There is growing awareness of environmental issues including pollution and recyclability of manufactured goods. One of the biggest polluters has been used cars disposed of at junk yards. In order to tackle this issue, the EU has taken an initiative (first in the world) to address these issues by enforcing an End-of-Life Vehicles (ELV) directive which focuses on reducing the hazardous substances and improving the recyclability of the car. ELV directive also requires OEM and other stakeholders to establish several collection centers to collect old cars and dismantle / recycle as per the directive listed standards / targets. The ELV directive requires automotive manufacturers to prove that their car meets the recyclability targets and restrict the usage of hazardous chemicals such as Pb, Cd, Hg and Cr6+.

How IMDS evolved?

Hewlett Packard Enterprise (then EDS) collaborated with European Union (EU) car manufacturers in 1999 and created a material data exchange system. In 2000 the first International Material Data System (IMDS) was released with ratification of the EU End-of-Life Vehicle (ELV) directive legislation.

In 2001 Hewlett Packard Enterprise extended IMDS into the United States with Automotive Industry Action Group (AIAG). Later IMDS was adopted as automotive standards in Japan and Koren. IMDS is now available in nine different languages and used worldwide by global automotive OEMs and suppliers, with over 400,000 users from more than 150,000 companies.

The motive behind IMDS is to provide fast and efficient information flow between OEMs and its suppliers. But today the focus is to improve data quality by checking the MDSs and Global Automotive Declarable Substance List (GADSL).

IMDS Release 12.0 has gone one step ahead by adding the Chemistry Manager framework to its fold. The chemistry Manager initially supports Biocidal Product (BPR) and REACH Annex XIV and has options to add other regulations in the future.

What is IMDS Compliance?

Started with an agreement between nine automakers( Audi, BMW, Daimler, Ford, Opel, Porsche, VW and Volvo) IMDS is now a global standard used by OEMs to classify parts used by them. The use of IMDS is to make sure that all supplies are following national and international compliance standards. Automobile manufacturers in the European Union were the pioneers in following the IMDS standards, later it is followed by many OEMs worldwide that require it to follow IMDS data.

Background

ELV directive 2000/53/EC was issued by European Union in the year 2000 with an aim to reduce hazardous substances such as Lead, Cadmium, Mercury and Hexavalent Chromium in M1 (cars with less than 8 passengers excluding the driver seat) and N1 (trucks less than 3.5 Tonne GVW) category vehicles. This directive has also enforced strict norms on recyclability targets such as 95% recyclability/recoverability by the year 2015 for all the vehicles which are placed in the European market. Japan, Korea and China have also enforced similar legislation; many automotive OEMs in North America are voluntarily following the EU ELV directive. The maximum allowable percentage for Lead, Mercury and Hexavalent Chromium is 0.1% and Cadmium is 0.01% by weight.

Why IMDS?

Today automotive, aircraft, toy and electronics manufacturers, and a growing list of others, are required to keep extensive materials data to comply with global regulations and environmental laws on such concerns as hazardous substances. HP International Material Data System (IMDS, www.mdsystem.com) provides a database of information on components and materials to make IMDS compliance easier.

There is a high cost for each manufacturer to assemble, store, and maintain such information. The ability to selectively share materials information with similar companies would be costly, too. IMDS was created by HP for an association of manufacturers to make supplier facts accessible economically. Its security policies keep proprietary information protected while other information is shared.

As a manufacturer, it needs a materials system maintained 24/7 for designers around the world. It’s easy with IMDS—already the world automotive standard—or an HP standard solution for any industry.

How to do IMDS Submission

IMDS is basically a web-based database where any registered supplier can send/receive material data sheets with other suppliers or OEMs. Assume that a

❖ Tier1 supplier supplies a new design (assembly) to its customer/OEM, Tier1 supplier will need to get all the components of the assembly from its Tier2.

❖ In order the Tier 2 will submit their component MDS, they need to get their material MDS from their suppliers and so on.

❖ Tier2 suppliers submit the IMDS datasheets to Tier1 along with the PPAP and get accepted by Tier1.

❖ Once Tier1 receives IMDS data sheets from all the Tier2 suppliers, it will be approved and assemble all the data sheets as per the BoM structure and submit it to the OEM.

This cycle continues for every engineering change of the part along with NPI.

The ELV directive has two major requirements, viz., controlling the amount of hazardous substances such as Pb, Cd, Hg and Cr6+ and improving the recyclability of the vehicle. As the datasheet contains all the basic substance information pertaining to that part/assembly, OEMs can decide to accept or reject the part based on their requirements and IMDS submission approval standards. If the datasheet is rejected by the customer, the supplier needs to rework on that MDS and resubmit it for approval again. The reporting process for a part/assembly continues till the OEM approves it. Upon successful approval of the assembly MDS, it can then be sent to a third party IMDS software, which calculates the recyclability based on the material classifications using ISO 22628 standards.

10 steps approach to get fully compliant with IMDS

1. Get all material information from the supplier chain

2. Make suppliers aware of IMDS report and required data

3. Every substance of the Material must be disclosed & its breakdown should be 100%

4. Part weight should be equivalent to actual weight. (Physical weight of the part)

5. The part in IMDS must be in accordance and up to date with the current regulation and also other regulations as well

6. Preferable language must be used and good communication must be maintained throughout the supply chain

7. Users should have proficient knowledge of the IMDS tool

8. Glitch free PLM (Product life cycle management) tool must be maintained

9. PLM & IMDS tool should have a good relation to each other and the user must be well versed with their relation and its functionalities

10. One point of contact is preferable for the whole organization to handle things related to the IMDS report.

Top IMDS Challenges –

1) Tracking Regulation updates:

Prepared to respond to periodic evaluation of ELV regulation and how it is applicable to supply chains. Often, the fear of non-compliance drives organizations to react to new regulations in a knee-jerk manner without sufficient knowledge of the regulations or their applicability. Organizations would do well to stay informed on regulatory updates and changes, and then quickly assess how these requirements apply to their supply chains.

2) Training for small volume suppliers

As IMDS training is an expensive process an affording a training will not be economically viable for small volume production organizations

3) Changing the validation criteria of OEMs

its considered as the OEM will update their validation criteria once in a year and we have to keep the note of this regulation update and transfer this change throughout the supplier chain IMDS process

4) Language constraints

suppliers either small or big the geographical location is relevant as a major part of the process dealing will be in English as some suppliers may not be proficient in English and the communication will be difficult.

5) Testing facility availability/cost

The IMDS data needs the end product basic substance break down weight percentage it may go even too small value like 0.0000001.the testing facility availability and the coast of this kind of testing is expensive

APA’s MDS Xpress IMDS Software helps in achieving 100% compliance

There are four major steps to achieve IMDS compliance in the automotive industry.

Step 1: BOM analysis

Step 2: Contacting suppliers via email

Step 3: Validating the MDS parts received

Step 4: Building the BOM tree structure

‘MDS Xpress’ software, can automate these steps leading to 3 benefit-

 

A) The headache of supplier follow up is largely removed

B) BOM Analysis is completed in 4 hours which used to take 5 days. Saves you several person-hours every week.

C) And data quality is improved in the IMDS submissions.

Future of ELV & IMDS

IMDS compliance

The IMDS Team is continuously working on and providing various releases and adding new features to help the regulation as well as to its users. Here is what IMDS is working on

● Assess and manage compliance to existing substance regulations (GADSL, REACh, ELV, Conflict Minerals, Biocides)

● Compile substance compliance documentation to be submitted for certification to countries where required (e.g. Type Approval in EU)

● Create pretreatment and dismantling manuals for each type approved model

● To effectively implement other regulations like REACH compliance, Conflict Minerals Compliance, biocides, etc in IMDS and thereby making the parts in accordance with the compliance and standards.

● Collecting more accurate and clear information from specific suppliers is implemented which is an added advantage. It helps to find each individual part is in compliance with the regulatory standards. And the best example would be (REC019- deactivation).

Furthermore, many new features as well as more accurate regulation checks can be done in the near future as technology advancements are rapidly emerging.

Future of ELV & IMDS

● Limit the use of hazardous substances in new vehicles (Lead, Cadmium, Mercury and hexavalent Chromium)

● Design and produce vehicles which facilitate re-use and recycling

● Develop the integration of recycled materials

● Improve the environmental performance of economic operators

● Ensuring proper functioning of the internal market and avoid distortions of competition

● Capable to recover more than 95% of the material used in Vehicles by 2018.

What should be the roadmap of IMDS compliance and ELV regulation:

● Strengthen inter-actions with EU-level environmental compliance assurance networks

● Environmental compliance and governance for the European Green Deal

● Creating and support tools for sanctioning environmental criminals and offenders, and for making the polluter pay

● Work together on access to justice in environmental matters

● Being smart – using geo-spatial intelligence

● Prepare a compilation of CJEU rulings on the obligation for the Member States to remedy the failure to carry out environmental assessments

● Establish a strategic approach to training and deliver tailored training activities through the networks of environmental inspectors, police, prosecutors and judges

● Strengthen cross-network cooperation and development of environmental expertise

● Strategies for verification of self – monitoring and reporting

Green, global manufacturing

Worldwide, there is a clear trend toward greener legislation. Once there were only four heavy metals restricted by legislation; today there are many more substances. REACH legislation has added still more to the list. To comply with laws, it’s vital for manufacturers and suppliers to have worldwide knowledge of restricted substances and know which substances are included in their components.

IMDS consultant

APA Engineering is providing IMDS compliance service to major automotive OEMs around the world. If you are looking for complete IMDS compliance solutions then contact us here