Electronics suppliers to the automotive industry will likely be impacted by a recent decision from the International Material Data System (IMDS) Steering Committee to deactivate IMDS Recommendation 019 (REC 019). The IMDS is the automotive industry’s system for managing data on the materials used in the manufacture of vehicles. REC 019 provided suppliers a modular approach to reporting materials in electronics components, including components containing lead, rather than reporting a fully exploded BOM.

With the deactivation of REC 019, electronics suppliers will have to collect full material declarations (FMDs) and manually enter this data into the IMDS. The Steering Committee’s decision to deactivate this recommendation was unanimous and cited unacceptable risks due to a lack of supplier due diligence during the reporting process. The only remaining unknown is when the deactivation will take effect but it appears the IMDS Steering Committee is leaning toward January, 2020.

Significant Impact for Electronics Suppliers

Electronics account for over 40 percent of the components included in an automobile. While there are provisions in the European Union (EU) Restriction of Hazardous Substances (RoHS) Directive that exempt electronics in automobiles from the directive’s scope, there are similar restrictions for heavy metals (Pb, Cd, Hg and Cr +6) in the automotive-specific ELV Directive. While the thresholds for the restricted metals are the same for the two Directives, exemptions between the two are not harmonized.

This can result in compliance gaps and miscommunication between the electronics suppliers, who are well versed in RoHS compliance, and their automotive customers when they are required to create material data sheets within the automotive-exclusive scope of IMDS. REC 019 was intended to support accurate reporting in line with material declarations made in the IPC-17521A format, which electronics suppliers would already be familiar with.

Learn more about the regulations impacting the automotive industry in Beyond the Database: Your Guide to Expanding Automotive Supply Chain Requirements.

Most of the data necessary for IMDS compliance can be found in an IPC-1752A material declaration, but the lack of an appropriate data exchange facility or process meant that transferring this data into the IMDS was not a viable option but neither was manual entry of electronic components. Many electronic components in vehicles are more complex than all of the non-electronic components combined. Removing REC 019 will alleviate a perceived compliance gap in IMDS, but it drastically increases the amount of work and data collection necessary for electronics suppliers to enter into IMDS as they complete the Production Parts Approval Process (PPAP).

Removing REC 019 will also result in additional and differing customer-specific requests that companies must meet in order to remain competitive. Reliable data management processes will be essential to manage proactive responses in the face of change. The Assent Compliance Platform automates supply chain data collection and centralizes it for efficient risk assessment and analysis. Contact us to learn more.

Neil Smith
Regulatory & Sustainability Expert, Product Sustainability

Neil Smith helps companies achieve their goals and supports them as they scale their programs by ensuring they are informed and prepared when it comes to their regulatory  Read More

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