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On Tuesday, March 31, the meeting of Expert Working Group 3 (EWG3) of CIRPASS-2 will be held. This European consortium is tasked with defining the architecture of the Digital Product Passport (DPP) for the textile sector. On the agenda is a point that, until a few months ago, seemed technical and manageable: the level of granularity of the passport.
Today, it is anything but.
What “Granularity” Means and Why It Matters
The textile DPP can be issued at three levels:
Model level — A single passport for all units of a given model (e.g., “white t-shirt, size M, 100% cotton, Spring 2026 season”).
Batch level — A passport for each production lot, identifying a specific supply chain, a specific spinning mill, and the specific actual composition.
Item level — A passport for every individual garment, with a Unique Product Identifier (UPI), potentially updatable throughout its entire lifecycle.
The CIRPASS-2 whitepaper, “DPP Granularity Level Options for Textiles/Apparel” (November 2025), is an honest and well-constructed document. It explicitly recommends that item-level identification should be encouraged (Recommendation R2) to anticipate future expansion toward the circular economy, and that the granularity level of product identifiers and mandatory information need not coincide (R1).
It was a balanced, scientifically defensible position that left room for SMEs while pointing in the right direction.
The Anonymous Email That Shuffled the Cards
On Friday, March 27, EWG3 Chair Andreas Schneider sent an unusual communication to the entire Expert Working Group: an anonymous statement from “a relevant expert from a major textile-producing country,” with an explicit request for anonymity.
The content is clear: model-level as the only mandatory level, at least in the initial ESPR phase. Batch and item-level are recognized as a “theoretical gold standard” but postponed to a voluntary future, supposedly supported by EU funds for third-country SMEs.
These are the classic arguments of industrial production lobbying:
SME ERP systems are structured by model, not by batch.
Item-level serialization requires unsustainable investments for small producers.
In e-commerce warehouses, it is “nearly impossible” to match a serial number to a customer at the time of sale.
While these points aren’t entirely false, they aren’t technical arguments either: they are economic-political arguments disguised as operational constraints.
The Problem This Position Refuses to See
A significant event occurred 48 hours ago, on March 28, 2026, just a few kilometers from where I write.
The Prato Finance Guard (Guardia di Finanza) seized 246,860 spools of industrial yarn imported from China under the “Legal Trade” campaign. The violations: lack of importer/distributor details and—more critically—the absence of minimum textile composition data required by EU Reg. 1007/2011.
In short: nobody knew what was actually inside those spools.
It could have been 100% cotton, or a cheap synthetic blend. No industrial buyer could verify it without lab analysis. No automated system could flag the anomaly before it entered the supply chain.
This is exactly why batch-level DPP exists. Model-level DPP is useless here; it provides a photograph of the declaredproduct type, not the delivered goods.
Mass Balance: The Blind Spot of the Debate
Mass balance verification answers a simple question: does the amount of certified fiber (organic, recycled, etc.) entering a batch’s supply chain match the amount of certified product coming out?
This is only possible at the batch level (or higher). At the model level, anomalies disappear into statistical noise. A producer using mixed raw materials in only some batches remains invisible to a model-level system.
To my knowledge, Reeco is currently the only system implementing mass balance verification down to the individual unit (item level) as part of the DPP audit workflow. While a European consortium of 49 partners debates whether the batch level is too “expensive,” an operating system developed by a micro-enterprise in Prato has already surpassed it.
The Durability Problem: JRC Milestone 3
I previously critiqued the JRC Milestone 3 on textile durability on this Substack. The JRC methodology uses average performance values as proxies for durability, without disaggregating by batch origin.
This is the failure of model-level thinking: it relies on averages that hide real variance. A garment from a batch with superior yarn has a different durability than one from a different supplier six months prior. Batch-level captures this; model-level does not.
I have submitted my Durability Index V1.02 and Repairability Index V3.1 to Antonio Delre (JRC Seville, Unit B5) upon direct invitation. This contribution is formally documented in the CIRPASS-2 Milestone.
What Is Really At Stake on Tuesday
The March 31 meeting is a choice of field: do we want a DPP that works as a verification tool or a communication tool?
A model-level DPP is for communication. It’s fine for pre-purchase e-commerce but useless for Customs or the Finance Guard. A batch-level DPP is a verification tool. It is the only way to prove that the specific lot in front of you is what it claims to be.
My Position for March 31
I am not neutral. My contribution to the CIRPASS-2 survey (ID bb6997ac) documented the gap in batch-level certification. The system I built is designed for item-level granularity as the maximum available, with the batch as the minimum mandatory unit for any meaningful audit.
Furthermore, in my November 2025 contribution to the New Legislative Framework (NLF) revision (ID: 95bac2ed-47e7-4a88-aa0a-7437928777dd), I advocated for:
Integrating third-party certificates into the DPP for real-time verification.
Quantified benefits: 30-50% reduction in manual verification and 70% automation of cross-checks.
Circular-compatible identification: RFID tags create unresolved end-of-life issues (chip/antenna dispersion during recycling). Only a unique code on a label—preferably made of the same fiber as the product—is compatible with true circularity.
My stance for the meeting:
Model-level as the minimum for aggregated environmental data (PEF/LCA).
Batch-level as the mandatory minimum for traceability and anti-fraud. It must accompany every commercial shipment.
Item-level as a medium-term goal, supported by a funded transition plan.
Granularity is a political choice: do we protect consumers and honest businesses, or the opaque trade flows thriving in ambiguity?
246,860 spools seized in Prato. The case remains open.
Stefano Cipriani is the founder of Reeco (ia.reeco.eco), a JRC registered stakeholder, and a member of EWG1, EWG3, and EWG5 of CIRPASS-2.