From Composition to Evidence: Lifecycle Governance for Automotive Sustainability Compliance

Automotive material compliance systems were built to record which substances a part contains, yet European regulation now asks about recycled content, carbon footprint, recyclability, and origin, attributes whose meaning depends on method, boundary, source, validity period, and assurance status. Through a structured documentary analysis of regulations, industry specifications, official statistics, and peer-reviewed studies, the paper examines three published cases in which an accurately recorded attribute diverged from what it was taken to represent: end-of-life vehicle indicators moving in opposite directions against their targets, a component meeting a 20% recycled-content requirement yet assessed as non-recyclable, and a cobalt supply map that grew from 28 to at least 79 actors under audit. It then derives six requirements for a lifecycle evidence record, proposes a federated architecture, and rates existing infrastructure against explicit criteria. Its main contribution is decision-point placement, a governance requirement that would give sustainability attributes standing at the engineering release gate.