Export readiness · 03 of 10
4 min read
Model, batch, item: three levels, and the time they save you
The largest time saving in this whole subject comes from knowing which questions you answer once per style, which once per production run, and which you never have to answer at all.
Three levels, in the law's own logic
Recital 33 of the ESPR gives the working definitions. A model is a version of a product whose units share the technical characteristics that matter to the requirements. A batch is a subset of a model produced in a specific place at a specific moment. An item is one single unit. They are not our invention, and building on them keeps your records legible to anyone reading them later.
What sits at each level
Model level holds what is stable across a run: fibre composition, care, guarantee terms, durability and recyclability, footprint. Batch level holds what changes between runs: which workshop sewed it, where the cloth was woven, where it was dyed and finished, the recycled content certificate, the chemical test, the production date. Item level holds what belongs to one piece: a serial, a repair log, an ownership change.
The arithmetic, which is the whole point
A brand with 40 styles made across 6 production runs answers model questions 40 times and batch questions 6 times. That is 46 answers. Treat everything as batch level and the same work becomes 240 answers for the same information. The second version is not more rigorous. It is the version that never gets finished, and an unfinished record helps nobody.
Item level is optional, and it inherits
Per-piece records are voluntary today. The practical route, and the one the preparatory work describes, is inheritance: an item takes its batch's data and adds a serial. Worth doing for high value pieces, for resale, and for anything you expect to repair. Not worth doing for a run of tote bags, and nobody is asking you to.
The essentials
- Model, batch, and item come from the regulation, not from us.
- Ask each question at the level where the answer actually changes.
- Per-piece records stay optional, and they inherit from the batch.
Primary sources
- Regulation (EU) 2024/1781 (ESPR), Recital 33 and Art. 9(2)(d). Checked 17 August 2026
- JRC, study on digital product passport content for textile apparel products, 13 May 2026
Criteria here are drawn from the ESPR text and the JRC preparatory study. Sources last checked 17 August 2026, and re-checked at every JRC milestone. Binding requirements for textiles begin only after the textile act is adopted and its lead time has run.
Where we stand
Mula is not affiliated with the European Commission, the JRC, or any certification body. What we do is readiness: getting your own evidence into order. We are not an economic operator, we do not register products in any system, and we never state that a product meets a rule. That judgement belongs to the party placing the product on the market and to the authorities.
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