Model, Batch or Item-Level DPP — Which One Will Your Garments Need?
The ESPR recognises three granularities for a Digital Product Passport: model (one passport for all identical units of a product), batch (one per production run) and item (one per physical unit). Which level applies to apparel is not fixed in the regulation — Article 9(2)(d) of ESPR (EU) 2024/1781 leaves it to each product group’s delegated act, and the textile act is expected in 2027. The practical strategy: structure data at model level now, keep batch and item identifiers ready.
Written by Nazrul Islam, Founder, DPPLive · Last updated: 16 July 2026
Article 9(2)(d): the delegated acts shall specify “whether the digital product passport is to be established at model, batch or item level, and the definition of those levels”. The ESPR’s recitals frame this as cost-proportionality — the passport should sit at the level that avoids costs disproportionate to the benefits. For textiles, that decision lands with the apparel delegated act expected in 2027.
Quick Answers
Go Deeper
- Regulation (EU) 2024/1781 (ESPR) — full text on EUR-Lex — Article 9(2)(d) (model/batch/item), Articles 10–12 (identifiers and data carriers)
- Regulation (EU) 2023/1542 (EU Battery Regulation) — battery passport, applying from 18 February 2027
- GS1 — GS1 Digital Link standard
Granularity Is a Data Decision — Make It Once
Factories that structure product data model-first with batch and serial fields ready will treat the 2027 delegated act as a configuration switch, not a crisis. DPPLive’s pipeline is built exactly that way — one data intake, any passport level. Check how ready your current data is.