On September 12, 2022, the revised IMDS Terms of Use (ToU) will go into effect. According to DXC Technology, this is to allow “IMDS-registered companies (OEMs and suppliers) extended use of existing IMDS information for legal requirements or regulatory obligations in the areas of sustainability, environment and corporate social responsibility.” In other words, you can use IMDS data, for example, to comply with the Supply Chain Sourcing Obligations Act. So by now it’s not “just” about meeting ELV, REACH, TSCA, Prop65, etc., material compliance requirements. Other aspects are being added, new areas such as “sustainability” and “due diligence” are now explicitly named in the ToU. The change in the terms of use can support companies in meeting their many legal obligations by drawing on existing data in the IMDS, which has been established for years.

Examples of uses for IMDS data now include:

• Vehicle certification and IMDS compliance checks
• REACH, BPR, RoHS, TSCA
• CSR such as human rights, animal welfare, deforestation, critical raw materials, conflict minerals, Supply Chain Due Diligence Act
• Import and Export Compliance
• Product Environmental Footprint, chemical strategy for sustainability, eco-design regulation for sustainable products, digital product passport, circular economy and waste treatment (e.g. SCIP, IDIS)
• Improvement of production process, safety data sheets
• Improvement of research and development for the quality process

IMDS functionalities will not change initially. However, according to DXC, additional IMDS functionality may be implemented in the future to support data collection for some of the listed requirements.

The new terms of use (ToU 6.0) can be found in this PDF.