The Most Public Casualty of a Data Gap
Sustainability claims are among the most visible things a fashion brand puts into the world — on product pages, in campaigns, in investor communications, in the retail partnerships that carry the brand narrative furthest from its source. They are read by people with very different reasons for doing so: consumers, journalists, regulators, competitors. Of all the functions that carry exposure from poor product data, Marketing carries the most public version of it.
That exposure is not new. What has changed is that the evidentiary bar for those claims is now being drawn in law — and most Marketing functions have been operating well below it without knowing it.
The pattern is consistent across the industry. A sustainability claim enters the brand narrative — a material sourced responsibly, a product made with reduced impact, a supply chain committed to transparency. The claim is accurate in intent. It reflects a genuine aspiration, often a genuine effort. What it typically does not reflect is a documented evidence chain that could be produced on demand, reviewed against current supplier information, and defended in front of a regulator who now has statutory authority to demand it.
The Green Claims Directive exists because this gap between claim and evidence is structural, not incidental. Its finding — that a majority of sustainability claims in the market were vague, misleading, or unverifiable — was not a finding about bad actors. It was a finding about an industry norm. Marketing has been making claims the evidence infrastructure of most organisations cannot support, not out of dishonesty, but because nobody asked whether the infrastructure existed before the claim went out.
The DPP changes that calculus directly. A digital passport is a published, product-specific, retrievable data record. A sustainability claim made in a campaign that conflicts with, or cannot be substantiated by, the data in that passport is not a messaging problem. It is a legal one. The claim and the evidence are now linked in a way they have never been before — and that link is accessible to anyone with a phone.
What makes this particularly acute for Marketing is the longevity of claims. A campaign runs for a season. The product page may remain live for years. The sustainability narrative built around a specific supplier, material, or manufacturing commitment does not automatically update when the underlying reality changes — when a certification lapses, for instance, or a supplier quietly substitutes an input mid-season. Marketing is typically the last function to know when that happens, and the first to carry the consequences when the gap becomes visible.
Legal's evidentiary standard — examined in an earlier article in this cluster — applies here with full force. The question is not whether the claim was accurate when it was made. It is whether it is accurate now, and whether the organisation can demonstrate that it is. Most Marketing functions have not been given the infrastructure to answer that. They have been given sign-off processes that review language, not evidence.
The reframe the DPP enables — and that the best-positioned brands are already beginning to make — is that verified product data is not a constraint on the brand story. It is the foundation that makes the story holdable.
A brand that genuinely knows its products — their composition, their provenance, their environmental footprint — is a brand whose sustainability narrative does not need to be carefully qualified. It does not need to hedge. It does not need to rely on the reader's willingness to take the claim on trust. The data exists. The claim rests on it. The story becomes more compelling, not less, because it can be demonstrated rather than merely asserted.
That is a different relationship between Marketing and data than most organisations have built. It requires that the evidence infrastructure be developed before the claim — which means Marketing needs a seat at the table earlier in the product development process than it typically occupies. The decisions that determine what Marketing will eventually be able to say truthfully, and defend credibly, are made upstream, before the brief is set and before the sourcing terms are agreed. Marketing rarely shapes those decisions. It inherits their consequences.
The brands that build that capability are accumulating something their competitors will find difficult to replicate quickly. Consumer scrutiny of sustainability claims is intensifying, and retailer and investor qualification processes are beginning to follow — turning on verified data rather than brand narrative. An organisation that can demonstrate the claims it makes — not assert them, demonstrate them — occupies a different competitive position from one that cannot.
The organisations that cannot will not simply face a compliance problem. They will find the brand narrative they have built, claim by claim over years, becomes a liability at the moment it is most needed — when a regulator asks for the evidence behind a published claim and the organisation discovers it cannot produce it. A data gap that was invisible in normal operations has a way of becoming very visible at exactly the wrong moment. Marketing, as the function whose name is on the claim, carries that moment most directly.
Verified product data does not constrain the brand story. It is what makes the story worth telling.
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.
Photo by Phillip Flores on Unsplash