IMDS Newsletter 58

April 29, 2022 - Issue 1 / 2022 (c) IMDS Steering Committee

In this IMDS Newsletter issue you can read about the following:

1. Interpretation on Substance Thresholds page 1

2. IMDS Release 13.2 online - 27th April 2022 page 1
3. Upcoming Release 14.0 in IMDS page 2
4. Users’ Echo page 3

1. Interpretation on Substance Thresholds

After receiving advice, we are reminded of our responsibilities not to under report the con-
centration of critical substances (e. g. substances of very high concern, ELV substances,
etc.) by rounding down the actual concentration of the substance in a material, so it does not
exceed a regulated threshold. It has been advised that a threshold must not be exceeded by
any amount and rounding down is not appropriate when assessing compliance.
For example, if your material contains 0.43% lead in aluminum, it must be reported at 0.43%
lead in aluminum (indicating it does not meet the current ELV requirements and therefore
would be non-compliant), as opposed to rounding down and reporting the lead content at
0.4%, which would incorrectly indicate compliance to the current ELV requirements. The
same principle, of course, also applies to all kind of restrictions such as under REACH where
thresholds, i.e. 0.1%w/w, are applied and were a rounding down from e.g. 0.14999% to 0.1%
would also trigger non-compliance.
If you have created materials where this is the case, please update your IMDS data (by
creating a new version of the incorrect MDS) as soon as possible and report the updated
information to all your customers.
If you have any questions regarding this, please contact your automobile IMDS manufacturer
contact.

2. IMDS Release 13.2 online – 27th April 2022

The IMDS Release 13.2 was successfully rolled out on April 27, 2022. The following en-
hancements are incorporated:
Allow structure mix
Materials used as coating do not represent a separate article according to REACH. But when
referencing a coating material as a component, IMDS currently shows a warning message
based on Rec001. With this change, the warning message will be hidden for certain material
classifications to allow correct the reporting of coated components. 1
 Add warning message if the Application Code “Other application (Potentially prohib-
ited)” is selected

Some OEM companies do not accept MDSs referencing the Application Code “Other ap-
plication (Potentially prohibited)”. With this change, a warning message will be shown in the
check result in case this Application Code has been used. The warning message will inform
the user about this being a recipient specific requirement and ask them to check with their
customers whether they should resolve the warning or not.

Calculate recycling quota based on material in a material reference

Since Release 13.0 manufacturers of polymeric materials are required to enter recycling
information themselves. With this change it will be possible to automatically calculate the
recyclate quota for polymeric materials consisting of other polymeric materials, based on the
quota defined for the referenced materials and their portion in the parent material.

Change of warning on invalid Application Code

The last update of Application Codes resulted in many warning messages for existing MDSs
due to the deactivation of several Application Codes for PAH substances. To counter this, the
Application Codes have since been flagged as “hidden”. This still hides any warning mes-
sages and prevents users from selecting these Application Codes.

With this change, these Application Codes will be deactivated again, therefore reactivating
the warning messages. However, the warning messages will be hidden in existing MDSs,
where the combination of substance, its portion and the material’s classification would no
longer qualify for any Application Code. In other words, warning messages will only be shown
where resolution is possible by creating a new version and updating the Application Code.

Application Code “Concentration within GADSL Limits” for substance groups

The Application Code “Concentration within GADSL Limits” is available for substances of the
four groups “Lead or its compounds”, “Cadmium or its compounds”, “Mercury or its com-
pounds” and “Chromium(VI)-salts” with a concentration of max. 0.1% or 0.01% within the
homogeneous material. With this change the portion of all substances within the homoge-
neous material belonging to each of these groups will be added together and compared to
this threshold. For example, if two lead compounds with a portion of 0.06% each exist in the
same material, the Application Code “Concentration within GADSL Limits” will no longer be
available, since the sum of both substances is > 0.1%.

3. Upcoming Release 14.0 in IMDS

IMDS release 14.0 is scheduled for Q4 2022/Q1 2023. It will contain the following
enhancements:

Allow structure mix

The change of the same name introduced in Release 13.2 will be reverted again. Instead, it
will be possible to select the purpose of a material or semi component on the same level as
a component (e.g., lubrication). If such a purpose has been selected for all non-component
datasheets or nodes on the same level, the warning message will not be displayed.

Chemicals Strategy for Sustainability (CSS)

After each GADSL/SVHC update, references to newly flagged substances marked as
confidential in released MDSs will automatically be revealed. Companies will be informed
about which MDSs were updated, but manually creating new versions to remove the
“confidential” flag will no longer be necessary.
2
SC90 Checks for Thermoplastics
The SC90 checks for classifications 5.1.a and 5.1.b will be expanded to ensure the correct
classification is selected based on the portion of filler substances within the material. A new
substance group will be introduced for substances which can be used as fillers and other
purposes (e.g., as pigments). When using such substances within filled thermoplastics
(5.1.a), their purpose can be selected. The selected purpose will determine whether they will
be treated as fillers by the new SC90 check or not.
Mandatory address data in requests and MDS rejections
Providing contact information will become mandatory in MDS requests and when rejecting an
MDS.
Check for old MDSs
A warning message will be shown in the check when referencing or sending/proposing very
old datasheets.
Chemical Recycling and Renewable Parts
New options for recyclate content besides the existing post-industrial and post-consumer
mechanical recycling will be introduced.

4. Users’ Echo - e-mails sent to IMDS

We heard about a Questionnaire on SCIP reporting require-

ments. Do you have any information for us concerning this
Questionnaire?
Thanks.

Dear IMDS User,

What you heard is correct. DXC will launch a Questionnaire on behalf of the vehicle manufacturers. To
give you some background information:
From 05 January 2021, Article 9.1 of European Waste Framework Directive (Directive (EU) 2018/851)
set up a new legal “Substances of Concern in Products” (SCIP) requirement consisting in reporting to
European Chemicals Agency (ECHA) any article/complex object containing REACH Candidate List ac-
cording REACH Article 33 requirement. This legal duty is applicable to any European supplier of article/
complex object delivering them to professional customers. In this context, ECHA has been mandated
to develop a dedicated “Substances of Concern in Products” (SCIP) IT infrastructure in order to collect
and to make available the data required to waste operators and consumers. This ECHA IT infrastruc-
ture has been implemented and especially SCIP ECHA DB is now increasingly used by different sectors
to provide the required information.
To facilitate the implementation if the SCIP legal duty within Automotive supply chain (and especially
for SME) and combining it as efficiently as possible with our IMDS data process collection, the IMDS
Steering Committee decided last year to invest money to develop a dedicated SCIP functionality allow-
ing to perform this legal duty directly from IMDS in an easy way.
After some months of this IMDS SCIP implementation (IMDS Release 13.0), the IMDS Steering Com-
mittee noticed that the use of IMDS SCIP is unfortunately far less than expected. It’s the reason why
the IMDS Steering Committee decided to launch this survey to better understand if the IMDS SCIP
interface & function could be really of relevance for a broader part of the IMDS supplier community and
finally to conclude on appropriate further steps.
Due the geographical scope of this SCIP legal duty, this survey is intended only for suppliers commer-
cializing articles and complex objects in Europe.
The IMDS Steering Committee definitely needs your answer even if you are not delivering products
subject to this legal duty so far (no REACH Candidate List substances contained in your product ac-
cording REACH article 33).
Best regards,
Your IMDS Newsletter Team

3
 4. Who to contact at the automobile manufacturers?

Anadolu ISUZU Mitsubishi Mitsubishi IMDS

Otomotiv E. Sener Coordinator
Aston Martin Lagonda D. Walker Nissan Y. Bito
BMW B. Stein-Schaller Porsche M. Weck
DAF Trucks DAF IMDS PSA Group PSA IMDS
Coordinator Coordinator
Daihatsu Daihatsu IMDS PT Astra Honda Motor H. Diansyah
Coordinator Renault Renault IMDS
Daimler V. Ackermann Coordinator
Dongfeng Honda Shao Linlin Renault Samsung Renault Samsung
e.GO e.GO Homologations IMDS Coordinator
Faraday Future G. Lewis Royal Enfield Regulatory Compliance
FAW-VW Xin Bao Coordinator
FCA US LLC Chris Sidney SAIC Yusong He
Fiat C. Berruti SAIC GM Guanghong Xia
Ford S. Riewer SAIC Volkswagen Shen Jian
GAC Honda H. Yinbin Scania Frank Schlüter
General Motors Kirankumar Jagatap Ssangyong Chae-Eun Lee
GM India Kirankumar Jagatap Motor Company
GM Korea Hyunkyung Kim StreetScooter Philipp Franz
Hino HN-Gikan Peis SUBARU Corp. SUBARU IMDS
Honda Honda IMDS Coord. Coordinator
Honda-Sundiro Akira Iwatake Suzuki Suzuki IMDS Coord.
Hyundai T. Unger Tata Motors D. Chandran
INEOS INEOS IMDS Coord. Tesla Motors S. Nagaraj
Isuzu Isuzu IMDS Coord. Toyota I. Schoukens
Jaguar Land Rover M. Griffin UD Trucks K. Kuwahara
JSV AVTOVAZ O. Demicheva Vinfast LLC Vinfast IMDS
Karma K. Shah Volkswagen VW IMDS
KTM M. Mehler Coordinator
Kubota Kubota Corp. Quality Volvo Car Corporation IMDS Coordinator
Ass. Promotion Dpt. Volvo Group P. Barve
LEVC - London EV Wuyang- Wuyang-Honda
Company IMDS System Engineer Honda Motors IMDS Coordinator
Maruti Suzuki India Ltd. MSIL IMDS Team
Mazda Mazda IMDS Support

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