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.

There is a version of DPP compliance that is technically achievable without being meaningfully useful. It involves populating a digital passport with data — material composition figures, environmental indicators, supply chain references — that is structured correctly, formatted to specification, and present in the required fields. The passport exists. The QR code resolves. The auditor can see the record.

The data behind it is estimated, aggregated, unverified, or last updated three seasons ago.

Ask most fashion brands how well they know their Tier 1 suppliers — the manufacturers assembling the finished product — and they will point to audit programmes, compliance certifications, and supplier codes of conduct. The picture there is generally tractable. Not always complete, not always current, but navigable. The relationship exists. The commercial leverage exists. The conversation, however imperfect, can be had.

Ask the same brands about Tier 2, the information is thinner, the verification harder, the accountability less direct.

Most fashion organisations collect a great deal of data. They collect it for audits, for certifications, for sustainability reports — for whatever the immediate requirement happens to be. The data gets assembled, the purpose gets served, and then — in the vast majority of cases — the data sits. It is not connected to anything else. It is not maintained. It is not treated as having any value beyond the task that prompted its collection.

This is not negligence. It is a rational response to how data collection has been structured.