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Product Carbon Footprint in IMDS — Introduction and Status

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This is part of a series in which we recap sessions from the 2023 IMDS & Product Chemical Compliance Conference held on October 17-18, 2023, at Suburban Collection Showplace in Novi, Michigan.

What should you know about product carbon footprint (PCF) and how it’s coming to IMDS? These important questions were addressed in a session at the 2023 IMDS & Product Chemical Compliance Conference titled “Product Carbon Footprint in IMDS — Introduction and Status.”

Oliver Schmid, Senior Engineer, Circular Economy, for Hyundai Motor Europe Technical Center GmbH, gave this presentation. Schmid is a member of the IMDS Steering Committee. He chairs the IMDS PCF Enhancement group, which includes carbon footprint information input into IMDS. In his presentation, he went over the background, reasoning, disclaimers, basics, decisions taken, and more. Here’s a recap of much of his presentation.

“PCF is the next big thing,” Schmid said. “You should at least familiarize yourself with the concept and calculation of PCFs and be prepared to become part of the reporting. ... IMDS is the most efficient established system to report PCF in the automotive industry."

Schmid shared that the regulations worldwide require declarations on PCFs in the near future, either on regulations on specific components, like in the EU Battery Regulation (a requirement in 2025) or as part of the corporate reporting requirements or of company pledges on carbon neutrality.

The whole automotive industry is in need of real PCF over the full supply chain (Scopes 1-3), he said. However, until now, there was no established system available to communicate this specific information. To tackle this major problem, the LCA Enhancement R246 was created to include PCF into IMDS. Last year, this enhancement was clearly voted a top priority by the OEMs and the supplier associations. There’s a very clear mandate to include PCF in IMDS as soon as possible, Schmid said.

Disclaimers: Setting the Scene
Schmid outlined three important disclaimers to quell fears and concerns about PCF and IMDS.

For one, the PCF value will not be mandatory for each material/component and every actor in IMDS. But rather, it depends on direct legal requirements on yourself and your B2B contracts — basically, if your customer faces legal requirements or PCF is part of their company policies.

Secondly, PCF will not be another rejection reason for IMDS data sheets. Instead, PCF reporting will follow the new enhanced reporting path, which is decoupled from the acceptance/rejection scheme of the normal, standard IMDS process. To make sure it cannot be misused, the PCF will not be visible before accepting the IMDS data sheet.

Lastly, the proper calculation of a PCF does require expert knowledge or even an expert tool to do so. A simple summarization in IMDS is not possible because PCF is a lot more complex. PCF requires additional inputs besides the received PCFs from the sub suppliers, such as internal processing or process waste.

Basics and Decisions Taken: State of Play 1
Schmid pointed out that the standard in IMDS that will be followed in reporting of calculated PCFs is bottom-up reporting, so it’s not about raw data. The whole calculation of the PCF is defined in the Catena-X Rulebook V2 and further explained in upcoming guidance documents. The Catena-X Rulebook was decided on after reviewing several rulebooks and was proposed by the European Automobile Manufacturers' Association’s working group on Life Cycle Assessment. As detailed PCF calculation is happening outside of IMDS, only a single PCF value cannot stand on its own, but additional values and information are needed, he said.

Regarding general decisions and basic requirements, Schmid noted four key topics:

  • Roles: The introduction of a new role is necessary, as the current IMDS experts are most likely not the PCF experts in a lot of (bigger) companies.
  • Transparency: Although it’s not finally decided yet, there is no disclosure of supply chain as a baseline for a transparency requirement. There is the need to identify hotspots and gain experience.
  • Regular review requirement: Especially in the beginning, the PCF value will change quite often, and a regular/annual review and potential update is required.
  • Enhanced reporting: Like Regulation Wizard, a dynamic reporting process is needed where updates are passed through and become visible automatically.

“There are still a lot of open questions regarding very specific topics and also some general ones, which we have to solve on our way to implement this,” Schmid said.

Thus, it’s important to keep updated on the latest developments with PCF and IMDS.

These topics and more will be covered at the 2024 Hybrid IMDS & Product Chemical Compliance Conference at Laurel Manor in Livonia, Michigan. Save the dates October 15-16, and stay tuned for announcements. Registration will open in April.

About the Presenter

A geoecologist by profession, Oliver Schmid has worked for 13 years as material compliance manager at an Automotive Tier 1 with a focus on substance restrictions such as REACH and being responsible for the reporting, namely IMDS. Schmid joined the European R&D Center of the Hyundai Motor Group in 2023 as senior engineer, where he continues working on circular economy projects and in the European automotive association. He is also a member of the IMDS Steering Committee, and he chairs the current activities on the IMDS PCF Enhancement.



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