When the lab and the supplier disagree
Below the tolerance the two values are both correct and there is nothing to resolve. Above it the position of the party placing the product on the market has already changed, on the day the result was issued rather than on the day somebody reads it. Nothing in law says a test beats a declaration, so the work sits in a sequence of gates rather than in a hierarchy of sources.
In 60 seconds
An accredited result that differs from a supplier's composition statement is not automatically a contradiction. The textile fibre labelling regulation sets tolerances, and inside them a declared value and an analysed value are both correct at the same time. So the first question is arithmetic rather than legal: how far apart are the two numbers, and were they produced by the same method.
- Manufacturing tolerance: three per cent of the stated composition, compared against the prescribed method.
- Extraneous fibres: two per cent of the weight of the textile product, rising to five per cent for carded products. Both conditions have to hold.
- The two tolerances may be applied cumulatively only where the extraneous fibres are of the same chemical type as fibres already named on the label.
- A Commission joint enforcement campaign recorded 49 of 132 garments as non compliant. It does not state the tolerance thresholds it applied.
- Not established: what becomes of stock already shipped. No provision read here ranks a test above a declaration or the reverse.
Above the tolerance the position changes, and it changes on the date the result was issued rather than on the date somebody acts on it. The same instrument places accuracy on the party placing the product on the market, which means an inaccurate statement is inaccurate whether or not anybody has noticed. Almost nothing written about supplier evidence says this part out loud.
Neither of those sentences settles which of the two numbers is true. That is a separate question with a worse answer, and it is the subject of the last section on this page.
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A declaration and a test result are not the same kind of object
A composition statement is an assertion about what a style is made of. A test report is a measurement of a sample, by a named method, on a named day. Setting the two side by side and calling the difference an error assumes they were trying to measure the same quantity, and often they were not.
The regulation does not leave the method open. It prescribes how a composition is determined for the purposes of the instrument, on a stated mass basis, after specified non fibrous matter has been removed and with defined allowances applied. A result produced by a different preparation, or by a method the report does not name, is a number about a different quantity. It can still be useful. It is not a like for like contradiction of the declaration.
Three separations do most of the work here, and only the third of them is arithmetic.
- What was measured. A sample of a fabric, a garment as constructed or a single component. These give different answers on the same goods and none of them is wrong.
- By what method. The prescribed one, an in house one or one the report leaves unstated.
- Against what statement. The composition as stated on the label, or a value in a specification that was never on a label at all.
Sorting a report into the right one of those before comparing anything is the step that dissolves most apparent conflicts. What each kind of document was produced by, and therefore what it establishes at all, is set out on what each document is worth.
One product. Two answers. No hidden guess.
When credible sources disagree, a useful product record shows the disagreement and the next decision. It does not make up a cleaner answer.
Illustrative example. Fictional product and evidence, not a captured engine result.
The same fact is under review
Body-fabric composition
Zip hoodie HX-01 · Navy · Size M · Batch B-2609
Scope: body fabric only, excluding cuffs and trims.
Supplier declaration
80% cotton / 20% polyester
- Issuer
- Example supplier
- Issued
- 10 September 2026
- Evidence
- ILL-DECL-014
- Covers
- HX-01 · Navy/M · Batch B-2609 · Body fabric
Laboratory report
65% cotton / 35% polyester
- Issuer
- Example laboratory
- Issued
- 18 September 2026
- Evidence
- ILL-LAB-027
- Covers
- Sample ILL-SAMPLE-027 from HX-01 · Navy/M · Batch B-2609 · Body fabric
Comparison check: this example assumes matching product and component scope, a comparable mass basis and the applicable method checks. The difference is not explained by the relevant tolerance in this example. A different batch, scope or method can change the conclusion.
Conflict retained
Both values. Both sources. Both dates. No averaging, no silent overwrite and no winner chosen solely because its document is newer.
Action required: resolve the composition
Confirm the evidence scope with the responsible owner and obtain the correction or further evidence needed to support the composition. Record the reason for the outcome and retain the earlier evidence. No single composition is approved in this example.
Fictional example of a governed evidence decision. Matching scope, method and tolerance checks are assumed; this is not a product compliance verdict or a captured engine result.
Keeping a conflict is not permission to publish an unsupported mandatory value or place a product on the market. The applicable rules and publishing checks still decide what may be published.
Governed resolution makes progress without losing the evidence or disguising the decision still needed.
Use this test when choosing DPP software
For the evidence behind the decision, read what each document can establish and who owns a published field. To see the rest of the product record, start with the data you already have.
Two tolerances, doing two different jobs
There are two tolerances and they measure different gaps. Manufacturing: three per cent of the stated composition, compared against the prescribed method. Extraneous fibres: two per cent of the weight of the textile product, rising to five per cent for carded products, and only where both conditions hold: the fibres are technically unavoidable in good manufacturing practice and not added routinely. Why the carded figure is higher, with the article numbers, is on fibre composition.
Drawn out, the manufacturing tolerance is a band around the declared value rather than a threshold under it. That shape is the reason a difference in either direction can sit inside it.
Everything above is about one attribute. Fibre composition is the claim family we have found in EU law that carries both a prescribed test method and a prescribed tolerance, which is why a disagreement about it has a procedure and a disagreement about most other attributes does not. The field itself, including how a declaration is read before any of this arises, is on fibre composition.
The two may be added together only in one circumstance
The regulation says when the tolerances may be applied cumulatively, and the gate is narrower than most summaries of it. They may be applied together where the extraneous fibres found are of the same chemical type as fibres already named on the label. Outside that circumstance the two allowances are separate and stay separate.
Adding them outside that circumstance is the comfortable error: two plus three per cent feels like a five per cent cushion, eight for a carded product, and the instrument grants neither. The gate is a test about chemistry, set out on fibre composition.
What changes on the day the result is issued
Where the difference sits outside the tolerances, the accuracy of the composition statement is a duty of the party placing the product on the market, and that duty does not wait for an enforcement authority to arrive. The declaration a supplier sent does not carry the duty across. It is evidence about what the supplier said.
So the state of the goods changes at the moment the result is issued rather than at the moment somebody opens the report. A brand that has the result and has not read it is in the same legal position as one that has read it.
Two things are not established. What becomes of stock already shipped when a result lands is not settled by anything read for this page, and the answer probably differs by market and by channel. Whether any rule exists for turning a batch level measurement into a fact about every item in a style is a question we looked for and did not answer; no instrument read here supplies one and no schema examined here carries one. How the estate types absences of that kind, and why not found by us never becomes there is none, is on how we know.
How often the two disagree, and what that measurement cannot tell you
A Commission joint enforcement campaign on textile labelling recorded 49 of 132 garments as non compliant, on a sample drawn across several member states rather than a market. It doesn't state the tolerance thresholds it applied, so that's a count of recorded non compliance, not a rate of wrongness. Its gradient across three bands of declaration complexity is on fibre composition.
One attribute where this conflict cannot arise
Recycled content does not produce this problem, and the reason is not that the paperwork is better. It is that nothing can contradict the paperwork. A preparatory study informing the textile decision reports that no laboratory test at scale determines whether a fibre is recycled or virgin, and we reached that study through a testing house summary rather than at the document itself.
If that holds, there is no second value for a declaration to disagree with. Verification rests on chain of custody records, which are documents about volumes and about parties rather than measurements of a garment. A disagreement between two such records is a disagreement about bookkeeping, and none of the machinery on this page applies to it.
That is a different problem with a different shape, and it belongs to the field rather than to this page. What a chain of custody record supports, and the gap between a mass balance position and an identity preserved one, is set out on recycled content.
The procedure, with its states named
Five gates in order, and two terminal states. The order matters because each gate can end the question before the next one is reached, and because the arithmetic gate is fourth rather than first. A great many disagreements never get as far as the numbers.
Naming the state when two values disagree
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1Is the evidence about this product at all?
- The report names this style, this batch and this materialThe two values describe the same object and the comparison can proceed.
- The report names a different batch or a different materialThere is no contradiction to resolve. A measurement of other goods says nothing about these ones.
- The report does not say what it coversScope is unstated rather than wide. The state is an absence rather than a conflict, and it is the report that has to be corrected.
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2Were the two numbers produced by the same method?
- The prescribed method, on the prescribed mass basisThe comparison is like for like and the tolerances are the right instrument to reach for.
- Some other method, or an unstated oneTwo measurements of different quantities. The regulation prescribes a method with a stated mass basis, defined removals and defined allowances. A result from anything else is not a contradiction of the declaration.
- The report does not name a methodNothing can be concluded either way. A result with no method is not evidence about composition.
SourceRegulation (EU) No 1007/2011 on textile fibre names and related labelling, consolidated textChecked 28 August 2026
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3Do the two values describe the same object?
- Both describe the same unit or the same production runThe scopes match and the numbers can be set against each other.
- One is a batch result and one is a style level statementThe comparison crosses a level. No instrument read for this page supplies a rule for turning a batch measurement into a fact about every item in a style.
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4How far apart are the two numbers?
- Inside the manufacturing tolerance of three per cent between stated and analysed compositionThis is not a conflict. Both values stand, and the regulation permits the difference.
- Outside it, and the extra material is extraneous fibre within its own toleranceThe extraneous fibre provision is a separate allowance with its own conditions, and it is not a second slice of the same allowance.
- Outside bothThe difference is not permitted by the instrument, and the accuracy duty on the party placing the product on the market is engaged from the date of the result.
SourceRegulation (EU) No 1007/2011 on textile fibre names and related labelling, consolidated textChecked 28 August 2026
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5Which measurement describes the goods as they are now?
- The result post dates the last change of material, supplier or processIt describes current production and the declaration is the older object.
- The result pre dates a change nobody recordedNeither value describes current production, and the state is not established rather than conflicted.
This names the state. It does not settle what becomes of goods already shipped, which is not established anywhere we looked, and it carries no rule for turning a batch result into a product fact, because no instrument read for this page supplies one.
The same discipline is what makes a product record defensible: every value keeps which source it came from, so a disagreement between two documents is visible instead of silently resolved.
A disagreement that survives the five gates is retained as a conflict, with both values, both sources and both dates kept. The record does not force a convenient single answer. Whether the unresolved state may appear in a particular published output is a separate decision under the applicable rules and publishing checks; retaining a conflict is not permission to publish an unsupported mandatory value.
ActivateDigital can build from existing product data without hiding disagreements, preserving the competing evidence instead of silently choosing a convenient answer.
What this page does not say
Three things, and the first of them is the one most likely to be read into the page anyway.
There is no universal source precedence rule
Nothing says a test beats a declaration, and nothing says a declaration beats a test. No provision read for this page establishes an order between sources. No published passport data model we examined carries a precedence concept, a source rank or a conflicted state at all, which is a gap in those models rather than evidence that the question does not arise. We publish that as a finding rather than leaving it to be inferred from silence, and where we looked is on the source list below.
What the regulation supplies instead is narrower and more useful: a prescribed method, two tolerances, a gate on combining them and a duty of accuracy that sits with one named party. Those settle whether there is a conflict. They do not settle which value is true, and the honest procedure has a state for that.
Nothing here is advice about a particular product
This page sets out what the instrument says and what the states are called. It does not tell anybody whether to ship, relabel, retest or stop on goods sitting in a warehouse, because that turns on facts this page does not have and on legal exposure it is not qualified to weigh. Whether a value that survives the gates will support the claim being made on it is a further test again, and it is on whether the claim survives.
No rule for turning batch evidence into a product fact
Evidence is produced at batch or lot level because that is how goods are made. Claims are made at item or style level because that is how goods are sold. We looked for an aggregation rule that would make the join safe and did not find one, in the instruments read here or in the schemas examined here. Where the procedure reaches that boundary it names the limit and stops, which is a worse answer than a rule and a better one than a rule somebody invented.
The neighbouring case, where there is no second source to disagree with because nobody ever answered, has its own procedure and its own permitted outputs. It is on what you may publish when you do not know.
Keep exploring
The question this one usually raises next.
Also worth reading
- Another anglePassport informationThe field this happens toThe denominator, the closed list of legal fibre names and how a declaration is read before anybody tests anything.
- CompareEvidence & suppliersWhen there is no second value at allWhat may go in a field nobody can fill, with a statutory counterpart for a properly stated unknown.
What can you establish from what you already hold?
Every value ActivateDigital resolves keeps the document it came from, its state and its provenance. Anything unproven stays unproven.
Sources
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EU lawCELEX 02011R1007-20180215In forceRelevant provisions reviewed
The spine of this page. The provisions read at the consolidated text are the extraneous fibre tolerance with its carded variant and both of its conditions, the manufacturing tolerance between stated and analysed composition, the provision governing when the two may be applied together, the analysis provisions with the prescribed method annex, and the provision placing accuracy on the party placing the product on the market. Each is named on this page by what it does rather than by an article number, because the internal numbering has not been eyeballed against the Official Journal and inventing a citation would be worse than describing the provision. That check is open.
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Commission joint enforcement campaign on textile labelling, 2026Regulator publicationReached through a secondary reproduction, primary text not read
Here for one figure and for one absence. The figure is published with its denominator. The absence is that the publication does not state the tolerance thresholds it applied, which is why its headline is not republished here as a rate of wrongness. One sub figure in the same campaign rests on five garments and is not published by us in any form.
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Official studyPre-decisional researchReached through a secondary reproduction, primary text not read
Reached through a testing house summary rather than at the study itself, and the sentence on this page that rests on it says so. It carries one proposition here, that no laboratory test at scale determines whether a fibre is recycled or virgin, which is the reason one attribute cannot produce the conflict this page is about. It is pre-decisional and is never cited as law.
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Secondary sourcePublished data modelRelevant provisions reviewed
One of the public passport data models the estate positions against, and the only one of the four whose address is registered here. It is on this page for a negative finding rather than a positive one. It models neither a precedence order between sources nor a conflicted state, and the finding that no universal precedence rule exists rests partly on having looked at models like this one and not found it.