FAQ – Frequently asked questions about IMDS, training, and compliance

FAQ – Frequently asked questions about IMDS, training, and compliance

You will quickly find answers to questions about IMDS, CDX, CAMDS and our training courses in our FAQs. They also cover many questions relating to product compliance.

IMDS

SCIP

IMDS stands for International Material Data System and is used by the automotive industry to document all materials used in a vehicle. It ensures compliance with substance bans or restrictions and is designed to simplify recycling. You can find more information here.

The IMDS is available free of charge exclusively for the automotive supply chain. The CAMDS is a similar system used in China. The CDX can be used across industries and covers more regulations.

OEMs must maintain all relevant material data for their products in the IMDS in a complete, consistent, and legally compliant manner. This includes information on the materials and substances used, including their percentage composition, as well as a complete structural representation from the component down to the material level. Weight specifications, classifications, and labeling in accordance with applicable legal requirements—such as REACH or the End-of-Life Vehicles Directive—are also required. If recycled materials are used, their origin and proportions must be documented in a traceable manner.

When it comes to recycled materials, it is important to note that their composition, quality, and traceability depend heavily on the type of source material and the recycling process used. A distinction must be made between post-consumer and post-industrial recycled materials, as these can contain different impurities and vary in quality.

The Product Carbon Footprint (PCF) is integrated into the IMDS and can be entered directly within an MDB. CO₂ emissions can be reported for materials, semi-finished products, and parts. Data entry is based on the methodology specified in ISO 14067 and follows the guidelines of the Catena-X PCF Rulebook.

Basic use of IMDS is free of charge for suppliers and subcontractors, provided they are part of the supply chain of a participating IMDS OEM. IMDS is funded by the participating OEMs and made available to their supply chains. Therefore, companies may generally only register if they belong to such a supply chain.

However, if a company wishes to use IMDS itself as an OEM at the end of the supply chain to fulfill its own obligations, a separate agreement with DXC is required. Additional services and features may also be subject to a fee.

First, you should check whether the company is already registered in IMDS. If the company is already registered, new user accounts are created by the designated IMDS company administrator.

If the company is not yet registered, company registration is completed online via IMDS. During this process, a company administrator and an IMDS contact person must be designated. The company administrator then manages the company’s other users.

We’d be happy to assist you with this. Simply schedule a free solution check.

External IMDS consulting can be helpful if your company lacks internal experience or capacity, if you need to create complex material data records, or if you regularly receive rejections from customers.

We’d be happy to assist you. Simply schedule a free solution check.

Yes, IMDS can be used to create and submit SCIP dossiers to ECHA.

However, this requires that the MDB structure accurately reflects the actual product or component structure. Only then can SVHC substances be correctly assigned to the respective product and the required SCIP information be derived.

In addition, the necessary SCIP data must be maintained in the IMDS, and the technical requirements for submission to ECHA must be in place.

An MDS may comply with the general IMDS rules and still be rejected by an OEM. Many vehicle manufacturers also have their own customer-specific requirements and validation rules for accepting material data sheets.

The GADSL (Global Automotive Declarable Substance List) is the central list of substances subject to declaration and prohibited substances in the automotive industry and is integrated into the IMDS. Pure substances are labeled accordingly as D (declarable), D/P, or P (prohibited) and can be filtered or analyzed specifically.

Yes. SVHC substances are labeled accordingly in the IMDS and can be identified in the substance view by, among other things, underlining and the “SVHC” label.

This requires that the substance in question has actually been declared in the material data record. Hidden or incompletely declared substances cannot be automatically detected.

CAMDS

CAMDS (China Automotive Material Data System) is a Chinese material data system for the automotive industry, comparable in function to IMDS. CAMDS is used to collect and share material and substance data throughout the automotive supply chain.

The system is used in particular to assess prohibited and restricted substances as well as the recyclability and reusability of vehicles, thereby supporting compliance with Chinese regulatory requirements. CAMDS is operated by the CAMDS Management Center in collaboration with the China Automotive Technology and Research Center (CATARC). More information is available here.

The CAMDS is particularly relevant for vehicle manufacturers that register or place vehicles on the market in China. The material data recorded in the CAMDS supports compliance with Chinese requirements regarding prohibited or restricted substances, as well as the reusability and recyclability of vehicles. The Chinese MIIT publishes compliance lists for M1 vehicles in this regard.

Suppliers outside of China are also affected if their customers require CAMDS data sets to compile the material data for the complete vehicle and to maintain the corresponding regulatory documentation.

IMDS and CAMDS are material data systems for the automotive industry and basically work in a similar way. Both systems track material and substance data throughout the supply chain.

The main difference lies in their market and regulatory focus: IMDS is used internationally by numerous vehicle manufacturers, while CAMDS is specifically tailored to the Chinese automotive market and its requirements regarding prohibited or restricted substances, as well as recycling and recovery.

Not necessarily. Whether data must be submitted to IMDS, CAMDS, or both systems depends on the customer and the target market.

For example, if a part is supplied to both international vehicle manufacturers and for vehicles in the Chinese market, submissions to both systems may be required. A submission to IMDS does not automatically replace a submission to CAMDS.

Yes. European suppliers may also be subject to CAMDS or affected by CAMDS requirements if their parts, materials, or components are used in vehicles intended for the Chinese market.

In this case, Chinese vehicle manufacturers or their supply chain partners may require that the relevant material and substance data be submitted to CAMDS. Therefore, the decisive factor is not the company’s place of business, but rather the customer and target market for which the products are supplied.

RoHS

RoHS restricts certain hazardous substances in electrical and electronic equipment and sets specific limit values for them.

REACH is significantly more comprehensive and regulates chemicals in nearly all industries and product types, for example through SVHC, restriction, and information requirements.

Both sets of regulations apply simultaneously to many products.

RoHS applies to companies that manufacture, import, or distribute electrical and electronic equipment and place it on the market in the EU. This includes both consumer products and professional and industrial equipment.

Suppliers are also often indirectly affected if their components or materials are used in products subject to RoHS and customers require corresponding documentation.

No. RoHS does not generally require laboratory testing of every product. Compliance can also be demonstrated through appropriate technical documentation, such as supplier declarations, material data, certificates, or existing test reports.

Analytical testing is particularly useful when supplier data is missing, insufficiently reliable, or when there is an increased risk. EN IEC 63000:2018 provides an established framework for RoHS documentation in such cases.

No. In addition to manufacturers, RoHS also applies to importers and distributors of electrical and electronic equipment.

Suppliers of components and materials are also often indirectly affected, as their customers require RoHS-compliant components and the corresponding documentation to ensure the end product’s compliance.

No. RoHS is a legal requirement to restrict certain hazardous substances in electrical and electronic equipment. The CE marking, on the other hand, indicates that a product complies with the applicable EU regulations.

For many electrical and electronic devices, RoHS is one of the requirements that must be taken into account as part of CE conformity. RoHS and CE are therefore closely related, but they are not the same thing.

Currently, the RoHS exemptions under Directive 2011/65/EU, as listed in Annexes III and IV, apply. These annexes describe applications in which the use of restricted substances—such as lead, mercury, or cadmium—is temporarily permitted because suitable alternatives are not yet available. The exemptions are time-limited and are regularly reviewed by the European Commission and, if necessary, extended or revoked. Companies must therefore continuously verify whether the exemptions they are using remain valid. The European Commission publishes the most current overview on its website under “RoHS Directive – Implementation.”

PPWR

The PPWR (EU Regulation 2025/40) regulates packaging and packaging waste in the EU. It applies to companies that manufacture, import, or distribute packaging or packaged products in the EU.

Further information is available here.

Depending on the type of packaging, companies must document and verify requirements related to, among other things, recycled content, recyclability, material restrictions, and labeling.

In the future, companies will be required to document the PPWR compliance of their packaging. This includes, in particular, technical documentation and an EU declaration of conformity.

Depending on the type of packaging, companies must demonstrate compliance with requirements regarding materials, recyclability, the percentage of recycled content, and packaging minimization, among other things.

For many types of plastic packaging, mandatory minimum recycled content requirements are being phased in. At the same time, the requirements for the recyclability of packaging are becoming more stringent.

Companies should first take stock of their packaging and responsibilities and obtain the necessary data on materials, substances, and recycled content from suppliers.

Next, the packaging must be assessed for requirements such as recyclability, recycled content, substance restrictions, and packaging minimization, and the necessary technical documentation must be compiled.

We’d be happy to assist you with this—just get in touch with us.

imds professional trainings

imds professional offers training courses for beginners and advanced users on material databases and tools such as IMDS, CDX, CAMDS, and iPCA, as well as material compliance and due diligence requirements, including POP, REACH, PPWR, and conflict minerals. These training courses are also available as certified programs, such as the two-level IMDS course or the three-level Material Compliance course.

You can find all training topics here.

The right training depends on your prior knowledge, your role within the company, and your day-to-day responsibilities related to IMDS and product compliance.
Our IMDS skills pyramid outlines the path from beginner to IMDS expert to IMDS officer.

Yes, training courses are offered both online and as in-house or in-person sessions.

Upon successful completion, participants will receive a certificate of participation or a certificate.

The training courses are practice-oriented, take current regulatory requirements into account, and provide knowledge that can be directly applied in day-to-day work.
We have been supporting the IMDS since its introduction, having trained the first OEMs and numerous other users since then. Our experience from numerous customer projects is also incorporated into the training courses.

A SCIP reporting obligation may apply if you place products on the EU market that contain a substance on the Candidate List of SVHCs in concentrations exceeding 0.1 percent by weight. This applies in particular to EU manufacturers and assemblers, importers, as well as distributors and other actors in the supply chain.

The key factors are therefore the company’s role, the product’s composition, the SVHC content, and whether the product is marketed in the EU. Distributors who sell products exclusively directly to consumers are exempt from the SCIP reporting requirement.

There is no separate filing fee for submitting a SCIP notification to ECHA. ECHA provides the Submission Portal, IUCLID, and a system-to-system interface for this purpose.

Products placed on the EU market that contain, in at least one component, a substance on the Candidate List of SVHCs in a concentration exceeding 0.1 percent by weight must be reported in SCIP.

Important: The threshold applies to the individual article and not to the weight of the entire product. This means, for example, that even components within an assembly or a vehicle can trigger a SCIP reporting requirement.

If there is a SCIP reporting requirement and the report is not submitted, or is submitted incorrectly, incompletely, or late, this constitutes an administrative offense under the Chemicals Act in Germany. This offense is punishable by a fine of up to 10,000 euros.

In addition, this may result in additional claims from regulatory authorities, customer complaints, and compliance risks. However, the absence of an SCIP notification does not automatically mean that the product in question is prohibited.

CDX

Note: There are two systems with this abbreviation!

CDX stands for Compliance Data eXchange and is a platform for the structured exchange and management of material, substance, and compliance data throughout the supply chain. Like IMDS, CDX is provided by DXC Technology and shares some similarities with it in terms of structure and functionality. While IMDS is specifically geared toward the automotive industry, CDX can be used across all industries. Companies can use it to centrally capture information about their products, exchange it with suppliers and customers, and use it to meet various regulatory requirements. You can find more information here.

The U.S. Environmental Protection Agency (EPA) also operates the Central Data Exchange portal, through which TSCA notifications can be submitted.

Companies need reliable information about the materials and substances in their products in order to assess regulatory requirements and their own customer specifications. Through CDX, they can request this information from their suppliers in a standardized format and then use it for their compliance assessments.

IMDS and CDX are both operated by DXC Technology and share some similarities in their structure and operation. While IMDS is specifically designed for the automotive industry and the exchange of material data, CDX is designed for use across industries and covers a broader range of product compliance topics.

The CDX enables the exchange of various material, substance, product, and compliance data throughout the supply chain. This includes, for example, complete or partial material declarations, information on contained substances and materials, as well as data for assessing regulatory requirements such as REACH, RoHS, SCIP, PFAS, POPs, or TSCA.

In addition, supplier declarations, safety data sheets, certificates, questionnaires, and other compliance documents can be stored and exchanged. Data on responsible sourcing—such as information on 3TG, cobalt, mica, lithium, nickel, or natural graphite—can also be recorded and shared via the CDX.

Depending on the use case, the data can also be exchanged with or reused by other systems via standardized formats and interfaces.

Yes, CDX is also suitable for medium-sized companies, especially when they need to regularly respond to compliance inquiries from customers or collect data from their own suppliers.

Instead of managing information via email, Excel spreadsheets, and individual documents, material, substance, and compliance data can be centrally recorded and reused in CDX. Companies can start small as needed and later expand their use to include additional products, suppliers, or compliance topics.

Especially as the number of requirements—such as REACH, RoHS, PFAS, or responsible sourcing—increases, CDX can help standardize processes and reduce the effort required for data collection and tracking.

A key advantage of the CDX is the structured organization of Full Material Declarations (FMDs) throughout the supply chain. Instead of compiling material and substance information via individual Excel files, emails, or various questionnaires, suppliers can provide their data directly in a standardized format.

This allows information from different stages of the supply chain to be consolidated into a complete product composition. At the same time, predefined validation rules and data structures help identify incomplete, contradictory, or incorrect information at an early stage.

This results in higher and more traceable data quality. Existing and approved data can also be reused, reducing duplicate work and improving the foundation for future compliance assessments.

REACH

REACH applies to companies in virtually all industries that manufacture, import, use, or place substances, mixtures, or articles on the market. This includes, in particular, manufacturers, importers, downstream users, and suppliers.

The specific obligations that apply depend on the company’s role, the product, and the substances it contains.

ECHA’s Candidate List of SVHCs contains substances of very high concern. These substances are candidates for possible inclusion in the REACH Authorization List (Annex XIV).

The Candidate List of SVHCs is published and regularly updated by the European Chemicals Agency (ECHA).

New substances are identified as substances of very high concern under the REACH procedure and subsequently added to the Candidate List.

As a general rule, this information should be passed along through the supply chain. If a product contains a substance on the Candidate List of SVHCs in a concentration exceeding 0.1 percent by weight, the supplier must actively inform its professional customer in accordance with Article 33 of REACH—at a minimum, providing the name of the substance in question.

Companies should collect this information from the supply chain and evaluate it for their own products. If information is missing or unclear, targeted inquiries to suppliers or additional material analyses may be necessary.

No. First, a distinction must be made between SVHC substances and the SVHC Candidate List. SVHCs are substances that meet the criteria for substances of very high concern under REACH. The Candidate List contains those SVHCs that have been officially identified and included as such under the REACH procedure.

Inclusion on the SVHC Candidate List does not in itself constitute a ban, but it may trigger information and reporting requirements. Further requirements may arise, for example, from an authorization requirement under Annex XIV or a restriction under Annex XVII.

Yes. Under REACH, packaging is generally considered a separate article and must be assessed independently of the product it contains. For example, ECHA explicitly lists plastic packaging as an article.

IMDS supports REACH compliance by flagging and filtering SVHC substances and by providing analysis functions for REACH-relevant substances.

For substances listed in REACH Annex XIV, regulatory information can be edited using the Regulatory Wizard in the IMDS Chemistry Manager. For relevant substances listed in REACH Annex XVII, application codes—among other tools—help assess the specific use of a substance in a component.

No. Depending on their activities, REACH applies to manufacturers, importers, distributors, and downstream users. Companies that manufacture, import, or distribute articles may also have REACH obligations.

The specific requirements that apply depend on the company’s role as well as the substances, mixtures, and articles it uses.

Conflict Minerals

Conflict minerals specifically refer to tin, tantalum, tungsten, and gold—often grouped together as 3TG (Tin, Tantalum, Tungsten, Gold). These raw materials may originate from conflict-affected or high-risk areas where their mining or trade can contribute to the financing of armed groups or to human rights violations. For more information, click here.

CMRT and EMRT are standardized templates developed by the Responsible Minerals Initiative (RMI) to gather information about the origin of raw materials and the smelters, refiners, and processors used in the supply chain. The main difference lies in the raw materials covered.

The CMRT (Conflict Minerals Reporting Template) focuses on the traditional conflict minerals—tin, tantalum, tungsten, and gold (3TG). The EMRT (Extended Minerals Reporting Template) expands the scope to include additional raw materials. It currently covers cobalt, copper, natural graphite, lithium, natural mica, and nickel.

The necessary information comes primarily from the company’s own supply chain. Companies use standardized templates such as CMRT or EMRT to ask their suppliers about the raw materials they use, as well as about known smelters, refineries, and other processors.

One challenge is that CMRT or EMRT alone are not always sufficient. Depending on the supply chain, additional documentation regarding origin, smelters and refineries, or audit status may need to be obtained.

A current example is China: The RMI is not conducting any new RMAP assessments there at this time. As a result, additional supplier documentation may be required to adequately assess due diligence obligations and risks in the supply chain.

Compliance may be required by legal regulations or customer requirements. The EU Conflict Minerals Regulation (EU) 2017/821 requires certain EU importers of tin, tantalum, tungsten, and gold (3TG) to exercise due diligence in their supply chains.

In the U.S., Section 1502 of the Dodd-Frank Act requires certain publicly traded companies to disclose and verify the presence of conflict minerals in their products.

In addition, companies may be indirectly affected by customer requirements.

Material Compliance Training Course

A Material Compliance course systematically imparts knowledge about legal requirements for substances and products, as well as their practical implementation within a company.

At imds professional, the course is structured in stages: “Material Compliance Professional” covers the fundamentals, “Material Compliance Officer” delves into operational implementation, and “Material Compliance Manager” focuses on strategic management, processes, and accountability. The levels build upon one another in terms of technical content and can be completed with a TÜV Rheinland-certified qualification (PersCert TÜV).

The course is specifically designed for employees in product development, purchasing, quality management, sustainability, regulatory affairs, and product compliance.

A basic understanding of products, materials, or regulatory requirements is helpful, but our three-level course is also suitable for beginners. You can find more information here.

A continuing education program provides the necessary expertise to reliably assess and implement legal and customer-specific material compliance requirements.

It helps identify risks early on, better manage processes and supplier data, and improve collaboration with customers and internal departments. At the same time, a recognized certification strengthens professional competence in the field of material compliance.

Our course covers topics such as REACH, RoHS, SCIP, PFAS, POPs, supplier management, material declarations, compliance processes, and current regulatory developments.

Consulting & Service

imds professional supports companies throughout the entire IMDS process. This includes, among other things, registration and administration, the collection and verification of supplier data, the creation and correction of IMDS data sheets, the analysis of reasons for rejection, the consideration of customer-specific requirements, and communication throughout the supply chain.

In addition, we assist with data quality assessment, regulatory issues, and the optimization and standardization of internal IMDS processes. Depending on your needs, we can handle individual tasks, complete work packages, or provide long-term support to your team as external IMDS experts.

Yes. We review existing IMDS data sets for completeness, plausibility, and compliance with OEM-specific and regulatory requirements. In doing so, we identify potential sources of error, assess data quality, and review the substance and material information contained therein—including with regard to GADSL, REACH, SVHC, and other relevant substance restrictions.

You will receive specific recommendations for optimization. Upon request, we can also handle the correction and resubmission of the data records. If a laboratory analysis is required to verify the material composition, we will put you in touch with our partner, the VDE Institute, as needed.

Yes. We provide support in assessing regulatory requirements, analyzing substance data, and addressing REACH, PFAS, and SCIP requirements. This includes, among other things, SVHC assessments, supplier inquiries, SCIP notifications, and the preparation of information for customers and regulatory agencies.

We assist companies in analyzing the new PPWR requirements and their impact on products and packaging. This includes identifying the necessary data, evaluating packaging, developing appropriate processes, and preparing for future verification and documentation requirements.

We provide support with supplier inquiries, the analysis of CMRT and EMRT data, and the implementation of efficient due diligence processes. In addition, we assist with customer inquiries, risk assessments, and the documentation of due diligence obligations throughout the supply chain.

External support is particularly useful when new legal requirements must be implemented, internal resources are lacking, or specialized expertise is needed. Many companies also turn to external experts to provide temporary relief during projects, audits, or periods of increased demand.

A compliance service reduces internal workload, provides additional assurance regarding regulatory requirements, and ensures that current developments are addressed in a timely manner. Companies benefit from specialized expertise, clear processes, and faster handling of inquiries from customers, suppliers, and regulatory agencies.

Even in cases of vacation cover, illness, staffing shortages, peak order volumes, or a lack of in-house expertise, an external compliance service can provide targeted support and ensure continuous processing.