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.
Chemical and sustainability information demands are increasing, and while IMDS is the tool to supply this information, a more dynamic approach and a more refined release process are needed and are in the works.
These were the key takeaways from the IMDS Steering Committee Update during the 2023 IMDS & Product Chemical Compliance Conference.
Committee chairperson Matt Griffin gave the presentation virtually from the United Kingdom. Griffin is also the senior technical specialist in hazardous materials compliance at Jaguar Land Rover Limited. He looked at IMDS future challenges and the strategic approach that the IMDS Steering Committee is adopting to be able to address them. Here’s a closer look at part one of his presentation. Look out for part two in the next newsletter.
Future Challenges
Griffin identified substance regulations, the circular economy, and sustainability as the three main future challenges. The substance regulations of concern are PFAS, bisphenols, PVC, and flame retardants.
“PFAS must be one of the biggest challenges we face in the European manufacturing industry,” Griffin said. “It's not just an automotive problem. It's going to touch every single manufacturing industry — computers, mobile phones, tablets, cars. There are an awful lot of industries that are going to be impacted by the PFAS regulation.”
While bisphenols have recently been withdrawn from substance regulations in the EU, they will be re-instigated once amended. Other activities are looking at potential PVC restrictions or restrictions of PVC additives, and then a flame retardant strategy.
There are also circular economy challenges ahead. In IMDS 14, a more enhanced PCR/PIR reporting was released. “We’re looking at chemical recycling and sustainable materials and how to address those challenges in a circular economy,” Griffin noted.
Additionally, there is a big sustainability requirement on the horizon with our product carbon footprint.
IMDS Strategy
There are three strategic themes or approaches to getting IMDS data: Tier to Tier, the Regulations Wizard, and Enhanced Reporting.
Tier to Tier
Tier to Tier is the standard, traditional approach for communicating the IMDS data sheet. It is used for stable information that is not expected to change. Data goes to each customer for approval.
“It’s incredibly slow to go from the bottom of the chain to the top of the chain,” Griffin said. “If anything’s changed, it may not reach the end customer if there’s a break in the chain and someone doesn’t forward that data.”
Later, the Regulations Wizard was introduced to get extra information to determine whether usage is OK. It’s used for REACH Authorization and biocidal products regulation. With REACH, if a substance has passed its sunset date, that substance is not allowed to be used in the EU. However, it can be used in products that were made into an article outside of Europe.
“So we need to understand the country of origin, where this substance is being used, and also if there’s an authorization number attached to the use of that substance if it’s used in Europe,” Griffin explained.
Regulations Wizard
The Regulations Wizard is going to be expanding to other regulatory information for MCCPs, PAHs, etc., and. It will become mandatory.
It is decoupled from the version of the materials IMDS ID, so if you've got version one of the material and it contains a substance and you need to know that information, you can send an anonymous request using the Regulation Wizard, which gets completed by the correct actor in the supply chain. You don't see who that actor is. But even if the materials are on version 3, 4, 5, that information is correct for all versions of the materials, and it's visible to all actors of the supply chain who are using that material even if they've not been sent it.
"The benefits are the data comes direct from the material creator and the first component creator, it’s quick — all tiers see the same level of data, there's no acceptance or rejection, and there's no IMDS supply chain disruption,” Griffin said. And the enhanced reporting will follow that it will be dynamic reporting. The data will come from the correct point in the supply chain and there'll be no supply chain disruption
He continued, “It's a great way to update that information really, really quickly without going through the normal Tier to Tier approach, so we're very pleased with the way that Regulation Wizard enhancement was implemented.”
Enhanced Reporting
In a similar transfer model to the Regulations Wizard, Enhanced Reporting is dynamic reporting where the data will come from the correct point in the supply chain and there'll be no supply chain disruption.
For Enhanced Reporting, new attributes and information are required and it can impact the lowest tier. Initially, it will be voluntary.
Look out for part two of “The Future of IMDS” in the next newsletter.
About the Presenter
Matt Griffin is the senior technical specialist for hazardous materials compliance at Jaguar Land Rover Limited. He is the current chairperson of the IMDS Steering Committee and an active member of the ACEA Materials and Substance Work Group, working on REACH, ELV legislation, and vehicle interior air quality. Griffin was also part of the ISO team that developed the ISO 12219 vehicle interior air quality and component emission standards.
