The Decision Nobody Has Made — What the DPP Requires of Leadership
Every organisation preparing for the Digital Product Passport eventually arrives at the same discovery. The data needed to populate a credible passport exists — in fragments, across functions, supplier relationships, and systems that were never designed to work together. Sustainability has some of it. Procurement has some of it. Operations has some of it. IT is maintaining the systems that hold pieces of it. Nobody has all of it. Nobody is accountable for it end to end.
That condition has a name. It is a leadership decision that has not been made.
The articles that follow this one examine the data capability problem through the lens of specific functions — what Finance carries without the right framing, what Legal is asked to certify without the underlying evidence, what IT is expected to implement without the organisational mandate to govern what the systems hold. Each of those functional pressures is real. But they share a common origin: an organisation that has never decided, at the level where such decisions belong, to treat product data as an asset it owns and is responsible for managing.
That decision has not been deferred because the data problem was invisible. It has been deferred because the cost of not making it has, until recently, been possible to absorb. Sustainability filed the report. The audit passed. The certification was issued. The structural weakness beneath each of those outcomes — that the data assembled for one purpose was never built to serve another — stayed hidden because nothing tested it directly.
The DPP tests it directly.
What the DPP requires at organisational level is not primarily a technology decision or a compliance project. It is a governance decision: who owns product data, with what mandate, what resources, and what accountability? That question does not have a functional home. It cannot be delegated to IT, or to Sustainability, or to the DPP implementation team. It belongs to leadership — because only leadership has the cross-functional authority to assign accountability that crosses functional boundaries. And only leadership can hold those accountabilities in place when the commercial pressures that routinely displace data quality from the agenda reassert themselves.
The organisations making genuine progress on DPP readiness share a recognisable characteristic. Somewhere in their leadership structure, someone has looked at the data capability problem in its full organisational dimension — not as a compliance project, not as an IT implementation, but as a strategic condition — and made a decision about it. Not a perfect decision. Not a complete one. But a decision: this is what we are going to treat as an asset, this is who owns it, this is what we are investing in it.
That decision changes everything downstream. It changes what IT is mandated to govern rather than merely store. It changes what Procurement is asked to build into supplier relationships rather than trade away for cost. It changes what Legal is given to work with rather than asked to conjure under pressure — and what Sustainability is expected to produce and what organisational conditions exist to make that expectation realistic.
The first-mover argument carries particular weight at leadership level. The governance, culture, and organisational habits that make data trustworthy cannot be installed. A system can be deployed in months. The shared definitions, the cross-functional accountability, the supplier relationships built around data quality rather than commercial terms alone — these take time. They compound. An organisation that begins building them now, under difficult conditions, is not simply preparing for a regulation. It is accumulating a capability that organisations starting later will find expensive and slow to replicate.
The organisations that will navigate the full DPP trajectory — through the first enforcement window, into the deeper requirements that follow, and toward the circular economy framework beyond that — without rebuilding at each phase are the ones that built the underlying capability rather than chasing successive deadlines. That is not a compliance observation. It is a strategic one. The difference between those two paths will be determined, in most cases, by decisions made or not made at leadership level in the next two to three years.
The cost of not deciding is not neutral. It compounds in the same way the capability does — quietly, across functions, in the widening gap between what the organisation claims to know about its products and what it can demonstrate. At some point that gap becomes visible in ways that are difficult to manage: in enforcement exposure, in procurement processes that turn on verified data the organisation cannot produce, in investor scrutiny that looks past the sustainability narrative to the evidence infrastructure beneath it. The organisations that arrive at that moment unprepared will not simply face a compliance problem. They will face a competitive one.
The articles that follow in this cluster examine each function's specific stake in the data capability problem. They are not independent pieces. Each one is a different expression of the same organisational condition — and a mirror held up to the decisions that created it. The question each article implicitly asks of leadership is the same: knowing this, what has been decided, by whom, and with what mandate?
That is the question the DPP is now making unavoidable.
Michael Shea is a digital excellence advisor, non-executive director, and leadership coach working with organisations navigating the human and technical dimensions of digital transformation. He hosts The Aeolian Discourse and writes at The Aeolian.