The short answer
Sometimes. The answer depends on the product group and the applicable EU law, not on a universal DPP rule.
The Ecodesign for Sustainable Products Regulation (ESPR) deliberately leaves the granularity decision to each product-group delegated act. That act can require a DPP at model, batch, or item level. A model-level passport can cover shared specifications. A batch-level passport can add information shared by a production lot. An item-level passport identifies one physical product.
For batteries covered by the EU Battery Regulation, the answer is more specific: each LMT battery, each industrial battery above 2 kWh, and each electric vehicle battery placed on the EU market or put into service from 18 February 2027 must have an electronic battery passport. The passport must combine model information with information specific to the individual battery. Its QR code links to a unique identifier attributed to that battery. The data model can reuse shared model information, but the identity and QR-linked record must distinguish the individual battery. (Battery Regulation, Article 77)
That is why a battery manufacturer should plan for one product-specific QR code and one unique passport identity per covered physical battery, subject to the final technical implementation rules and the practical placement rules in the Regulation. The QR code may be printed or engraved on the battery. If that is not possible or warranted because of the battery's nature or size, it may be placed on the packaging and accompanying documents. (Battery Regulation, Article 13(7))
Why “one DPP per product” is not a universal rule
The EU's product-passport architecture has two layers:
- The regulation establishes the common requirements, such as a persistent unique product identifier and a physical data carrier.
- The product-group delegated act specifies the level of reference and the data fields for that group.
Under ESPR Article 9(2)(d), the delegated act must specify whether the DPP is established at model, batch, or item level. Article 10 then requires the DPP to be connected through a data carrier to a persistent unique product identifier, with the data referring to the model, batch, or item as specified by the applicable act. (ESPR, Articles 9 and 10)
This matters because a DPP is not simply a digital brochure for a product family. It is a structured record whose identity and data scope must match the obligation for that product group. Before designing QR production, confirm:
- Which regulation applies.
- Whether the relevant delegated act is in force.
- Whether the act requires model, batch, or item-level passports.
- Which data must be shared across a model or batch.
- Which data must be unique to the individual item.
- Where the data carrier must be placed.
The safe operational principle is: reuse common data, never reuse an identity that the law requires to be unique.
Model, batch, and item level compared
| DPP level | What it identifies | What can usually be shared | What it cannot safely represent by itself | Typical operational question |
|---|---|---|---|---|
| Model | A defined product model or variant | Specifications, materials, design and intended performance | Individual serial history, unit-specific events or state of health | “What is this model?” |
| Batch | A production lot with a common manufacturing context | Model data plus lot date, plant, supplier or quality information | Events or defects affecting only one unit | “What happened to this lot?” |
| Item | One physical product | Shared model data can be inherited or referenced | Nothing that must distinguish one item from another | “What is the history of this exact unit?” |
These labels are not interchangeable. A SKU may be an internal catalogue key. It does not automatically prove that the DPP must be SKU level or item level. The applicable legal act controls the DPP level.
The precise battery answer for February 2027
Article 77 of the Battery Regulation sets a binding battery-passport obligation from 18 February 2027 for:
- LMT batteries.
- Industrial batteries with a capacity greater than 2 kWh.
- Electric vehicle batteries.
The same article requires two kinds of information in the battery passport:
- Information about the battery model.
- Information specific to the individual battery, including information resulting from use.
The passport is accessible through the QR code referred to in Article 13(6), which links to a unique identifier that the economic operator placing the battery on the market attributes to it. The QR code and unique identifier must comply with the specified ISO/IEC 15459 standards or equivalent standards. (Battery Regulation, Article 77(1)-(5))
In plain English, the manufacturer can maintain one reusable data foundation for a battery model, but cannot use one shared identity for every physical battery when the passport must carry individual-battery information. Each covered battery needs a traceable identity that can receive its own lifecycle and status data.
This is especially important because the Regulation distinguishes individual-battery information such as performance and durability values at placing on the market, state of health, and status such as original, repurposed, reused, remanufactured, or waste. (Battery Regulation, Annex XIII, point 4)
Do you need to print a different QR code on every battery?
For every covered physical battery, plan on a QR code that resolves to that battery's unique passport identity. Do not print the same passport QR code on every unit of a model unless the applicable implementation rules explicitly permit a different structure for that product and use case.
The QR code is the data carrier. It is not the passport itself. A scan should take the user or authorised actor to the record associated with the identifier encoded or resolved by that carrier. A shared model QR code could show common specifications, but it would not by itself distinguish the state, history, or status of one covered battery from another.
The placement rule is also practical. Article 13(7) says labels and the QR code should be printed or engraved visibly, legibly, and indelibly on the battery. Where that is not possible or warranted because of the battery's nature and size, they can be placed on the packaging and accompanying documents. Article 13(6) also states that, from 18 February 2027, all batteries carry a QR code, with the code providing the battery passport for the categories covered by Article 77. (Battery Regulation, Article 13)
Example: one battery model, three physical batteries
Imagine a manufacturer produces three units of the same industrial battery model:
| Layer | Shared or unique? | Example |
|---|---|---|
| Model record | Shared | Chemistry, rated design, model-level manufacturing information |
| Unit A identity | Unique | Battery identifier A, production events and later lifecycle data |
| Unit B identity | Unique | Battery identifier B, separate performance and status data |
| Unit C identity | Unique | Battery identifier C, separate performance and status data |
| QR code | Product-specific | Each code resolves to the corresponding unit identity |
The model record can be maintained once and referenced by all three passports. The unit identities and unit-specific data remain separate. If Unit B is repurposed or remanufactured, the Regulation also requires a new battery passport linked to the original passport or passports. (Battery Regulation, Article 77(7))
What this means for production and operations
Treat item-level battery passports as a serialization workflow, not a one-time QR-code design task.
1. Assign identity at the right production point
The unique identifier must be associated with the physical battery before the record is released as the authoritative passport. Your process should prevent duplicate identifiers, record the association between the identifier and the unit, and preserve a clear audit trail.
2. Separate shared data from unit data
Store model attributes once where possible, then attach unit-level attributes and events to each battery. This reduces duplicate entry without collapsing different batteries into one record.
3. Generate the carrier from the identity
The QR generation step should be driven by the unit identifier, not by a generic product URL copied across a print run. Test the printed or engraved code on the actual material, surface, and size used in production.
4. Keep the passport current
The economic operator must ensure that battery-passport information is accurate, complete, and up to date. This is not compatible with a static PDF that can never receive lifecycle changes. (Battery Regulation, Article 77(4))
5. Plan replacements and status changes
Replacement, reuse, repurposing, and remanufacturing create identity and linkage questions. Define how the original passport, the new passport, and the changed status are connected before the first affected unit leaves the factory.
A practical decision tree
Use this sequence for each product group:
- Is there a specific legal obligation already in force? Start with the applicable regulation, then check delegated acts and implementation rules.
- What level does the rule require? Record model, batch, or item level explicitly in your data model.
- Which fields are shared? Put stable model or batch information in reusable master data.
- Which fields are unique? Reserve individual records for identifiers, lifecycle events, status, and other unit-specific data.
- Where must the data carrier appear? Follow the product-group rule and physical feasibility requirements.
- How will updates and corrections work? Assign owners, version data, and retain the link between the physical product and its passport.
What to do now if you manufacture batteries
The deadline is fixed, but the work is not only QR generation. Build a unit-level inventory for covered batteries, map model and individual data separately, confirm the identifier standard, test physical marking, and rehearse the full scan-to-passport flow.
For the broader distinction between the battery passport and the ESPR DPP framework, see DPP vs Battery Passport. For the underlying data and access structure, see the Digital Product Passport requirements checklist. If you need to assess your portfolio, use the DPP readiness check and review the battery passport guidance.
Conclusion
There is no legally correct universal answer of “one DPP per product” for every product category. ESPR delegated acts decide whether a passport is established at model, batch, or item level.
For covered batteries, the answer is materially different. From 18 February 2027, each covered physical battery must have an electronic battery passport containing model information and information specific to that individual battery. The QR code links to a unique identifier attributed to that battery. You can reuse the data foundation, but you must not reuse the identity where individual tracking is required.
The implementation question is therefore not “Do we duplicate every field?” It is “Which data is shared, which identity is unique, and how do we keep the correct QR-linked record attached to the correct physical product?”
Continue through the cluster
For the battery-specific production rule, read Battery Passport QR Codes: Does Every Battery Need a Different QR Code?. Then use the DPP identifier guide, the high-volume issuance workflow, and the battery passport data model to turn the decision into a working architecture.
