Does each size and colour get its own product passport?

What you must do concretely

What is expected of you

A collection usually consists of one model in multiple sizes and colors. The question of whether each variant receives its own passport is fundamentally about Article 12 of the ESPR (Regulation (EU) 2024/1781), on the unique identification code, and Article 11 of the ESPR, on the technical design of the passport. These two articles together determine how granularly a passport must be assigned.

Each product with its own characteristics receives its own identification code

Article 12 of the ESPR requires that a product be identifiable via a unique identification code, which in turn links to the passport. A size M in black color is not automatically identical to a size L in white color, given material, composition, or other regulated characteristics. For a company with 10 to 100 employees, this means that assigning codes is not a one-time action per collection, but a recurring task per variant that actually differs in the data the passport must display. How that code is precisely constructed and assigned is described on the page about how you give each product a unique identification code.

The passport may contain shared data at product group or model level

Article 11 of the ESPR allows room for a technical setup in which a passport refers to data that apply to a whole group of products, provided the unique identification code of the individual product remains recognizable. This is relevant for collections: some of the information — fiber composition, washing instructions, country of production — is often identical for size S and size XL, while other data, such as a batch number, may differ per variant. For a company, this means the question is not "one passport per product or one for the entire collection," but which data are recorded and reused at which level.

The link between variant and passport must be correct when scanned

What the customer scans must correspond to the passport that belongs to that specific item. This concerns how the QR code ends up on the garment and which code is behind it. Companies working with an external platform typically provide the correct data per variant so that the data carrier does not accidentally refer to the wrong size or color. More on that step is on the page about how the QR code for the product passport comes onto clothing and textiles.

Where things go wrong in practice

A common situation is that a collection with ten colors and six sizes is treated in practice as "one product," with one code for everything. Once a customer scans a specific item and the displayed composition does not match the garment worn — for example, because a color variant has a different weave — a discrepancy arises between what the passport says and what the product is.

A second situation is adding a new size or color to an existing collection after the fact, without creating a new code and new or modified passport. The new variant then shares the code of an existing variant, which is confusing once someone wants to check the origin or composition of that specific item.

A third situation arises with private label: different importers have the same basic model produced, each under their own brand and with minor variations in fabric or finishing. When those importers adopt the identification codes of the manufacturer uncritically without linking them to their own brand data, there is a risk that two different products from two different companies refer to the same passport.

A fourth situation is technical in nature: a collection is linked to an ERP system in which variants are maintained at SKU level, but the link between SKU and passport ID is not consistently established. During a system update or migration, some variants then lose their link or are assigned the code of a different size. Anyone wishing to assess this link will find background information on the page about linking the product passport to its own ERP or inventory system.

A fifth situation arises with collections that are phased out over time: a size or colour is no longer sold, but the passport remains necessary for items already with the consumer. If the variant is then inadvertently treated as "removed" rather than "no longer produced", access to information that remains relevant for existing owners disappears.

What you can record

• A variant overview per collection, with for each size and colour the unique identification code and an indication of which data are shared with other variants and which are not.
• A fixed procedure for assigning codes to new variants, so that a size or colour added at a later stage does not inherit the code of an existing variant.
• An overview of shared versus variant-specific data, for example fibre composition as shared data and batch or production number as variant-specific data, consistent with the structure that Article 11 of the ESPR permits.
• Agreements with the manufacturer or importer about who assigns the code, especially in the case of private label, so that two parties do not independently issue codes for what is ultimately the same or slightly different product.
• A control point at collection changes, whereby when a variant is added, modified or phased out, it is recorded what happens to the associated passport.
• Documentation of the link with its own system, so that in the event of a system change or update, it can be traced which SKU corresponds to which identification code and which passport.

Anyone in doubt as to whether a particular variant already falls under the rules can first check whether the underlying product itself falls within the scope via the page on whether the digital product passport applies to specific clothing and textile, before time is invested in setting up codes and data per variant.