This is part of AIAG's series recapping sessions from the 2025 IMDS, Product Compliance & Sustainability Conference. Registration is now open for the 2026 conference October 7–9 in Novi, Michigan.
It’s time to treat sustainability data with the same rigor as manufactured parts. That was the message RSJ Technical Consulting President Michael Wurzman delivered to manufacturers navigating the fast-evolving world of sustainability reporting at AIAG’s 2025 IMDS, Product Compliance & Sustainability Conference.
Leading the session “Sustainability Data Approval Process,” Wurzman proposed SDAP as a solution to the industry’s long-standing data quality issues. He emphasized that it’s especially necessary as new regulations such as the European Union’s Digital Product Passport raise the stakes.
From Acceptable Quality to Zero Defect
Wurzman opened with a historical analogy. Decades ago, manufacturers relied on acceptable quality levels — shipping parts as long as defects stayed within statistical limits. That approach changed when quality pioneers such as W. Edwards Deming helped transform global manufacturing standards. Today, he said, sustainability data is stuck in that earlier era.
“If the customer accepts it, it must be OK” has been the prevailing mindset for IMDS submissions and other regulatory data, he said. But Wurzman estimates that 30–40% of the sustainability data his company handles raises plausibility concerns — materials missing essential substances, inconsistent methodologies, or incomplete supply chain inputs.
With PCF data entering IMDS and sustainability disclosures facing tax, compliance, and competitive implications, “bad data means bad decisions,” he emphasized.
Why the Urgency Now?
Regulatory pressure is intensifying. The Digital Product Passport, beginning with batteries and expected to expand across product categories, will require comparable, auditable sustainability data. Carbon taxes, accelerated depreciation policies, and other financial mechanisms may hinge on that data’s integrity.
At the same time, sustainability metrics are moving upstream into design and procurement decisions. If data is unreliable, companies risk flawed supplier selection, missed carbon targets, and regulatory exposure.
Wurzman also pointed to cost. He estimates that 60–70% of IMDS-related effort is spent correcting, clarifying, or resubmitting poor-quality data. Doing it right the first time, he argued, would dramatically reduce that burden.
Introducing Sustainability Data as a Manufacturing Process
His proposed solution is SDAP — the Sustainability Data Approval Process. Rather than viewing IMDS and PCF reporting as administrative tasks, Wurzman urged attendees to treat sustainability data as a manufactured output. Just as physical parts move through defined workflows, inspections, and approvals, so too should sustainability data.
That means:
- Establishing clear requirements and quality standards.
- Mapping data flows similarly to product flow diagrams.
- Conducting Failure Mode and Effects Analysis on data processes.
- Defining KPIs to measure performance.
- Training employees in consistent methodologies.
- Embedding documentation and corrective action systems.
In his framing, sustainability data is no longer an add-on. It is part of the product itself.
“My product is not just the physical component,” he explained. “It’s the product plus the wealth of sustainability data attached to it.”
Leveraging Existing Quality Frameworks
Wurzman does not advocate starting from scratch. He suggested integrating SDAP into established frameworks such as Advanced Product Quality Planning and Production Part Approval Process.
For example, product flow diagrams already used in PPAP can help identify process chemicals, energy inputs, and emissions relevant to PCF calculations. FMEA methodologies can anticipate data risks. Process audits can replace expensive, impractical audits of every individual PCF submission.
Auditing the process — rather than every data point — builds confidence without overwhelming the industry.
Addressing Supply Chain Realities
A major challenge lies in the supply chain. Small suppliers often lack staff, expertise, or budget for advanced sustainability tools. Wurzman emphasized that OEMs cannot simply mandate compliance without enabling it.
He called for cost-effective, widely accessible data tools — potentially hosted within collaborative digital networks — and standardized industry training programs capable of reaching tens of thousands of users.
Collaboration among OEMs, Tier 1 suppliers, and industry groups will be essential, he said. A fragmented approach risks inconsistent data and competitive disadvantage.
AI Won’t Fix Bad Inputs
While artificial intelligence and generative tools are gaining traction, Wurzman offered a caution: “AI is the greatest way to generate garbage — if you feed it garbage.” Without standardized processes and quality-controlled inputs, automation will only scale errors faster.
A Call to Commit
Ultimately, Wurzman framed SDAP not as a technical tweak but as a cultural shift. Just as statistical process control once reshaped manufacturing, sustainability data now demands comparable discipline.
The path forward requires OEM commitment, standardized training, auditable processes, and a shared decision: that data quality is not optional.
He concluded, “We now manufacture sustainability data — and we need to manufacture it with the same quality as our parts.”
Seeking Volunteers
AIAG is seeking volunteers to help with the development of the SDAP document. If you’re interested, please reach out to AIAG’s Corporate Responsibility team at cr@aiag.org.
SAVE THE DATE FOR THE 2026 IMDS CONFERENCE
These topics and more will be covered at the 2026 IMDS, Product Compliance & Sustainability Conference from October 7–9, 2026, at Vibe Credit Union Showplace (formerly called Suburban Collection Showplace) in Novi, Michigan. Learn about the latest sustainability topics as well as global legislative issues and IMDS topics. Conference registration is officially open, so secure your spot today.
