The IMDS often poses a challenge for manufacturers of electronic and electrical components. These are usually not purely automotive suppliers but also produce for other industries. They are initially subject to other legal regulations such as the RoHS Directive. The aim of the RoHS Directive is to restrict certain hazardous substances in electrical and electronic equipment and to reduce the pollutant content in order to protect people and the environment as well as to improve recycling. However, RoHS and the ELV are similar in that both restrict heavy metals such as lead, mercury, cadmium, and hexavalent chromium. “Changes to the RoHS Directive and its exemptions are usually followed up in the ELV Directive. For example, it is envisaged that the RoHS exemptions for lead in aluminum alloys will probably find their way there as well in the next revision of the ELV,” explains Dr. Berthold Liebig, senior materials compliance expert at ebm-papst Mulfingen GmbH & Co. KG. Among other things, the company manufactures fans and electric drives for the automotive industry.
In addition, discussions are underway at the EU level about including lead in Annex XIV of the REACH Directive. This will also affect reporting in the IMDS and in the SCIP database, allowing companies to demonstrate that they are complying with REACH and the WFD guidelines. “A documentation tool such as the IMDS is also beneficial with regard to other substance restrictions, such as those that may occur in the digital product passport of the new planned Ecodesign Regulation,” Liebig adds. In addition, the IMDS queries the standard designation for plastic parts, which can facilitate subsequent sorting, and the recycled content as well as their origin (post-production or post-consumer). The data from the IMDS, such as the documented listings of materials, could also serve as the basis for simple life cycle assessments or the carbon footprint of a product. This makes studies in the field of sustainability possible and verifiable. However, different components pose different challenges here, such as electronic components. “These activities with IMDS data can also be used as a reference, such as for REACH evidence in questionnaires for sustainability ratings,” explains Berthold Liebig.
The Supply Chain Due Diligence Act (LkSG) has also been in force in Germany since January 2023. “This initially only directly affects companies with more than 3,000 employees, which must comply with certain due diligence requirements regarding human rights and environmental protection conditions, among other things,” explains Tim Thome, product environmental compliance expert at imds professional. “But their suppliers can also be indirectly affected, as their customers expect information on the origin of components, for example.” And here, too, IMDS can be helpful, he says, in accessing existing supply chains and knowing where which products and components are sourced. This information can be used for things like risk analysis. In other countries in Europe—such as France, the Netherlands, and the United Kingdom—similar laws are already in place, and Brussels is currently working on an EU law. “And next year, at the latest, when companies with 1,000 or more employees will also be subject to the LkSG, there will be very few companies that will be able to avoid dealing with the issue,” Tim Thome stresses.
However, in order to correctly implement all the legal requirements for product compliance, appropriate processes are required in the company and knowledge of materials and/or chemistry should also be on hand. In addition, systems such as the IMDS, the CAMDS, BOMcheck or even the SCIP database often have to be used in order to pass on data along the supply chain. Service providers such as imds professional can help to develop both processes and know-how. The necessary knowledge is imparted during training and coaching sessions and companies are supported in their work. Companies that do not want to or cannot take on the numerous tasks related to materials reporting themselves can take advantage of imds professional’s range of support services. “For example, we can take charge of supplier management, which is often very time consuming. What’s more, we can validate the data and create material data sheets. If no data can be obtained or if it needs to be checked for correctness, a laboratory analysis can also be helpful,” explains Markus Engel. These laboratory analyses are carried out by imds professional in collaboration with expert partners.
Markus Engel is convinced of the benefits of the IMDS for all parties involved. “Even if the increasing amounts of laws and substance restrictions initially mean a lot of work for companies, it’s very important to keep the overarching goal in mind: the need to strengthen environmental protection and sustainability, and to protect human health. Systems like the IMDS help to achieve this goal. And for recycling companies, the IMDS can be helpful not only in knowing what the individual components of a car are made of in order to recycle them, but it can also provide valuable information on who uses and needs which recyclates, which can help companies tap into a new customer base.”