DPP Is Not Just the Sustainability Department's Problem

The Organizational Misassignment Slowing Brands Down

In most brands that are actively preparing for Digital Product Passport compliance, ownership of the DPP workstream sits with the sustainability team. This is understandable — DPP is associated with environmental transparency, circular economy, and green claims, all of which are natural sustainability department territory.

It is also a significant organizational mistake, and one that is quietly causing brands to underestimate the scope of the DPP challenge and move too slowly on the elements that matter most.

A compliant DPP is not a sustainability report. It is a data infrastructure that spans product development, IT systems, supply chain operations, legal and compliance, and manufacturing — simultaneously. Sustainability teams typically have neither the authority nor the technical resources to drive the changes needed across all of these functions. When DPP sits only with sustainability, the workstream stalls at the boundaries of what that team can control.

What DPP Actually Touches

To understand why DPP cannot be owned by a single department, consider what a compliant Digital Product Passport requires in practice:

• A unique serialized identifier on every product unit — a change to label production that affects product development, sourcing, and CMT factory operations
• Structured supply chain data at the facility level — data that lives in sourcing and procurement systems, maintained by sourcing teams
• Component-level material composition data — detailed product specification data that originates in product development and is held in PLM systems
• Chemical compliance documentation linked to individual products — owned by quality and compliance teams
• A real-time, API-accessible data endpoint — an IT infrastructure requirement
• Long-term data retention beyond commercial product lifecycle — a data governance and IT policy question
• Controlled multi-stakeholder data access — an IT architecture and legal requirement
• Dynamic data updates from repair and recycling operators — a supply chain and operations process design question

Of these eight requirements, sustainability teams can directly influence perhaps one or two — the content of sustainability certifications and environmental performance data. Everything else requires engagement from other functions that sustainability teams have no direct authority over.

DPP is a cross-functional data infrastructure project that happens to have a sustainability application. Treating it as a sustainability project that happens to need some IT support inverts the priority order and consistently produces under-resourced, under-scoped implementations.

Which Teams Own Which Parts of DPP

A well-structured DPP program assigns clear ownership to the function best positioned to deliver each component:

Product Development / Design

Owns: material composition data, component-level specification, care instruction content, repairability design intent, end-of-life design decisions.

Product development teams make the decisions that determine the largest portion of DPP content — what a product is made of, how it is constructed, and how it can be cared for, repaired, and eventually recycled. DPP data collection must be integrated into the product development process itself, not added as a retrospective documentation step. The data needs to be captured at the moment design decisions are made, not reconstructed months later from incomplete records.

Sourcing and Procurement

Owns: supplier registry, facility-level supply chain data, country of origin of materials, supplier certification management, supplier data-sharing agreements.

Sourcing teams have the supplier relationships needed to collect the upstream supply chain data that DPP requires. They are also the team with contractual leverage to require suppliers to provide data — through purchase order conditions, supplier codes of conduct, and supplier onboarding requirements. Without sourcing team engagement, supplier data collection stalls.

IT / Digital

Owns: data infrastructure, API development, system integration, identifier management, access control architecture, data retention policy implementation.

The IT function owns the technical infrastructure that makes a DPP actually function — the data store, the API endpoint, the resolver integration, the access management system, and the integrations with PLM, ERP, and compliance tools. DPP is, at its core, an IT project. IT teams need to be involved from the beginning of planning, not brought in at the end to "build a system" once other teams have defined requirements that may or may not be technically feasible.

Quality and Compliance

Owns: REACH compliance documentation, SVHC substance declarations, chemical test reports, conformity documentation, regulatory tracking.

Compliance teams hold the chemical and regulatory data that feeds the most sensitive DPP data fields — substances of concern, restricted substance compliance, conformity declarations. They also typically have the clearest view of the evolving regulatory landscape, making them important partners for tracking the Delegated Acts and understanding when methodology-dependent data requirements are confirmed.

Sustainability

Owns: environmental performance data, certification strategy, sustainability claims governance, Green Claims Directive compliance, proxy data methodology for internal use.

Sustainability teams are the natural owners of the environmental performance layer of DPP — carbon footprint data, recyclability assessments, circularity claims — and of the governance around what claims can legitimately be made given the current state of regulatory methodology. They are also typically the function most fluent in the regulatory context (ESPR, Green Claims Directive, EPR) that frames the DPP obligation.

Operations / Supply Chain Management

Owns: CMT factory coordination for serialized label implementation, production workflow changes, label supplier management, logistics data.

Operations teams must drive the production-side changes that serialized label introduction requires — coordinating with CMT factories, managing label supplier transitions, and ensuring the process controls needed for correct label-to-unit matching are implemented and maintained.

Legal

Owns: Green Claims Directive exposure assessment, supplier data-sharing contract terms, DPP service provider contract review, data sovereignty and GDPR compliance for DPP data.

Legal teams need to be engaged on both the risk side (what claims can the brand make in a DPP without Green Claims liability?) and the contractual side (what obligations does the brand need to impose on suppliers, and what does the DPP service provider contract actually commit to?).

Why Cross-Functional DPP Programs Stall

Even when brands recognize that DPP is a cross-functional challenge, implementation programs frequently stall for predictable reasons:

No Senior Sponsor with Cross-Functional Authority

When DPP ownership sits with a sustainability manager or director, that person typically has no authority to direct IT to build infrastructure, procurement to change supplier contracts, or operations to modify factory workflows. Without a senior sponsor — ideally at C-suite or VP level — who can direct resources and resolve cross-functional conflicts, DPP programs get stuck at the boundaries between teams.

IT Engaged Too Late

The most common failure pattern: sustainability or compliance teams spend months defining what data they need, then bring IT in to build the infrastructure. IT then identifies that the data model, access requirements, and integration needs have not been adequately specified — and that the timeline assumed by the other teams is not realistic. The engagement gap costs months that brands cannot afford as 2028 approaches.

Sourcing Teams Not Accountable for Data Quality

Supply chain data gaps are consistently the largest barrier to DPP completion. When sourcing teams are not accountable for the quality of supplier data — when data collection is left to the sustainability team to manage as best they can without direct supplier leverage — gaps persist and escalation is difficult. Sourcing teams must own supplier data as a sourcing function KPI, not treat it as someone else's problem.

Departmental Silos Recreated in the DPP System

When each team manages its own DPP data contribution independently, without a shared data platform and common product identifier, the siloed structure of the legacy IT landscape gets recreated in the DPP infrastructure. The result is multiple partial records rather than one complete, accurate DPP per product.

A Governance Model That Works

Brands that make the most progress on DPP preparation share a common structural feature: a cross-functional steering group with clear executive sponsorship and defined functional ownership for each DPP component.

The effective model includes:

• An executive sponsor — typically a C-suite or senior VP role with authority across the relevant functions — who is accountable for DPP compliance at the organizational level and can resolve cross-functional resource conflicts
• A DPP program lead — a dedicated program manager (not a sustainability manager wearing a DPP hat alongside other responsibilities) who coordinates across functions and manages the implementation timeline
• Functional workstream owners — named individuals in IT, sourcing, product development, compliance, and operations who are accountable for their function's DPP deliverables
• A shared data platform — a single DPP data environment (built internally or provided by a service provider) that all functions contribute to, rather than parallel data management processes that need to be reconciled
• Defined data ownership rules — clear documentation of which team is the authoritative source for each category of DPP data, and what the process is for resolving conflicts when sources disagree

The Practical Starting Point

For brands that currently have DPP sitting entirely within the sustainability function and want to restructure appropriately, the starting point is a cross-functional scoping exercise:

1. Map the DPP data requirements to internal data owners. For each of the nine DPP data categories, identify which internal team currently holds the relevant data and which team would need to be involved in collecting or maintaining it going forward.
2. Identify the cross-functional dependencies. Which DPP deliverables require IT? Which require sourcing? Which require legal sign-off? Mapping these dependencies makes the cross-functional scope visible — often for the first time.
3. Bring the map to a senior decision-maker. The scoping output is the business case for appropriate executive sponsorship and resource allocation. DPP compliance cannot be resourced at the sustainability team budget level — it is a company-wide infrastructure investment.
4. Establish functional ownership before selecting a platform. Platform selection decisions made before governance is established tend to optimize for the preferences of the team making the decision (usually sustainability), rather than the technical and operational requirements of the broader program.

Frequently Asked Questions

Can a small brand manage DPP preparation with a small team?

Yes — but the cross-functional scope doesn't shrink just because the organization is smaller. In a small brand, one person may wear multiple hats (sourcing and sustainability, for example), but the functional domains that need to be covered remain the same. The risk in small organizations is that DPP lands on whoever has the most bandwidth at a given moment, rather than being owned by whoever is best positioned to drive each component. Clear ownership — even if held by a small number of people — is what determines whether preparation progresses.

Should DPP ownership move from sustainability to IT?

Not necessarily — neither function should own DPP exclusively. The most effective model places program ownership with a cross-functional role or a dedicated program manager who reports to senior leadership and coordinates across IT, sustainability, sourcing, and operations. If forced to choose a single home, IT is often better positioned to own the infrastructure decisions — but the content and data quality decisions require sustainability, sourcing, and compliance engagement that IT teams typically do not have the domain expertise to drive.

Is DPP preparation a project or an ongoing operational capability?

Both. There is an initial project phase — building the data infrastructure, establishing supplier data collection, introducing serialized labels — that has a defined scope and timeline. But DPP is also an ongoing operational capability: data must be maintained and updated as products move through their lifecycle, new products must be onboarded into the system with each season, and the system must evolve as regulatory requirements are confirmed and updated. Organizations that treat DPP as a one-time project will find themselves out of compliance as their product range changes and dynamic data requirements accumulate.