For decades, “can you trace this field unit back to the plant and supplier lot that built it?” was a question only auditors and recall lawyers asked.
Starting 18 February 2027, EU regulators ask it about every EV battery placed on the market. And your product category is on the schedule.
The Ecodesign for Sustainable Products Regulation (EU 2024/1781) has been in force since July 2024. It introduces the Digital Product Passport: a structured record that travels with the product and answers where it was made, what is in it, and how to repair it. The battery passport comes first, mandatory from 18 February 2027 for every EV battery, LMT battery, and industrial battery above 2 kWh. Textiles, iron and steel, and aluminium follow via delegated acts, expanding toward electronics and machinery before 2030.
Here is what worries me. Most of the DPP conversation is happening in sustainability departments. But a passport is only as truthful as the configuration records behind it.
Look at what modern manufacturing actually is: the same part number built in multiple plants, by different suppliers, with locally sourced materials. If your organization does not record which construction went into which unit, you will not have a traceability problem in 2027. You will have a false declaration problem. And the regulation reaches deeper than a label: passports are issued at model, batch, or item level and identify the facility that made the product. Battery passports are per unit. You cannot issue a truthful per-unit passport from records that do not specify which construction went into which unit. The passport does not create the discipline. It exposes whether you had it.
For CM professionals, this is the strongest budget argument of the decade. The as-built records, closed-loop change control, and controlled identification that CM2 has taught for decades are exactly the data pipeline a DPP legally requires. Organizations with that discipline get compliance nearly for free. Organizations without it will bolt a passport onto data they cannot trust.
So here is my question: is your organization treating the Digital Product Passport as a sustainability reporting exercise or as a configuration management exercise?
I would argue that whoever frames it decides whether it works. Let me know what you think.