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The Downpass is a standard where traceability is largely based on inspection of documentation rather than physical inspection of farms. The main module does specify inspections of slaughtering facilities to verify that the down was sourced post-slaughter, but it does not include farm checks. If brands want farm audits or want to exclude foie gras they have to ask for additional modules. Consumers cannot clearly see which modules a company implements.

A new version of the Downpass standards is due in 2017. This version is expected to prohibit live plucking and force-feeding, which would represent a significant improvement compared to the current requirements. However, we believe the inspections envisaged (only every two years, with little rigour as regards the choice of sampling methods) to be insufficient, and weak in comparison to stricter standards already present in the market.