Who Actually Owns Your DPP? Nobody. And That Is a Bigger Problem Than You Think.

Let me paint you a picture.

It is a Tuesday morning. Someone senior has just come back from a conference and announced that the brand needs to get moving on Digital Product Passports.

Everyone in the room nods. The meeting ends. And then the most expensive game of pass the parcel in your company's history quietly begins.

Sustainability assumes it lives in IT. IT assumes it lives in Compliance. Compliance assumes Product is leading it. Product is waiting for someone from Sustainability to send a brief.

Nobody sends the brief.

Six months later, nothing has happened except a very long email chain and a vague sense of collective guilt.

Sound familiar? You are not alone.

This is so common that people working in DPP implementation have a name for it: the hot potato effect. And it is one of the single biggest reasons brands that want to be ready for the EU's incoming regulations are going to find themselves scrambling.

Here is the thing though. This is not a technology problem. It is not a data problem. It is a people problem. And people problems are actually the ones I am best placed to solve.

So what even is a DPP, and why does it matter who owns it?

A Digital Product Passport is essentially the life story of a physical product. Where the raw materials came from, how it was made, what is in it, how to repair it, how to recycle it at the end of its life.

Example DPP - Created with Gemini Nano Banana Pro

Think of it as a QR code on a label that, when scanned, tells the full truth about that jumper rather than just "hand wash cold."

The EU's Ecodesign for Sustainable Products Regulation, known as ESPR, is the legislation that makes this mandatory. Unlike a lot of EU sustainability regulation that has been delayed, watered down or quietly shelved, ESPR is on track.

Mandatory implementation is expected by 2027, with full DPPs required by 2030. The ban on destruction of unsold textiles and footwear hits in July 2026 for large companies.

The window to get ahead of this strategically rather than reactively is not as wide as it looks.

But here is why ownership matters so much. A DPP is not a sustainability project with a QR code bolted on at the end.

It is a data programme that touches design, sourcing, IT systems, marketing, compliance, logistics and your supplier relationships all at once.

If it is not owned by someone with enough authority and cross-functional reach to bring all of those teams together, the data never gets collected, the pilots never get past the pilot stage and you end up with a very expensive label that says very little.

What does good look like?

The brands doing this well are doing three things differently.

First, they are treating it as a data programme, not a QR code project. The QR code is the output. The actual work is understanding where your product data lives, who holds it, what the quality is like and how to get it into one place. Start there.

Second, they are not waiting for perfect regulation. There is enough guidance already published by the EU's Joint Research Centre to start auditing your data gaps now. The brands that are piloting and learning will be in a completely different position to the ones waiting for every last data point to be confirmed.

Third, and most importantly for this piece, they have identified a named sponsor. One person with the mandate, the seniority and the brief to convene the right people and keep momentum going. Not a committee. Not a working group that meets quarterly. One human being who owns it.

The cross-functional bit is not optional

This is where a lot of brands underestimate the scale of change involved. A DPP implementation is not just an IT infrastructure project or a sustainability reporting exercise.

It is a change management programme that will require your design team, your buying and merchandising team, your digital and ecommerce team, your retail operations team and your supplier base to all be working from the same playbook.

That takes time to build. It takes trust. It takes someone who understands both the commercial context and the sustainability strategy well enough to translate between the two and make the case to each function in language that actually lands.

Getting that alignment in place before the regulatory pressure arrives is not just sensible. It is a genuine competitive advantage. The brands that have already done the internal groundwork will be able to move faster, collect better data and tell a more credible story to their customers.

The ones that start when the deadline is six months away will be doing everything in a rush, at a higher cost, with lower quality data and a team that resents the project before it has even launched.

The practical starting point

If you are reading this and thinking "we are very much in hot potato territory," here is where to start.

Book a meeting with the heads of IT, Sustainability, Compliance, Product and Marketing in the same room. Not to make decisions, but to agree on one thing: who is the named lead and what does their mandate look like?

From there, run a basic data audit. Where does your product data currently live? How complete is it? How consistent is it across your SKU range? That exercise alone will tell you more about your DPP readiness than any amount of regulation-watching.

And if you want a structured way to do that without it turning into a six-month project in itself, that is exactly what we help brands do.

DPPs are not coming. They are already here.

The luxury houses are already doing this. Smaller independent brands are already doing this. Nobody's Child started with a spreadsheet and a basic product information page and built from there. Tom's Trunk did not have a mega budget. What they did have was a decision to start.

The question for your brand is not whether you will need to implement a Digital Product Passport. It is whether you will do it in a way that creates genuine commercial value or in a way that just keeps the regulator quiet.

The difference between those two outcomes often comes down to one thing: deciding, clearly and soon, who actually owns it.

Ready to stop passing the parcel? Book a free 30 minute DPP readiness call and leave with a clear first step.

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