport for Every Single Product, or Is One per Product Type Enough?
This is one of the most practical Digital Product Passport questions I get — and I understand why: it feels like the answer should be a single number. One passport per model? Per batch? Per individual item?
The reality is that there are three possible levels of DPP granularity, and the choice between them is not technical — it is strategic. And it is worth understanding the implications of each before Delegated Acts make that decision for you.
The Three Levels: What They Really Mean
The first level is the model level: a single Digital Product passport representing all identical units of a given product. At first glance, this seems like the simplest and least costly option — you create one DPP for a type of chair or t-shirt and keep it valid.
The problem is that this approach only works if every single piece of information required by the regulation remains exactly the same for every unit produced. In industrial reality — where suppliers change, raw materials vary across batches, and production processes evolve — this level of stability is almost impossible to guarantee.
When ESPR Delegated Acts come into force, the model-level approach risks becoming a false shortcut: any significant variation would require creating a new DPP, eliminating any perceived efficiency. Its meaningful application will likely be limited to extremely simple and standardized products — a bag of cement, an industrial brick, or highly uniform commodity goods.
The second level is the batch level: a Digital Product Passport associated with a group of products manufactured together, using the same raw materials and production processes. This traceability model is a standard already familiar in sectors such as food and pharmaceuticals, where batch-based recall management is common practice.
In the steel industry, the natural equivalent is the heat: all elements produced from the same melt — beams, rolled products, rebars — share identical chemical composition, raw material origin, and process parameters. A DPP at heat level would allow precise certification of these properties for each derived product, and in case of non-compliance, immediate traceability of all potentially affected elements.
This level enables meaningful supply chain traceability while maintaining manageable complexity — and represents the most pragmatic starting point for many industrial sectors approaching DPP implementation.
The third level is the individual item level: each physical unit has its own passport, identified by a unique serial number, NFC tag, RFID chip, or persistent unique identifier. This is the true digital twin of the product — its unique history, from manufacturing to recycling.
It requires the highest investment, but it also unlocks the greatest strategic value: anti-counterfeiting, predictive maintenance, circular economy services, precise warranty management, and certified second-hand resale ecosystems.
The Hybrid Approach Emerging in Practice
The question “which level should I choose?” actually hides an important distinction: level for whom?
What the most advanced market leaders are adopting in this transitional phase of Digital Product Passport implementation is a hybrid model — and it is worth understanding it clearly.
Internally, across the supply chain and for quality control, they collect data at the highest possible level of granularity — batch or individual item. This internal robustness is a strategic asset, independent of any regulatory obligation.
Externally, toward the end consumer, they aggregate and present this product lifecycle information at model level, because at this stage, detailed batch-level data does not add value to the user experience and unnecessarily increases complexity.
This hybrid DPP strategy allows companies to build the right data foundations today — those that will be required when Delegated Acts define mandatory minimum levels — without incurring the full cost of maximum granularity where it is not yet required or valued.
The Choice That Defines Ambition
There is one final consideration that goes beyond regulatory compliance. The choice of granularity does not only answer the question “what does the regulation require?” — it answers the question “what kind of company do I want to be?”
A manufacturer that chooses the individual item level does not do so merely to comply with ESPR requirements: it does so to offer personalized warranties, combat counterfeiting, build a certified second-hand market around its products, and collect real usage data to improve future generations. It is a competitive strategy that uses the DPP as a lever, not a burden.
Those who settle for the minimum regulatory requirement will have a compliant passport. But they will also have already chosen to leave differentiation to others.
The granularity of the DPP is not a technical detail to be delegated to IT: it is the first strategic question of the entire Digital Product Passport project. And the answer says a lot about where you want to take your company.
