SME
DPP Project Roles and Responsibilities
Whose job is the DPP? Defining ownership, data entry, approval, publication and maintenance roles with a RACI, plus typical organisational models.
Most DPP projects stall not because of technical difficulty but because of unclear ownership. Quality, product development, sustainability or IT? If the answer is not written down, the work belongs to nobody.
A typical RACI
| Activity | Responsible | Accountable | Consulted | Informed |
|---|---|---|---|---|
| Scoping | Project owner | Management | Sales, quality | Whole team |
| Data inventory | Product development | Project owner | IT | — |
| Supplier data requests | Procurement | Project owner | Quality | Suppliers |
| Data entry | Product/quality | — | — | — |
| Data approval | Quality | Project owner | — | — |
| Publication and signing | Project owner | — | Legal | Sales |
| Registry submission | IT / platform | Project owner | — | Logistics |
| Maintenance and updates | Quality | Project owner | Procurement | — |
Who should own it?
Three models appear in practice:
- Quality ownership: close to the conformity file and audits. The most common and usually the healthiest.
- Sustainability ownership: integrates easily with CSRD and CBAM but may have weak access to product data.
- Product development ownership: closest to the data source but weaker on regulatory tracking.
Whichever you choose, the owner must have access to both product data and the supplier relationship.
In a small team
In a ten-person company a RACI table can be overkill. The minimum rule is: the person entering data and the person approving it must be different. That single separation measurably reduces errors. See DPP data quality management.
Moving into maintenance
When the pilot ends the project team disperses and passports stop being updated — the most common failure pattern. To avoid it:
- Tie update triggers to processes (certificate renewal, formulation change). See passport lifecycle management.
- Assign maintenance to a role, not a person.
- Put an annual review in the calendar.
Frequently asked questions
Can a consultant own it?
No. A consultant accelerates; legal responsibility and sustainable maintenance stay with the company.
Why not IT ownership?
The DPP is a data and compliance project, not a software project. IT is a critical stakeholder but should not own the content.
What should I ask management for?
One decision: who owns it, and how much of their time. See a 90-day DPP pilot.
