Model, batch or item: at which level the passport is issued
The question decides the cost of the whole exercise. Issuing one passport per model is a catalogue task; issuing one per garment is a production-line task. The proposal for textiles puts the floor between the two, at the production batch, and distributes the fields across all three levels.
Edoardo Rinaldi · Founder, Trama
Last updated: 28 August 2026
Three units, and they are not interchangeable
The Regulation defines the three levels it can require. A model is a version of a product of which all units share the same technical characteristics. A batch is a subset of units of the same model produced together — one dye lot, one production run, one order at one facility. An item is a single physical unit: one garment, on one hanger.
Every field in a passport sits at exactly one of these. The level is not a brand’s choice. It is fixed for each field, and a brand may disclose more finely than required, never more coarsely.
What sits at batch level, and why
The proposal puts the batch identifier itself, the identity of the manufacturer, the facility where production happened, the substances of concern, and the safe-use and end-of-life instructions at batch level.
The reason is that these are the fields that actually change between production runs of the same model. A style reordered in a second season may be made in a different factory, from a different dye lot, by a different subcontractor. A model-level statement about the facility would be true of the first run and false of the second, and both would be sold under the same product name.
The chemical case is the one that bites hardest. Because the declaration covers the batch, it has to hold for every unit in it — in practice, a disclosure written for the worst case across all colourways produced in that run.
What stays at model level
Fibre composition, the robustness and recyclability scores, the environmental footprint, care instructions, repair information and warranty stay at model level. These are properties of the design rather than of the run, and testing each batch for them would multiply laboratory cost with no gain in accuracy.
One field crosses the line depending on how it is proved: mechanical test results sit at batch level when they are self-declared and at model level when they are certified by a third party. The route chosen to prove conformity therefore changes how much testing a brand does — see the two routes.
The single garment stays voluntary
Item-level identifiers are described as voluntary and encouraged, not required. That is the single most expensive line in the proposal, and it went the way the industry asked.
Serialising every garment means a unique code printed, applied and reconciled per unit, and a record per unit for the lifetime of the product. Brands that already serialise — for authentication, for resale, for warranty — can keep doing so and gain the finer level. Brands that do not are not being asked to start.
Why one QR per product is the wrong mental model
Fashion systems already assign a code per colour and size combination, and it is tempting to treat that code as the passport. It is not sufficient, because it does not identify the production run.
The identifier printed on the garment has to be able to carry the batch. In the standard scheme used across retail, a product code and a lot number are two separate fields of the same identifier, and a passport address that carries only the first can never resolve to batch-level data. The consequence is physical: the level is fixed at the moment the label is printed, and raising it later means re-issuing every carrier already sewn into stock.
This is the practical test to apply to any passport shown to you as an example. Scan it, look at the address it opens, and check whether a lot number can appear in it at all. Where the address is an opaque identifier with no room for a lot, batch-level compliance is not reachable without reprinting.
What the level costs in collection
Batch-level fields cannot be gathered from a catalogue. They come from documents attached to a particular production run, held by the supplier who made it, and they have to be captured while that run is open.
A season closes. The mill moves to other orders, the subcontractor who finished the fabric is finishing something else, and the person who could have answered a question about a specific lot has moved on. A batch-level value not collected during the season is not reconstructible afterwards, which is the structural problem in a textile chain rather than a scheduling one.
What to decide now
Two decisions can be made before the delegated act, and both are hard to reverse afterwards.
The first is the identifier scheme: whether the code applied to a garment can express a lot at all. The second is where batch identity comes from — which system already knows which units belong to which run, and whether that system’s lot numbers reach the people who collect supplier documents.
Common questions
Does every garment need its own Digital Product Passport?
No. Item-level identifiers are voluntary in the current proposal. The required floor is the production batch: one passport can cover a run of units of the same model produced together.
What is the difference between a model and a batch?
A model is a version of a product whose units share the same technical characteristics. A batch is a subset of units of that model produced together — one run, one dye lot, one facility. The same model reordered later is a different batch.
Which data has to be at batch level?
The batch identifier, the manufacturer, the facility, substances of concern, and safe-use and end-of-life instructions. These are the fields that can differ between two production runs of the same style.
Can we publish more detail than required?
Yes. The level fixed for each field is a floor, not a ceiling: disclosure may be finer than required, never coarser. A brand that already serialises garments can issue at item level.
Is a GTIN enough to identify a passport?
Not for batch-level data. A product code identifies the model or the colour and size combination; the lot number is a separate field of the identifier. An address that cannot carry a lot cannot resolve to batch-level content.
Why does the level have to be decided before printing labels?
Because the identifier is physically applied to the garment. Raising the level afterwards means re-issuing the carriers already attached to stock, which is a production cost rather than a software change.