The IMDS Steering Committee has decided that in the near future, standard data sheets for electronic components may no longer be used for reporting in the IMDS system as has been the case up to now. The PCB standards in IMDS that are provided by ZVEI, also known as Rec019 semi-finished parts, will be deactivated at the same time as IMDS Release 13.0 is rolled out, i.e. probably on 19 May 2021, according to an update by the Steering Committee in June 2020. At the latest by then, companies will have to collect real and accurate data in order to fulfill reporting and compliance requirements in the automotive sector. They are no longer allowed to include standard semi-component data sheets with fixed materials, weights and chemical concentrations in their reports.

Some Automotive Manufacturers are Converting Even Earlier!

Some companies are starting to phase out the standard data sheets earlier. For example, since August 17, 2020, Volkswagen has rejected all material data sheets (MDB) using REC019. This also applies to the group brands Porsche, Audi, SEAT, Skoda, Bugatti, Bentley, Lamborghini, Ducati, Volkswagen Passenger Cars and Volkswagen Commercial Vehicles. General Motors (GM) has also provided corresponding information to suppliers. All new and special regulations including all details can be found under General Motors or Volkswagen at OEM Specific Information.

The Devil is in the Detail: Different Reference Values

PCB assemblers often already require MDS for all components on a board such as resistors, integrated circuits (IC), capacitors and transistors. Some companies in the supply chain are increasingly checking PCB MDS against the defined rules from the 001 guideline in IMDS and rejecting them. For example, FBOM representations are no longer accepted. The rationale being that with this structure, REACH compliance cannot be evaluated.

The devil is in the detail here, namely in the different reference values for pollutant contents in the components. For example, the End-of-Life Vehicle Directive (ELV) refers to “homogeneous materials”. This refers to separate materials that cannot be easily broken down into their components, but can be separated again by simple means such as grinding or milling. In contrast, REACH refers to “article”, which is, however, only vaguely defined in the original text of the REACH regulation. Clarity was only brought about by a ruling of the European Court of Justice (ECJ). According to this ruling, an article is something that has existed as an independent product at some point in the production chain, in short: “Once an article, always an article”.

Cable as Example: Differences between ELV and REACH

For substances that are subject to both ELV and REACH regulations, different calculations result from different reference values. Let us take a cable containing lead as an example, a substance whose use is regulated in both regulations. According to ELV, a cable consists of two homogeneous materials: copper wire and plastic insulation; it is therefore necessary to check the concentration of a certain substance in the insulation and in the wire. However, according to the definition in REACH, these are not two separate articles. Only the wire has previously existed as a separate article. The insulation is sprayed on during production. Therefore, a separate article “insulation” never existed, but only the granulate to produce it.

This means that, for example, the concentration of lead contained in the insulation must be related to the total cable weight. Because the insulation often accounts for only ten percent of the weight or less, the lead may no longer be subject to REACH notification. In relation to the entire cable, the concentration may be less than 0.1 percent and therefore not subject to REACH notification. According to ELV, however, plastic insulation would be a homogeneous material and it would have to be checked whether there is an exception in the ELV for the contained lead with a concentration of five percent. For our example, lead in plastic materials, no such exception applies, though.

Capacitors: Definition as “Collection of Materials” is problematic

Most manufacturers of capacitors, for instance, report their parts in IMDS as a collection of homogeneous materials, the so-called Flat Bill of Material (FBOM). This procedure, which has been common practice in the electronics industry for years, has so far been accepted by the automotive industry. A corresponding agreement published on the website of the German Electrical and Electronic Manufacturers’ Association (ZVEI) has now been removed and is no longer valid.

Some companies no longer accept a description of capacitors as “collection of materials”. In fact, MDS for capacitors published by manufacturers contain materials for the foil, electrolyte, case, lead wires and solder etc. It is difficult to estimate where one item ends and the next begins. If, for example, a wire is soldered to a ceramic body, then the wire and body also exist alone, that is to say they are independent articles. But the solder joint is only created when soldering them together, so it is not an article. What is the reference value now? Such gaps in the definition leave a lot of room for interpretation.

Since this situation is unlikely to change in the short term, manufacturers of electronic components must represent their capacitors as a collection of individual REACH articles to be on the safe side and to not endanger the production process. Manufacturers in Asia should therefore look into the details of the European REACH legislation. European customers will still have to be convinced on this.

If you want to make sure that your company meets the EU reporting requirements or need help with implementation, please contact us. We also offer customized in-house training courses concerning REACH, RoHS, ELV and IMDS.