The EU Digital Product Passport registry supports three levels of registration granularity: model, batch, and item. For batteries, only one of those levels is available. Understanding DPP registration granularity at item level, what it means operationally, and why the regulation requires it, is the starting point for any manufacturer preparing to comply before the February 2027 deadline.
The Three Granularity Levels Explained
The DPP Registry User Guide for Economic Operators defines three distinct levels at which a product can be registered in the EU Central DPP Registry.
Model level covers all items that share the same specifications and features within a product family. A single registration record applies to every unit built to that design. This is the broadest level and carries the least registration overhead per unit shipped.
Batch level applies to a specific production run made within a defined timeframe. One registration record covers every unit produced during that run. Batch registration sits between model and item in terms of granularity and administrative effort.
Item level applies solely to one specific physical unit. One registration record corresponds to one battery leaving the production line. This is the most granular option, and for batteries it is the only option currently available.
Why Batteries Require Item-Level DPP Registration Granularity
The User Guide states that item level is currently the only available and pre-selected option for the Batteries product group, because it is the agreed and defined level for that category. This is not a temporary default waiting to be changed. It reflects a deliberate policy choice rooted in the nature of battery data.
Batteries are not static objects. Each unit has a unique electrochemical history from the moment it leaves the factory. State of health, charge cycles, capacity fade, and incident records all accumulate at the individual unit level over time. A model-level or batch-level passport cannot carry that data without collapsing into ambiguity: whose state of health? Which unit’s cycle count?
Commission Implementing Regulation (EU) 2026/1778 governs the data model applicable to each product group under Article 11. The data model for batteries requires fields that are inherently unit-specific, including the unique identifier assigned to each battery under Article 77 of Regulation (EU) 2023/1542. That identifier links the physical battery to its digital record throughout its life, including second-life applications and end-of-life processing. A model or batch registration cannot support that linkage.
Annex XIII of Regulation (EU) 2023/1542 organises access to battery passport data into four tiers. Point 1 covers data accessible to the general public. Point 2 covers data accessible to persons with a legitimate interest and the Commission. Point 3 covers data for notified bodies and market surveillance authorities. Point 4 covers individual-battery data for persons with a legitimate interest. Point 4 exists specifically because some data belongs to a single unit, not a product family. Item-level registration is the structural prerequisite for point 4 to function.
What Item-Level Registration Means for Your Production Volume
Item-level registration means one registration record per physical battery unit. The arithmetic is straightforward. If you produce 10,000 EV battery packs per year, you need 10,000 DPP records per year. If you produce 500 industrial batteries above 2 kWh per month, you need 500 records per month, or 6,000 per year.
The EU Central DPP Registry accepts batch file submissions, which reduces the manual effort of creating records one at a time. However, each batch file accepts a maximum of 100 DPPs. A manufacturer creating 10,000 records needs a minimum of 100 separate file submissions to complete that volume. Planning your submission workflow around that ceiling matters, particularly if you are working toward the February 2027 compliance date for EV batteries.
The 100-record-per-file ceiling is not a barrier to compliance, but it does shape how you structure your data pipeline. Manufacturers who attempt to handle item-level registration manually, record by record or file by file without automation, will find the process slow and error-prone at scale. The ceiling makes the case for connecting your production systems directly to the registry through an API or a platform that handles submission on your behalf.
What Data Goes Into Each Item-Level Record
Each item-level DPP record must carry the data fields required by the applicable data model under Article 11 of Commission Implementing Regulation (EU) 2026/1778. For batteries, the European Commission’s guidance enumerates 71 data points in total. Of those, 51 are mandatory for EV batteries at the February 2027 deadline, 54 are mandatory for light means of transport (LMT) batteries, and 36 are mandatory for industrial batteries above 2 kWh.
These are data points as defined in the Commission guidance enumeration. The Traceable platform decomposes those data points into a larger number of attributes internally, but the regulatory count is 71 total, with the mandatory subsets listed above. For a full breakdown of which fields are required and when, see the battery passport mandatory fields reference on this site.
Some of those fields are fixed at manufacture: cell chemistry, rated capacity, manufacturer name, date of manufacture, carbon footprint per functional unit. Others are expected to be updated as the battery moves through its life. State of health data, for example, must be accessible to persons with a legitimate interest under Annex XIII point 4 of Regulation (EU) 2023/1542. That update capability only works if the record is tied to a specific unit. A batch-level record has no mechanism to carry diverging state-of-health values for the hundreds of units it might cover.
Unique Identifiers and the Item-Level Link
Article 77 of Regulation (EU) 2023/1542 requires that each battery subject to the passport obligation carries a unique identifier. That identifier must be printed or affixed to the battery and its documentation, and it must link to the battery’s digital record in the registry. The unique identifier is the physical-to-digital bridge.
At item level, the relationship is one-to-one: one identifier, one physical battery, one DPP record. This makes traceability unambiguous. A recycler receiving a battery at end of life can scan the identifier and retrieve the full history of that specific unit, including its original specifications, its carbon footprint declaration, and any updated state-of-health data added by the operator over its service life.
At model or batch level, that one-to-one relationship breaks down. Scanning an identifier on a physical unit would return data for an entire product family or production run, not for the unit in hand. For batteries, where individual unit history is both commercially valuable and legally required to be accessible, that ambiguity is not acceptable under the regulation.
Preparing Your Systems for Item-Level Compliance
The practical implication of item-level registration is that your production and data systems must be capable of generating a unique identifier and a complete set of required data fields for every battery unit before it leaves your facility. That means integrating your manufacturing execution system, quality management system, and supply chain data into a single output that can be submitted to the registry.
Several steps are worth completing before the February 2027 deadline for EV batteries. First, confirm that your production line assigns a unique identifier to every unit at manufacture. Second, map your existing data against the mandatory data points required under Article 11 of Commission Implementing Regulation (EU) 2026/1778 and identify gaps. Third, design a submission workflow that accounts for the 100-DPP-per-file ceiling, whether through batched API calls or a platform that handles submission automatically. Fourth, establish a process for updating records post-sale, particularly for state-of-health data that must remain accessible under Annex XIII point 4.
None of these steps require waiting for further delegated acts. The item-level requirement for batteries is confirmed. The data model under Article 11 of Commission Implementing Regulation (EU) 2026/1778 is in force. The February 2027 deadline for EV batteries is set. Manufacturers who begin system preparation now have time to resolve integration issues before the deadline arrives.
Model and Batch Levels: Still Relevant for Other Product Groups
Model and batch registration are not redundant concepts. For other product groups covered by the Ecodesign for Sustainable Products Regulation (EU) 2024/1781, the appropriate granularity level will be determined by the delegated act for each category. Textiles, electronics, and furniture may well be registered at model or batch level where individual unit tracking is not required by the applicable data model. The three-level structure exists precisely to accommodate that variation across product categories.
For batteries specifically, the policy decision is made. Item level is the only available option, and the data architecture of the battery passport depends on it. Manufacturers planning compliance programmes for multiple product categories should note that the granularity choice is product-group-specific and cannot be assumed to carry over from one category to another.
To see how Traceable handles item-level DPP creation, batch file submission, and registry integration for battery manufacturers, visit traceable.digital/pricing to start a free trial. Plans are available for manufacturers at different production volumes, with no long-term commitment required to get started.
