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The IMDS
The recent updates to the Global Automotive Declarable Substance List (GADSL) and the ACEA Regulatory List have important implications for companies using the International Material Data System (IMDS). While these changes may appear to be routine list maintenance, they can directly affect reporting obligations, data quality requirements, and the acceptance of Material Data Sheets (MDS) throughout the automotive supply chain.
GADSL Updates: More Than Just New Substance Entries
GADSL serves as the automotive industry’s global reference for substances that must be declared or are subject to restrictions. Updates to the list are regularly incorporated into IMDS and can introduce new reporting requirements for suppliers and manufacturers alike.
The latest revisions include newly added declarable substances, changes to the classification of existing substances, and additional attention to substances that may fall under the category of Medium Chain Chlorinated Paraffins (MCCPs). As a result, substances that were previously considered uncritical may now trigger declaration requirements or require closer review.
For IMDS users, this means that existing MDS submissions may generate new warnings, compliance checks may produce different results, and the IMDS Regulation Wizard may flag substances that did not previously require action.
The Role of the ACEA Regulatory List
The ACEA Regulatory List complements GADSL by covering substances and substance groups that are regulatory relevant but may not meet the criteria for inclusion in GADSL itself. This is particularly important for substance groups that are regulated by definition but do not have a comprehensive list of CAS numbers.
Examples include certain PFAS-related substances, PFOA-related compounds, and other complex substance groups. Even if a substance does not appear on GADSL, it may still require declaration if it is included in the ACEA Regulatory List and present in a material or component.
For companies working with IMDS data, the ACEA list provides an additional layer of regulatory transparency and helps identify substances that could become compliance concerns in the future.
What Should IMDS Users Do Now?
To stay ahead of potential compliance issues, companies should consider the following actions:
- Review existing material data for newly added or reclassified GADSL substances.
- Use the IMDS Regulation Wizard to identify materials affected by the latest updates.
- Pay particular attention to chlorinated paraffins and PFAS-related substances.
- Engage with suppliers to obtain updated substance information where necessary.
- Align internal compliance and material screening processes with the latest GADSL and ACEA requirements.
Taking these steps early can help avoid data quality issues, customer inquiries, and potential MDS rejections later in the supply chain.
Looking Ahead
Regulatory requirements for chemicals and materials continue to evolve rapidly, especially in areas such as PFAS, substances of concern, and sustainability reporting. The latest GADSL and ACEA updates are another reminder that material compliance is becoming increasingly data-driven and supply-chain focused.
For IMDS users, regular reviews of existing material declarations and proactive monitoring of regulatory developments are no longer optional. They are becoming a critical part of maintaining compliance and meeting the growing expectations of automotive manufacturers worldwide.
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