Changes in IMDS Terms of Use – Version 7.0
Effective Date: September 8, 2025
The following outlines important new provisions introduced in IMDS Terms of Use Version 7.0, highlighting how the updates expand the system's scope, legal obligations, and data governance expectations for users.
1. Introduction of Extended OEM Scope
What Changed: IMDS now formally includes Original Equipment Manufacturers (OEMs) of electric and electronic equipment, in addition to traditional on-road vehicle OEMs (cars, trucks, buses, motorcycles).
Why It Matters: This reflects the industry shift toward electrification and regulatory focus on electronics, requiring suppliers to report data for a broader range of end products beyond automotive.
2. Expanded Scope of Data Use
What Changed: The use of IMDS data now includes compliance with newer regulations such as:
a. PFAS under the Chemical Strategy for Sustainability (CSS)
b. Supply Chain Due Diligence Acts (e.g., human rights, environmental risks)
c. Digital Product Passport (DPP) and Ecodesign for Sustainable Products Regulation (ESPR)
Why It Matters: This integrates climate, circular economy, and ESG criteria into IMDS, aligning material data collection with EU Green Deal initiatives and global sustainability mandates.
3. Clarification of Confidential/Internal Use Data
What Changed: Data marked as "Confidential" or "Internal Use" must be disclosed if it includes substances that:
a. Become Substances of Very High Concern (SVHC) under REACH
b. Are listed in GADSL (Global Automotive Declarable Substance List)
c. A transition period will be provided before the system reveals these substances.
Why It Matters: Ensures legal compliance even when sensitive formulations are used, balancing confidentiality with mandatory disclosure.
4. Export Control Clauses Enhanced
What Changed: More robust language added to comply with U.S. and international export/import laws:
a. Includes mention of ITAR (International Traffic in Arms Regulations)
b. Lists sanctioned countries (e.g., Iran, North Korea, Venezuela, Crimea) and denied parties
Why It Matters: Prevents unlawful data transmission and ensures alignment with global trade laws, particularly relevant for international companies using IMDS.
5. Tighter Restrictions on System Use
What Changed: Clear prohibition of:
a. Unauthorized access methods (hacking, password mining)
b. Automated data scraping, including use of bots, scripts, crawlers
c. Commercial training on the productive IMDS server (unless pre-approved)
Why It Matters: Protects system integrity and prevents misuse that could affect data reliability or system performance.
6. Clarification on DXC Access and System Statistics
What Changed: DXC may:
a. Access anonymized system metrics (e.g., number of users, MDSs)
b. Internally access user data only with prior written consent and under supervision
Why It Matters: Increases transparency and reinforces confidentiality while allowing maintenance and system health checks.
7. Account Deactivation and Reactivation Procedures
What Changed: Explicit rules added:
a. 30-day written notice before deactivation for inactivity
b. 20-day objection window
c. 3 working day reactivation period upon user request
Why It Matters: Provides clear user rights and a predictable account management framework.
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