International Material Data System - Prohibited or Declarable Substances Lists

Prohibited or Declarable Substances Lists

The starting point of the system are the black and gray lists of prohibited and declarable substances. These substances, when used in materials and components for the automotive industry, are of concern to human health, environmental safety and recycling. Prohibited substances, like hexavalent chromium, are forbidden due to legal or internal regulations. Declarable substances should not be construed to mean that the substance is prohibited from being used in a vehicle part, or is to be de-selected from use but that there is a requirement to know that the substance is in the part.

In the early days, most OEMs had their own list of prohibited and declarable substances which made it a challenge for suppliers far down the supply chain to report as they didn't know where their product would appear. The OEMs responded to the concern of the suppliers by harmonizing their requirements into one list, the Global Automotive Declarable Substance List (GADSL). Some OEMs still have their own lists and most of the OEMs accepting the GADSL still have complementary requirements. Because of ongoing research and lawmaking, these lists are subject to change.

Because it is a computer-based system, IMDS recognizes hazardous substances by comparing the entered data with the lists of prohibited substances. Hence OEMs can trace hazardous substances back to the part and work on eliminating them through the supply chain.

All substances have to be stated in the material data sheet (MDS) of the IMDS with a resolution of 1 gram or better - not just the declarable and prohibited substances (Cr VI / Hg /...). That is why substances and materials of products must be known in detail. Material information on parts is later delivered from the OEMs to dismantler companies in order to achieve the goals of the ELV Directive.

The basic premise of the system is that the flow of data through IMDS companies mimics the flow of the product through companies in the physical world with each link in the supply chain supplying data in IMDS to their customer as they deliver product to their customer. Data entry in IMDS is frequently a requirement of PPAP - in other words, no data no pay for product.

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