Who owns the digital product passport inside your company?

Most companies that miss the digital product passport (DPP) deadline will not miss it because of technology. They will miss it because nobody owned it.

The number

In a KPMG survey of more than 70 organisations across 13 European countries, conducted between September and December 2025, 23 percent of respondents reported that internal ownership of the DPP was "not assigned". The same survey found 23 percent had not started any preparation work at all.

Those two numbers are almost certainly the same companies. Nothing starts until someone owns it.

The sample is small, self-selected and weighted toward textiles and footwear, and KPMG sells DPP advisory services, so read it as directional. But the direction is unambiguous, and it matches what the structure of the problem predicts.

Why it stalls, structurally

The passport sits across four functions, and each has a legitimate reason to think it belongs elsewhere.

Sustainability owns the subject matter, the material and circularity data, but usually not the supplier relationships or the systems.

Supply chain owns the supplier relationships, which is where most of the data lives, but not the regulatory interpretation.

Compliance or legal owns the obligation, but has no operational authority to make suppliers respond.

IT gets handed the passport because it involves an interface, and inherits a data collection problem it has no authority to solve.

Sitting between four owners, the passport becomes everyone's job and therefore nobody's. It gets discussed in every quarterly review and advanced in none of them, until a tender or an auditor asks and there is no team, no data and no time.

What the owner actually needs

Naming someone is not enough if the name has no authority. Three things make the difference.

Authority over supplier data requests. The core of the job is getting evidence out of companies that have no obligation to prioritise you. That requires someone who can put requirements into supplier agreements, which usually means procurement backing.

A budget line. Not large, but real. Work without a budget line loses to work that has one, every quarter.

The right to say no. If the passport owner cannot refuse to publish an unevidenced claim, the control does not exist. Given that inaccurate passport data carries both regulatory and consumer liability, as set out in DPP penalties, that veto matters.

Where the owner usually sits

There is no single right answer, but there is a useful test: put it with the function that already owns the relationship with suppliers, and give it a reporting line to whoever owns market access.

The passport decides whether products can be sold. That makes it a commercial risk with a data dependency, not a data project with commercial implications. Companies that file it under IT find it competes with every other ticket and slips, which is the argument made in market access, not IT.

The cheapest decision available

Naming an owner costs one meeting. It is the only step in the whole programme with no lead time, no supplier dependency and no budget requirement.

If 23 percent of surveyed companies have not taken it, the more useful question is not whether your competitors are ahead. It is whether the answer at your company is a name or a discussion.

Sources

• KPMG, *European Digital Product Passport Readiness Survey*, published February 2026. Fieldwork
• September to December 2025, more than 70 organisations across 13 countries: 23 percent report DPP
• ownership "not assigned", 23 percent have not started any work.
• https://kpmg.com/xx/en/our-insights/esg/european-digital-product-passport-readiness-survey.html