In the September 2016 AIAG eNewsletter, we looked at the evolution of IMDS up to now. This month, we focus on IMDS Release 11.0, scheduled for production release in November 2016, which includes Chemistry Manager.

Why is Chemistry Manager Needed?

Initially, the End-of-Life Vehicle (ELV) directive was the only legislation that IMDS was designed to address, and it was simple to select the application codes for a specific substance. Other regulation-related substance groups were later introduced into GADSL and supported in IMDS: 

• Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulations has its permissible uses, permissible regions, and different REACH versions in different areas.  

• Biocidal Product Regulation (BPR) substances have product categories and substances that are permitted for some product categories but not others. There is also an additional consideration of why a specific chemical was added to a material (for example: if the usage is biocidal, BPR regulation applies; otherwise the usage is permitted).

Chemistry Manager was created because the regulations are becoming more complex and determining the applicability of the regulations involves more than just simple selection of application codes and exemptions. REACH and BPR substances are flagged in IMDS today, yet the complexity of the regulations has precluded an effective method for the supply chain to provide the information necessary to support compliance for these regulations. 

What is Included in Chemistry Manager for IMDS Release 11.0?

The initial release of Chemistry Manager allows for entering regulatory information required for the European Economic Area (EEA) for those companies whose materials or products are used in supply chains or sold inside the European Union (EU). In addition to providing a method to answer more complicated regulatory questions, the information can be provided throughout the supply chain simultaneously by requesting the information anonymously from the supplier and maintaining the link between the added regulatory information and the related MDSs.

The questions included in the initial release of Chemistry Manager are:   

• BPR
  • Still in Production? Is the material still in production?
  • Added for biocidal property? Has the active substance been added for its biocidal property?
  • Biocidal property desired in finished article/product? Is the biocidal property desired in the finished article or product?
  • Product type: Which product types are applicable to this active substance in this material?

• REACH (Material)
  • Still in Production? Is the material still in production and is at least one production site in the EEA?
  • EEA produced: Is at least one production site in the EEA or is the material imported into the EEA?
  • Authorization status: What is the authorization status?

• REACH (Component)
  • Produced in EEA? Is at least one production site of the component in the EEA?
  • Material imported? Is the material imported into the EEA?
  • Authorization status: What is the authorization status?

Future Chemistry Manager Considerations

The expectation is that the Chemistry Manager scope will expand as new regulations and new regions impose additional requirements. Examples are CHINA REACH and California Proposition 65, both of which require automotive products in their regions to report beyond what is currently collected in IMDS.

Automotive Industry Action Group (AIAG) members are starting to see a blurring of the lines between automotive and other product family regulatory considerations. For example:

• Electric chargers used for Electric Vehicles (EV) and not on the car itself are subject to the Restriction of Hazardous Substances (RoHS) directive.

• High-output batteries for EVs are subject to the Battery and Waste Electrical and Electronic Equipment (WEEE) regulations.

• 2019 RoHS will add four phthalates to their list of substances. Automobiles are exempt, but not components used for broader applications.

In addition, products are being used in a broader range of industries and becoming subject to a broader range of regulations. Just as the IMDS Conflict Minerals (CM) Analyzer helps companies identify products which are subject to regulations not completely covered in IMDS and feed that information to complementary solutions such as Compliance Data Exchange (CDX), Chemistry Manager will assist companies in preparing for the broader regulatory compliance topics that are beginning to impact our industry.

To learn more about IMDS, read Chuck and Marelle’s previous article, IMDS Through the Years, here.

Chuck LePard and Marelle Fogel are the Americas representatives for IMDS and CDX. Chuck is an engineering, manufacturing, material, and conflict mineral regulatory compliance senior consultant at HPE Eng. & Mfg. Solutions. He is an active member of AIAG's Chemical Management & Reporting and Conflict Minerals Workgroups and the AIAG Chemical Management & IMDS Summit Planning Committee. Marelle is a consultant specialist at HPE Eng. & Mfg. Solutions. She has a strong applications background related to manufacturing solutions, with an expanding role in AIAG Corporate Responsibility topics.
Hewlett Packard Enterprise is a proud Platinum Sponsor of the 2016 AIAG IMDS & Product Chemical Compliance Conference.