REC019 has now been deactivated in IMDS Release 13.0. Until this point ZVEI data sheets could easily be used to report printed circuit boards (PCBs) as a generic mixed material. We have already highlighted this issue in some of our other posts and are going to take a closer look at the impact of the deactivation here.

In order to comply with REACH and especially following the ruling on case o5a (Once an article – Always an article), it is critical that individual PCB parts are reported in the IMDS. This is because each article constitutes a separate product. The previous REC019 structure did not allow separate parts to be mapped, which means problems would also occur with the interface to the SCIP database. REC001 stipulates that a full declaration is now required.

What does this mean for existing and new MDSs?

New MDSs can no longer simply reference the deactivated REC019 data sheets. New copies or versions of an MDS that contain a REC019 data sheet will now trigger an error message in the IMDS and cannot be sent.

What happens to material classifications 8.*?

Material classifications 8.1 and 8.2 have been deactivated as part of IMDS Release 13.0. This means that a deactivated material classification can no longer be selected when a new MDS is created. An error message is generated when a material MDS with invalid material classifications is accessed in edit mode.

This is because material classifications 8.1 and 8.2 are used for special materials used in the electrical and electronic industry. One such example is a mixture of epoxy resin and silver which is used as a conductive adhesive. This classification only describes how the mixture works and not what it contains, but it is important to ensure that each mixture’s constituents are declared in the IMDS. Each mixture must now be classified under the substance that makes up the highest proportion of the mixture. In the case of the example above, this would be either as a thermoplastic (5.4.3) or as a special metal (4.2) if there is more silver than any other constituent.

Who is affected by the deactivation of REC019?

All suppliers of electrical and electronic products (E/E products) with PCBs and suppliers of individual components must now provide their customers with a full declaration. The work involved in processing inquiries, generating material data sheets (MDS) and checking every detail requires a lot of effort.

But you don’t need to manage this heavy workload alone

We are here to help you get on top of all the latest IMDS requirements with our tailored consulting services and training courses. Simply send us an email and we’ll get in touch to discuss your requirements and pinpoint the right solution for you. Our IMDS experts can show you how to use the system and optimize your internal processes. We can even manage all your material reporting requirements on your behalf.