Automotive manufacturing companies report and manage material and substance data added to the automotive parts on a digital platform called the International Material Data Management Systems (IMDS). The IMDS Steering Committee offers several recommendations to categorize and identify materials in Material Data Sheets (MDS). It also provides guidance on reporting the presence of declarable substances added to the automobile parts and materials.
The IMDS recommendation 019 was approved and enforced on October 30th, 2003. It is solely relevant for reporting electrical and electronic components. Recently, changes to the End of Life Vehicle Directive (2000/53/EC) and the communication requirements from the REACH in 2013, an Rec 019 process was created. The Rec 019 outlines a detailed description for creating MDS that are specific to electrical and electronic components, and includes all materials used at various stages of the manufacturing value-chain such as PCB/PWB, flexing circuit boards and electronic items added to automotive products.
To sum up, the IMDS Rec 019 was created to simplify the challenge of data submission process for complex materials and their small weight composition in the electronic assembly used in the automotive industry and avoid the uphill task for IMDS users who were previously creating datasheets. On September 10th, 2019, the Steering Committee decided to scrap the Rec 019 on the grounds that it was outdated and the module was used to hide dangerous substances such as lead. This deactivation, planned for 2020, was delayed until 2021 due to COVID-19 impacts. With IMDS Release 13.0 the published Recommendation IMDS019 Semi-Component MDSs (SMDSs) has been deactivated.
Consequences on Electronic Suppliers across the Automotive Industry
The deactivation of Rec 019 meant that electronic suppliers need to collect material declaration and make manual entries to IMDS. Companies and electronic suppliers can begin proactively with internal review of material data and document their findings to submit for compliance. This practice was deemed favorable in case the regulatory agencies choose full material declaration (FMD). Most of the suppliers are mostly expected to get FMD and others may deal with possible delays in IMDS submissions.
Electronic suppliers may likely face communication gaps around compliance if they are eligible for RoHS and their customers need to comply with IMDS. The change is also going to have a grave impact on the customers’ trust for not fulfilling their request for material information in a coherent manner.
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