The fashion industry may have spent the last two years profusely preparing for digital product passports—attending summits, studying regulatory frameworks, debating implementation timelines. But what if the sector-spanning search for DPP solutions was in vain?
According to a joint paper by digital sourcing platform World Collective and green tech company Kinset, it was—searching for solutions to solve the wrong problem.
That’s because the European Union’s DPP transition—one moving from policy discussion to operational reality—presents a critical implementation gap, per the paper, which said current regulatory frameworks often designate brands as the “responsible economic operators.” Yet the primary data required for compliance—fiber origin, material composition, chemical inputs—are generated and held upstream by suppliers and processors.
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The joint analysis contends that a brand-led accountability setup simply can’t scale in practice, arguing that the industry needs a distributed model backed by infrastructure spanning the full value chain. It pointed to UNIDO readiness assessments showing just 29 percent of firms can currently supply fiber-level data—and that in some regions, basic spreadsheet tracking still performs best, reaching 93 percent.
As compliance conversations continue, the “From Research to Reality” positioning paper is in direct response to the latest research—just one that adds the “missing, operational” layer. The paper, fully named “Making DPP Accountability Scale Across the Value Chain,” chiefly argues that, without shared systems and data standards, DPPs will end up being paperwork recreated later, not accurate, live records of reality.
“Digital product passports won’t succeed as a brand-side reporting project,” said Jeanine Ballone, founder and CEO of World Collective. “The data that makes a passport credible is created upstream; unless we build workflows and accountability where that data lives, we’ll end up with passports assembled after the fact—not passports that reflect what actually happened.”
Given that the proof and product-level data live upstream—with mills, processors and manufacturers—brands can’t “report their way” into compliance at scale. Without standardized data exchange and upstream infrastructure, DPP compliance risks becoming what the partners called a reconstruction theater: A post-hoc assembly of fragmented, unverifiable claims rather than a credible record of production reality.
“Everyone talks about DPP readiness like it’s a policy decision; it’s actually a data architecture problem that most suppliers can’t solve alone,” Ballone penned in a blog post World Collective published earlier this month. Kinset concurred; Katelyn O’Riordan, co-founder and CEO of the Dublin-based SaaS platform, said that DPPs are ultimately a systems problem, not just a reporting one.
In their paper, the partners outline a workable shared-accountability approach, distinguishing between data created versus controlled and outlining the systems needed to exchange verifiable information across tiers. They said the concept is being validated through live pilots that test its performance in real production environments—at present being implemented through supplier-driven DPP data capture and structured compilation workflows aimed at scaling.
“If data can’t move cleanly between suppliers, brands and regulators, compliance will break down under its own complexity,” O’Riordan said. “Interoperability and automation are what make distributed accountability workable and DPPs scalable in practice.”
The paper examining “the implementation gap that no one is talking about” was spearheaded by Ballone, who previously spent a baker’s dozen years with VF Corp.
After serving as the vice president of Innovation Next at PVH Corp. for three-and-a-half years, she left in 2019 to serve as managing director of Fashion 4 Development—a New York City champaigner (a portmanteau of “champions” and “campaigns,” if you will) for sustainability among apparel companies and brands. In 2023, Ballone founded World Collective as a globally connected digital ecosystem designed for sustainable, transparent sourcing.
“The bottleneck isn’t supplier willingness to comply, it’s the fundamental data infrastructure required to make compliance possible,” Ballone said. “Here’s what no one wants to admit: When we ask suppliers for DPP-ready data, we’re asking them to produce information their systems were never designed to capture.”
