An in-depth analysis of how Market Surveillance Authorities (MSAs) will conduct digital audits and why static documentation is a liability.
The enforcement of the EU Battery Regulation (2023/1542) introduces a new era of regulatory oversight: the real-time digital audit. Unlike traditional compliance frameworks where documentation was requested weeks in advance, the Digital Product Passport (DPP) allows Market Surveillance Authorities (MSAs) to verify a product’s status instantly at the point of entry or sale.
**The Risk of Static Data Silos**
Many manufacturers still rely on decentralized PDF repositories or static web-entries. In a professional industrial context, this is a significant liability. Under Article 77, the data associated with a DPP must be "accurate, complete, and up-to-date." If an MSA scans a data carrier and finds a discrepancy, such as an outdated carbon footprint value or an unverified recycler instruction, it can trigger an immediate "Notice of Non-Compliance," potentially leading to a market withdrawal across all EU member states.
**The Solution: Unified Registry Infrastructure**
To ensure audit-readiness, manufacturers must move towards a unified registry that acts as a "Single Source of Truth." This infrastructure must support:
1. **Dynamic Data Updates:** The ability to push updates to the DPP without changing the physical QR code or carrier.
2. **Uptime Guarantee:** Regulators expect 24/7 access to mandatory data sets.
3. **Verification Trails:** Logging who accessed the data and when, providing a defensive audit trail for the manufacturer.
Preparation for 2027 should not focus on "having a website," but on building a resilient data pipeline that can withstand the scrutiny of European regulators.