CARE ID’s Review of CIRPASS-2 - Digital Product Passport Granularity Options for TextilesApparel 1.1 (5 Nov)

CIRPASS-2 has published a new recommendation paper outlining possible granularity options for Digital Product Passports (DPPs) within the European textile and apparel sector.

While these are not binding rules (EU DPP rules will be defined by the European Commission), the paper provides the clearest public guidance to date on how future DPP architectures may be structured.A key takeaway from the recommendations:

• Mandatory information → likely at model/batch level

• Product identification → expected at item level

• Item-level identifiers are encouraged as the long-term direction for DPP evolutionCARE ID has already adopted this architecture and is running item-level DPP pilots with multiple Korean fashion brands to validate it across production, retail, and after-care environments.

1) Why “information” ≠ “identification”The paper recommends separating:

• Model/Batch-level information

(PCF, materials, durability, testing)

• Item-level identifiers

(repair, resale, ownership, take-back, lifetime, anti-counterfeit)This separation is essential for circularity. CARE ID has followed this distinction from the beginning.

2) Model-level — efficient but limitedModel-level data aligns with ERP/PLM systems and supports e-commerce and environmental averages.

However, it cannot track:

• specific fibres or factory lots

• individual product lifetime events

• repair, resale, take-back historiesIt is suitable for compliance, but insufficient for circular business models.

3) Batch-level — theoretically precise, practically inconsistentThe paper points out that there is no single harmonised definition of “batch” across industry or regulation

(ESPR batch ≠ factory batch ≠ shipping batch ≠ internal lot).This inconsistency complicates label production, logistics, and traceability.

Thus, batch-level granularity can be useful for information, but is not ideal for product identification.

4) Item-level identification — foundational for circularity

CIRPASS-2 encourages item-level identification because functions required by ESPR’s long-term goals rely on it:

• Repair & service events

• Resale & transfer-of-ownership

• Take-back & EPR settlement

• Lifetime & durability traceability

• Anti-counterfeit & grey-market control

None of these are feasible at model or batch level.The paper also notes that serialisation costs are modest (~USD 5 per 1,000 labels; dropping to ~USD 3 at scale), though SMEs may still require support.

Similar challenges appear in Korea, where institutional assistance is often necessary for item-level DPP adoption.CARE ID’s Circular Fashion Solution and low-burden serialisation workflow were developed to reduce this barrier for SMEs and export-oriented brands.