Two questions arrived this past week, from two different organisations, both actively engaged with their Digital Product Passport readiness. The first: "Do you think there is a reasonable chance the implementation date gets pushed back?" The second, from a different conversation entirely: "It's two years before I need to worry about this."

Both questions are understandable. Neither reflects the situation accurately.

It is worth being generous about how the Digital Product Passport has been understood — or misunderstood — by many of the organisations now trying to prepare for it. The early conversation around the DPP was dominated by its most visible feature: a data carrier, typically a QR code, attached to a product and scannable by anyone in the value chain.

That reading was not unreasonable given what was publicly visible at the time — but it was the wrong one.