Digital Product Passports for Sustainability Leads

Sustainability functions have spent a decade building corporate-level reporting from estimates, because product-level evidence was not obtainable at reasonable cost. The passport changes the economics of that, and the change is larger than the compliance obligation that forced it.

The practical opportunity is consolidation. Four obligations currently drive four separate supplier data exercises, and they ask overlapping questions of the same parties in different formats at different times of year.

What the passport actually gives a sustainability function

Every row draws on the same underlying evidence. The reason it does not feel that way today is that each obligation arrived separately, was assigned to a different owner, and produced its own spreadsheet and its own supplier mailing.

How it changes Scope 3

Most Scope 3 category 1 reporting is spend-based: expenditure multiplied by an emissions factor. It is defensible as a starting point and nearly useless for decisions, because it moves when procurement prices move and does not move when a supplier decarbonises.

Product-level footprints collected as passport evidence replace that with supplier-specific primary data. The number becomes responsive to the thing you are trying to change, which is the precondition for a reduction target that means anything.

How it changes green claims

Directive (EU) 2024/825 and the proposed Green Claims regime shift environmental claims from marketing assertions to statements requiring substantiation. A recycled content claim on a label now needs evidence behind it that a regulator can examine.

The passport is the natural home for that evidence, because it holds the claim next to the signed supplier credential that supports it. The alternative — a claim in a brand system and its evidence in a compliance folder — is exactly the arrangement that fails an inspection.

The uncomfortable consequence is that some existing claims will not survive contact with their evidence. That is better discovered internally than by a market surveillance authority, and the passport programme is usually where it happens.

Where sustainability and compliance functions collide

The passport obligation usually lands on compliance because it is a regulation. The data it needs is largely what sustainability already collects. Neither function typically owns the supplier relationship, which sits with procurement.

• Compliance is measured on whether the passport exists by the deadline.
• Sustainability is measured on whether the reported figures are credible and improving.
• Procurement is measured on cost and continuity, and pays the relationship cost of every request.
• Nobody is measured on whether the three collect the same evidence once.

That last line is the whole problem. The consolidation opportunity is real and nobody’s objective, which is why it requires an explicit decision rather than emerging naturally from three well-run workstreams.

What to do with the supplier mailing calendar

The most immediately valuable action available to a sustainability lead is not technical. It is to find every supplier data request the company sends in a year, list what each asks for, and identify the overlap.

In most manufacturers this exercise finds three to five separate requests reaching the same suppliers, asking for composition, footprint and certification data in incompatible formats. Suppliers answer the first properly, the second partially, and the third not at all — which is usually read as supplier unwillingness rather than as a self-inflicted problem.

What to ask for that you probably are not

Sustainability requests typically ask for values. Passport-grade evidence asks for values with an asserting party and a date, which is a different thing and only marginally harder to obtain if requested from the start.

Asking for it later means going back to every supplier a second time, which is where the goodwill runs out. If a data request is being redesigned anyway, this is the change worth making — the mechanism is described in verifiable credentials explained.

What this does not solve

It does not make deep-tier data appear. Tier-1 suppliers can usually answer for their own operations and frequently cannot answer for theirs, and the passport does not change that beyond making the gap explicit rather than hidden inside an average.

It also does not settle methodology disputes. Two suppliers can compute a product carbon footprint honestly and differently, and a passport that records both figures with their methods is more truthful than one that averages them into a single clean number. Truthful and clean are genuinely in tension here.

How to talk about it internally

The passport arrives as a regulatory obligation, which means it is usually presented internally as a cost. That framing makes it hard to secure the procurement sponsorship the programme actually needs, because nobody volunteers relationship capital for someone else’s compliance deadline.

The more accurate framing is that the company is already paying for this data several times over, in separate requests with separate formats and diminishing supplier response rates. The passport is a consolidation of spend that happens to also satisfy a regulation.

That argument is checkable, which is why the request inventory matters. Three named requests reaching the same forty suppliers is a fact a procurement director will act on; an assertion that consolidation would be beneficial is not.

A reasonable first ninety days

1. Inventory every supplier data request the company currently sends, and what each asks for.
2. Map ESRS E5 and E1 datapoints against the passport field list for one product group.
3. Identify which environmental claims currently lack evidence that would satisfy substantiation.
4. Agree with compliance and procurement who owns the single supplier request.
5. Pick one product group and collect once, properly, rather than everything partially.

The last point is the one that gets argued. Breadth is politically easier and produces a dataset too thin to report from; depth on one group produces evidence you can actually publish, and a template for the rest. Depth wins, and it is worth spending capital to defend that choice.