By role

Five mandates, five different first ninety days

The same regulation lands very differently on a compliance lead who owns the obligation and a supply chain director who owns the data. These are written for the person, not the topic.

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Playbooks: 5
Horizon: First 90 days
Pitfall: Named on each

Definition

Which department should own a Digital Product Passport programme?

Compliance owns the obligation, but the data sits in sourcing, product development and sustainability. Programmes stall where compliance is made accountable without authority over the teams holding the attributes, so ownership should be assigned per attribute rather than per project.

That single misalignment accounts for more delayed programmes than any technical problem. Each playbook below sets out the moves that role should make first, why each one matters, and the failure mode specific to that mandate — including the ones where the honest answer is that the role has been handed an impossible brief. Obligations attach per product group under the ESPR.

Five roles

The first ninety days, by mandate

Read your own, then read the one belonging to whoever you will be arguing with. Most internal friction here is two roles optimising for different things, correctly.

The compliance lead’s first ninety days

You own the obligation and almost none of the data. Every attribute a passport needs sits in sourcing, product development or a supplier you have no contract with, and you will be the one asked why it is missing.

Role: Head of Compliance
Most common pitfall: Being made accountable for the programme without authority over the functions holding the data. Fix the ownership map before the timeline, or the timeline is fiction.

1Establish scope per product group, not per product
ESPR attaches obligations to groups. Until the groups are listed, nothing else can be scheduled and every estimate is guesswork.
2Publish a gap register with a named owner per attribute
It converts an aggregate readiness figure into assignable work, and it makes visible that most gaps are not yours to close.
3Get the access policy agreed before the first passport is published
Attribute visibility cannot be retrofitted once a passport is publicly resolvable, and commercial teams will object after launch rather than before.
4Set the correction process, and rehearse it
Suppliers submit figures that turn out to be wrong. A programme with no route to correct a published passport has a compliance problem the moment it succeeds.
5Track delegated acts as they are adopted, with a named owner
The eighteen-month clock starts without anyone telling you, and being late is a market withdrawal rather than a fine.

We will run a scope and gap session against your real product groups, not a generic template. Ask for it.

The sustainability lead’s passport agenda

You already report at entity level under CSRD. The passport pushes the same questions down to product level, where the evidence is thinner and the claims are older, and it makes both visible to anyone with a phone.

Role: Chief Sustainability Officer
Most common pitfall: Treating the passport as a reporting project. It is a product data project whose output happens to satisfy reporting, and running it from the disclosure calendar puts it permanently behind the delegated acts.

1Audit which existing public claims you could actually evidence
Publishing a passport puts your marketing claims next to your data. The gap between them becomes a greenwashing exposure the moment it is machine-readable.
2State the chain-of-custody model behind every recycled content figure
Mass balance and segregated are both legitimate and mean different things. Publishing one as the other is the claim most likely to be challenged.
3Reconcile product-level data to the entity-level ESRS disclosure
Auditors will ask. The reconciliation is the work, and doing it after both numbers are published is considerably harder.
4Report circularity as separate named metrics, not one score
MCI, recycled content and repairability are different scales. A composite "circularity score" is a figure no standard recognises and no auditor accepts.
5Use passport data as the ESRS E5 evidence base
Resource inflows, outflows and durability are already required for the passport. Collecting them twice for two frameworks is the most common avoidable cost here.

We will show you which ESRS E5 datapoints your passport data set already answers. Ask for it.

The supply chain lead’s data problem

Everything the passport needs that you do not already hold is somewhere in your supplier base, usually two or three tiers down, held by someone who has never been asked and has no obligation to you directly.

Role: Supply Chain Director
Most common pitfall: Assuming tier 1 can answer for tier 3. Visibility usually stops at tier 2, and the attributes ESPR asks for are mostly held below that line.

1Map which tier actually holds each missing attribute
Process-stage origin, chemistry and land geolocation live at tier 3. Asking tier 1 for them produces a forwarded guess rather than a measurement.
2Group requests by attribute set and supplier, never by product
One mill supplying eleven styles should receive one request. Eleven identical requests produce one late reply and a damaged relationship.
3Give suppliers an explicit route to say "we do not measure that"
Without one you receive an estimate presented as a measurement, which is worse than a gap because it looks complete.
4Record who asserted each value and when
Provenance is what makes a figure defensible later. A number with no named source cannot be defended to market surveillance.
5Put the attribute requirement into new supplier contracts now
Retrofitting a data obligation into an existing agreement takes a renewal cycle you may not have before the delegated act lands.

We will draft your first collection campaign using your own product group’s attribute set. Ask for it.

The engineering lead’s design decisions

Several passport attributes are design outputs, not data collection tasks. Disassembly time, spare-part availability and recyclability are decided at the drawing board and become expensive to change once tooling exists.

Role: Product Engineering Lead
Most common pitfall: Treating the passport as a downstream publishing task. By the time a product is in tooling, four of its passport attributes are already fixed and two of them are bad.

1Treat disassembly time as a design requirement with a target
It decides whether recycling is economic and it feeds the repairability index directly. Adding it after tooling is a redesign rather than an adjustment.
2Choose the data carrier alongside the housing, not after it
A carrier retrofitted to a finished product is a sticker. One designed in is direct-part marked and survives the disassembly a recycler performs while scanning it.
3Decide the issuance level before serialisation is specified
Item, batch or model determines how many unique identifiers the line applies. Changing it after launch means reissuing every carrier already in the field.
4Design fastenings for separation, and document the sequence
Adhesive and welds make components non-separable in practice, which caps recyclability regardless of what the material declaration says.
5Build the material declaration into the bill of materials
Substance data assembled from a BOM you already maintain is nearly free. Assembled retrospectively from suppliers it is a project.

We will review one product’s design against the attributes its group will require. Ask for it.

The commercial lead’s case for the passport

You are being asked to fund a compliance programme. Three of its outputs have a measurable return, and the one usually pitched hardest — consumer engagement — is the one hardest to bank.

Role: Commercial & Brand Lead
Most common pitfall: Funding it as a marketing initiative. The deadlines are regulatory, so a programme on a campaign calendar misses the delegated act and then has to be redone at speed.

1Model the eco-modulated producer responsibility fee saving first
It is the only line that turns better data directly into a lower invoice, per market, per period, with an auditable basis.
2Use the passport as the resale and repair channel’s data layer
Second-hand and repair both need product history. Owning that history keeps the margin and the customer relationship inside your channel rather than a marketplace.
3Treat scan data as intent, not reach
A scan asking for repair instructions is somebody keeping your product in use. That is worth more than a hundred passive impressions and should be reported differently.
4Audit marketing claims against what the passport will publish
The passport puts your claims next to your evidence. Any claim you cannot support becomes a liability the moment it is machine-readable.
5Sequence by product group, not by catalogue
One group delivered properly is a reference for the next. A catalogue-wide launch delivers nothing until it delivers everything.

We will build the fee and resale model with your own tonnage and product data. Ask for it.

Next step

Work through your own first ninety days

We will run a scope and gap session against your actual product groups, with the people who hold the data in the room rather than a summary sent afterwards.

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Ninety minutes, your products, no slideware.