In April 2023, the IMDS website released a bulletin titled “Global PFAS Chemical Regulations and Required IMDS Actions.” This bulletin aims to raise awareness about the essential uses of per- and polyfluoroalkyl substances (PFAS) in automotive applications and highlights global legislative efforts targeting these chemicals.

North American Disclosure Requirements

Both the U.S. and Canada have introduced disclosure requirements for PFAS:

- United States: The Environmental Protection Agency (EPA) has enacted a rule mandating manufacturers, including article importers, to report PFAS-containing products manufactured between 2011 and 2022.
- Canada: A newly published notice requires reporting of select PFAS substances in products for the year 2023. Additionally, states like Maine and Minnesota will implement reporting requirements in 2025 and 2026, respectively.

Industry Collaboration

Automotive industry associations are working closely with stakeholders to address PFAS challenges, including identifying materials and parts containing PFAS. The Global Automotive Declarable Substance List (GADSL) was significantly updated in August 2022 to include thousands of PFAS substances with low reporting thresholds. Ongoing reviews ensure all PFAS substances in the automotive supply chain are accurately identified and declared.

Importance of Compliance

It is crucial for all automotive tiers to regularly consult the latest GADSL version to ensure accurate IMDS data on PFAS declarable substances. Close collaboration between manufacturers and suppliers is essential for meeting these reporting requirements. Suppliers should familiarize themselves with relevant PFAS regulations and stay updated on legislative changes to proactively address compliance.

Upcoming Deadlines

Given the frequent updates to the GADSL and the low reporting thresholds, the automotive industry must ensure that all PFAS used in their products are accurately reflected in IMDS. By January 1, 2025, IMDS data must be updated to comply with the U.S. EPA's PFAS reporting and recordkeeping regulations.

For more information, visit https://public.mdsystemimds-pfas-supplier-bulletin-update