Accurate materials reporting in the International Material Data System (IMDS) is crucial for the automotive industry. A material data sheet (MDS) that meets all requirements is important for an OEM to demonstrate compliance with substance bans and can be used for type approval evaluation. Additionally, the system helps meet the recycling and reuse quotas mandated by the European End-of-Life Vehicles Directive (ELV). OEMs pass on the reporting obligation to their supply chain to obtain all data on the materials and substances used. This not only requires a company account in the IMDS but also appropriate processes. Missing MDSs must be requested from suppliers, incoming data must be checked and then compiled into a data sheet. Specific members of staff should be familiar with REACH, and various departments such as development, quality, and production must also be involved. The larger and higher up a company is in the supply chain, the more complex the tasks and processes. All aspects converge with OEMs, which is why they face unique challenges. It is therefore no surprise that many turn to service providers for support. This has been the case for a manufacturer of trucks and car parts, which has been working with imds professional GmbH & Co. KG for just over a year. 

“The collaboration began when the truck and passenger car divisions of the company were in the process of separating,” recalls Markus Engel, Senior Consultant for Product Environmental Compliance at imds professional. First they sat down together to define the terms of the collaboration and to establish a plan for materials reporting in the IMDS. “Working closely with our customer’s key contact, we reviewed the existing processes, redefined the inspection criteria and acceptance procedure for a data sheet (MDS), and thus improved data quality,” reports Engel. “We regularly meet with key individuals from various departments, both virtually and in person at the customer’s site.” 

The project team at imds professional ensures materials reporting is carried out smoothly in the IMDS. This means they check all the MDSs that are submitted by suppliers and are necessary for sampling. If the data does not meet the required criteria, data sheets are rejected and requested again. If all data is correct, it is accepted and can be used for materials compliance evaluation. Additionally, parts used in the automotive sector are evaluated according to the PPAP procedure and transmitted to the customer. “Several hundred data sheets need to be checked daily,” explains IMDS expert Engel. This takes up a significant amount of time, so a company would need to invest in personnel to complete these tasks. This makes outsourcing to a service provider efficient and cost-effective, especially because it means peak periods can also be effectively covered. “We can flexibly involve additional project staff as needed,” he adds. 

In the meantime, imds professional also supports branches and subsidiaries at various locations in the USA as well as several American suppliers. Unlike in Germany, where the supply chain was already included in the IMDS, it had to be completely rebuilt in this case. This means suppliers had to be informed and registered in the IMDS. “Onboarding is always a challenge and requires a lot of time,” explains Markus Engel. “Training for suppliers is often necessary, and we can conduct these in various languages.” In this case, training and communication took place in English and Spanish, as many suppliers are located in Central America. Additionally, inspection criteria had to be defined, and the necessary processes set up internally. “We also provided a landing page specifically for our customer’s suppliers containing important information about the IMDS in both English and Spanish,” explains Markus Engel, continuing to outline further support options available from imds professional. He continues, “We also work with some suppliers to ensure the quality of MDSs to avoid rejections.” 

In the USA, there is a strong focus on being able to make statements about PFASs in addition to the required IMDS entries. Under the US chemical legislation TSCA, all products containing PFASs – per- and polyfluoroalkyl substances – must be reported retroactively to 2011 from July, and this reporting must be completed by January 2026. “The IMDS is ideally suited to meet this requirement, as it provides full declaration and allows users to search data sheets to report all used substances,” adds the IMDS expert. 

Although trucks and heavy-duty vehicles do not yet need to be included in the IMDS, the truck manufacturer has decided to continue using this system due to its history. Because of its passenger car division, the company has been represented there from the very beginning and has collected the material data for all of its vehicles via the system. “Since the new EU End-of-Life Vehicles Directive (ELV-R) will soon require manufacturers of other vehicles (not just passenger cars) to use the IMDS, I would advise all other HDV manufacturers to review their processes as soon as possible and to take into account the planned changes to the ELV,” advises Markus Engel. Most suppliers have been accustomed to transmitting their data via the IMDS for many years and supply both automotive and truck manufacturers, who are often already members. 

This situation arises from the planned requirements for using recyclates under the European Green Deal. It is planned that the ELV, which currently only applies to vehicle classes M1 and N1, will also apply to vehicle classes M2, M3, N2, N3, O, and L3e, L4e, L5e, L6e, and L7e five years after it comes into force. Although there will be exceptions and not all requirements will apply to the newly added vehicles, it is planned that 25% of the plastic content of a new vehicle should consist of recyclates, and this requirement will apply to all. “The IMDS already allows users to specify the recyclate content of a material, including whether and to what extent it comes from chemical or mechanical recycling, or if it is derived from bio-based materials,” explains Markus Engel. “Manufacturers should take advantage of these possibilities.” Additionally, there will be a take-back obligation for manufacturers, and it must be ensured that end-of-life vehicles are actually dismantled, and the parts are reused or recycled as completely as possible. “To do this, it is necessary to know the exact composition of substances, and this can be ensured through the IMDS,” continues the Product Environmental Compliance expert. A circular economy passport for vehicles is also planned, for which IMDS data can be used, which demonstrates how the IMDS supports materials transparency. 

About imds professional:

imds professional provides a range of solutions to help companies remain in full control of their materials and product compliance obligations. We offer three core services: consulting, support, and training. These services can be customized to ensure your company fully complies with all types of environmental legislation, directives, and guidelines. Our unbiased, targeted advice, customized services, and training courses ensure you remain competitive in the face of increasing regulatory requirements. Small to medium-sized operations and businesses throughout the world from the manufacturing and processing sector have been relying on our expertise since 1999. Further information can be found on www.imds-professional.com