The job description for a Sustainability leader in a fashion or textiles organisation has changed more in the past five years than in the previous two decades. What was once a role centred on strategy and stakeholder engagement has been loaded with technical demands that few sustainability professionals were trained for and fewer still were resourced to meet. Verified supplier data. Granular environmental indicators. Product-level traceability reaching into tiers most brands have never directly engaged.

When a garment moves from a production facility to a distribution centre, an event occurs. When it is received, inspected, and logged, more events occur. When it is shipped to a retail partner, returned by a consumer, and routed to clearance or disposal, each carries data the passport will eventually need. Taken together, that sequence of events is the evidentiary backbone of any credible Digital Product Passport.

Most of that evidence is never captured in a form that serves any purpose beyond the immediate operational one.

A conversation happens with reliable regularity when a fashion or textiles organisation begins a data-related implementation. The scope is defined. The system is selected. The project plan is approved. And then, partway through, the implementation team discovers that the data the system needs to hold has never been properly defined — that two functions are working from different versions of the same information, and that the governance questions the project assumed had been answered were never asked.

Most of the data problems described in this cluster trace back, eventually, to the same place. A function without the evidence to support a claim. A system holding data that nobody owns. A supplier relationship that was never structured to produce the transparency now being asked of it. Follow those threads far enough and they tend to arrive at a sourcing decision — one made on cost and lead time, in a season where margin was tight and the data question was not yet on the agenda.

Procurement did not create the DPP problem intentionally. It created the conditions for it systematically, across seasons, in the ordinary course of doing its job as that job has historically been defined.

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.

There is a moment in every product's life when the data that will ever exist about it is largely determined. It is not the moment of manufacture, or the point of sale, or the date a compliance deadline falls due. It is the brief.

The materials specified at the brief stage define what composition data is collectable. The construction methods chosen determine whether disassembly and end-of-life data is meaningful or theoretical. The supplier relationships established for a new material set the ceiling on how far back in the supply chain traceability will ever reach. By the time a product enters production, many of the data questions the DPP will ask have already been answered — not by a data governance decision, but by a design one.

A pattern has become familiar in fashion and textiles organisations. A claim is going to market — on a product page, in a procurement tender, in an investor disclosure. Someone sends it to Legal for review. Legal checks the language, notes the risks, may soften a phrase or add a qualification. The claim goes out.

What Legal rarely gets to ask is the prior question: what is the evidence behind this claim, where does it live, who is responsible for keeping it current, and what happens when it lapses?

Finance is usually the last function to be engaged on DPP readiness. And it is usually engaged in a specific way: someone needs budget approval.

That is a limited role. It is also, given what is actually at stake, the wrong one.

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.