IMDS Steering Committee address

Timo Unger Manager Environmental Affairs

Hyundai Motor Europe R&D

Why do we use

IMDS?

IMDS is a…

…Success Story

IMDS release process

4 f

IMDS release process

f

WHAT NEXT IN IMDS?

• No IMDS release planned in 2017

• Requests from supplier

organisations and OEMs received

and evaluated

• Enhancements to be considered

for next release in 2018 identified.

• High Priority items identified

• Business Designs currently drafted

• Cost benefit analysis under way

• Business Designs under discussion:

Chemistry Manager enhancements

Improved work flows

Spare parts handling / identification

Next slide…

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Status: In progress No decision taken yet

Release 12 enhancements under discussion

Release 12 enhancements under discussion

ID Enhancement Request

3 Update of Recyclates in IMDS SC182: request consists of 2 parts. 'Proposal 1' would be an enhancement, 'Proposal 2' is an update of wording in IMDS and not to be treated as enhancement, but should be done

4 + 5 Assignment of MDSs to IMDS Requests request #4:marking of MDSs assigned to a request directly in the inbox (and in the A2 module) of IMDS request #5:Update MDS in a completed IMDS request SC182: there is more behind the entire request handling. Not allow sending MDS if there is a request open…? Idea: have a working group to define BD for a proper Request handling, not work on all the individual items. Group all request items into one enhancement request! Involve suppliers, how to best manage their part of business. Their input will be valuable

57 + 6 Keep Cursor focused in Inbox after opening details and returning to Inbox request #57: Position of cursor in the Inbox after opening a MDS request #6: Enable to return to the same point in the Inbox after opening a MDS instead of returning to the top of the list

8 + 11 Preliminary MDSs #8: Preliminary MDS in warnings #11: Add to search result of In/Outbox info if preliminary MDS or final MDS

12 IMDS Analytics: enlarged excel file for result details

14 + 40 +48 Chemistry Manager: Intelligent Substance/Material Management for BPR '#14: Intelligent Biocidal Flagging #40: Enhance the Chemistry Manager in the sense that only materials with relevant classifications are considered for the BPR regulation wizard #48: Chemistry Manager: implement matrix of material classes for biocides to prevent irrelevant substance/material combinations

18 German material name #18: delete German material names #94: German tradename

19 System Language Change during IMDS System Use

28 +58 #28: Make Warnings on Version Management violation visible to Recipient SC182: are there reasons not to show same infos on both sides? Quality issue #58:Recipient Warning for New MDS ID for Supplier / Part Number combination SC182: similar to AG's request #28. With version warning

41 Implement new user profile which allows the access to metadata only (see extra folder) Not AI relevant

ID Enhancement Request

45 Rejection mail should contain some more information on company that rejected the datasheet

59 Make the “MDS Passed All Checks” message more explicit

65 Chemistry Manager – Request Handling for latest MDS version containing no more regulatory substances while previous versions did

68 Chemistry Manager – • Display ID/Version as well for all direct MDS references of accepted MDSs • Add Filter Option for Direct Suppliers in Chemistry Manager Detail Screen

71 + 69 Spare Parts, Application Code #71: Spare Part Flag SC182: combine with #69? If at all, then 1st 71, then 69 MG: ths is only for chapter 4 for OEMs #69: Create Error When Sending IMDS with old application codes SC182: combine with #71 in general: how to deal with old ACs (error handling for old ACs). 2 step aproach, first #71

84 In “regulatory information” if “complete” will be chosen for “state of information”, all parts/assemblies will be shown where at least one information has been completed, but not all information. E.g. if two BPR substances are inside one MDS, for one BPR the information is complete, but for the other one not, the entire MDS will be shown as completed. “Incomplete” does not work at all. SC182: DXC to look at it. DXC Comment: Flag is set for entire MDS, not for single substances. In principle the statement is not wrong, it had been implemented as designed. If a different behaviour is needed then the search frame will have to consider this, or an explanation has to be provided to the users

90 Implement a function to see last status changed (date) and status (accepted) as part of an Analysis Parameter SC182: adding similar search profile as implemented. Is in search but not in analysis. Talk to CLEPA for Business Design ==> Mr. Müller to contact CLEPA if SC selects item

100 Substance lists: Add GLAPS to IMDS SC182: 2 step approach. 1st substance group (flag only those in IMDS which would as well be on GLAPS), 2nd more information similar to GADSL. Prio H for step 1 - substance group only. Step 2 is out of scope Info 19.07.2017: GLAPS is still in draft mode

101 Chemistry Manager: summary for important individual optimizations Chemistry Manager – Improve Wizard Search Handling and User Guidance

102 Improve MDS Update Function

103 Improve Performance Problems due to Automatic MDS Update Functionality

CHEMISTRY MANAGER UPDATE

… as of June 23rd, 2017

• 14,200 requests

• 4,700 closed / 9,500 open

• Suppliers entering Regulatory

Information even before request

• PLEASE ENTER REGULATORY

INFORMATION LATEST WHEN

REQUESTED

Chemistry Manager

• How to find requests sent to my company? – A wizard can be found under „Functions“ –> „Regulation Wizard“

• Outlook – In principle the functionality is open also for other legislation (e.g. TSCA, Prop65, ...)

– Pre-Requisite: The benefit is outweiging the generated effort

Enhancement 100: GLAPS vs. IMDS - A Clarification

• GLAPS: Harmonised list of „critical“ process chemicals and their regulations to be monitored in the global plants

• No current or future direct link / obligation to/in IMDS, but an idea: – Flag GLAPS Substances in IMDS

similar to other substance groups

– Reason: Companies can draw conclusions on the legal status of chemicals used in the production process

Data Quality & Reliability

Why is it important to keep

IMDS information up to date?

Take Home Message

• GADSL is not a black list

• Most of the substances listed can be used and need not to be substituted

• Don´t make reference to GADSL when phasing out!

• GADSL substances change

• Application change / or you

have received a request from

the OEM

• You have received an updated

MDS from your supplier THE

WHEN DO I NEED TO UPDATE MY IMDS DATA?

Tools to keep information up to date

• “Allow Faster Update” - Release 9

enhancement

• Chemistry Manager – Release 11

enhancement

• Application code (13 & 16) deactivation

– June 2017

Data Quality

• Overall finding: Everything starts with a good Material Material Data Sheets (MMDS)

• It is not a secret: IMDS Data Quality – There is „some“ room for optimisation!

R 9.0 (12.6.2014)

Restrict MDS copies: - Only the MMDS creator can copy his own MMDS, - Receiver are only able to forward

Before being able to send MMDS, the system automatically checks these MMDS based on commonly accepted criteria. No sending without passing this quality checks

Allow faster MDS updates

R10.0 (15.10.2015)

Introduction of standardized maximum deviation based on component weight, eliminate tolerance entry

Material checks for Classification 5.x and 6.x - come up with a warning if a material of those classifications consists of one substance only

New check: Published MMDSs shall be error and warning free

Self-certification for MMDS publishers - Reduce the amount of users publishing MMDSs

R11.0 (15.01.2017)

Rollout of Chemistry Manager

Allow Forwarding for Material MDS (MMDSs)

Avoid further usage of own/accepted preliminary MDSs -Final version MDSs must not contain references to preliminary MDSs

Mark MDS as obsolete - reduce distribution of not used data

• Since Release 9.0 several measures have been initiated:

Data Quality

However there is still a long way to go... – SC working groups actions to increase the

MMDS quality in IMDS

• Further optimize the process-chemicals list and its related processes

• MMDS Quality: e.g. only allow material manufacturers to create MMDSs, …

• Material Naming: e.g. define clear rules to name materials (e.g. via a wizard)

The basis for many of our future decisions

• Reasons to collect use information of (potential) SVHC’s in the Automotive Industry via IMDS – Perform impact assessment of potential restrictions on the automotive business

– Input into Stakeholder Consultation and other legislative development processes

– Improvement of alternative assessment (Substitution) projects

• These information serves as basis for many of our future decisions

• GENERAL QUESTION: Are we impacted by that substance? – Is there a need for Notification acc. to REACH Art 7.2 or communication acc. to Art. 33?

– Is there a need for further actions concerning Authorisation or Restriction and other global legal obligations (e.g. SNURs, CEPA, Stockholm, ...)

Do we have to provide input into stakeholder consultations (Advocacy)?

Do we have to start communication with the responsible substance associations?

Do we need a Substance Pilot?

- Is there an impact foreseen for the production sites of OEMs or suppliers?

- Does the substance potentially have to be added to GADSL?

- What are the necessary compliance actions (e.g. substitution)?

Automotive Impact Assessment Process How can YOU make use / benefit ?

• There is a process defined for general global requests (e.g. Stockholm Convention, national laws (e.g. China, US, ...), GADSL criteria checks, ...

• In principle, every association can start a substance impact assessment if the criteria (see *2) are fulfilled.

• Process to approve a global substance investigation:

1. Send request to one of the four ACEA WG M&S contact persons

1. Dave Bassan (Opel) - david.bassan@opel.com

2. Matt Griffin (JLR) - mgriff52@jaguarlandrover.com

3. Karin Oldenburg (BMW) - karin.oldenburg@bmw.de

4. Timo Unger (Hyundai) – tunger@hyundai-europe.com

2. Contact person to asks WG M&S via email

3. WG M&S has X days to respond

4. No response = Yes

5. If “No”: Detailed discussion of the reasons /concerns

The detailed Impact Assessment Process

• Start: A substance needs to be investigated

• OEMs and suppliers check the usage of that substance – In parts (only OEMs): IMDS

– In the production (OEMs & Suppliers): Internal systems

• If relevance is indicated, invitation to detailed discussion

• Outcome is stored in a central document (SVHC Tracking Sheet)

• Stakeholders will be informed

• Usual Timeline: From request to results ~ 3-4 weeks

Please help us to

protect (y)our business

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Provide input into the SVHC survey for process chemicals

(not for parts!)

Request to suppliers

REACH ECJ Article Judgement How to deal with Printed Circuit Board Assemblies (PCBAs)?

The Overall question… Does the IMDS system or the IMDS rules need to be changed in order to comply with the new ruling?

REACH ECJ Article Judgement How to deal with Printed Circuit Board Assemblies (PCBAs)?

• The current ECHA SiA guidance (Chapter 5.1.3) does : – acknowledge the difficulty of data collection and the need for pragmatic solutions

(Due diligence based approach)

– indicate that the exact parts composition is not required to fulfill the obligations (full IMDS Data)

• In the ECHA Partner Expert Group (PEG) meeting – it was accepted that in some sectors a certain level of aggregation (=Rec019) would be acceptable

– Industry was invited to develop own guidance documents considering the industry specifics

• Based on that, the REACH TF has concluded that – There is no need to change the Rec019 reporting in IMDS, in order to fulfill the (new) obligations

caused by the ECJ Judgement.

• The current Rec019 reporting enables users to fulfill their communication duties in line with the judgement,

if the overall Rec019 principles are applied...

• However: The company internal calculation needs to be adjusted…

Overall Rec019 Principles

• If companies make use of a Rec019 data sheet, they must have available all data on the exact material composition of their purchased electronic components

• Companies are committed to take the required measures to verify / update their Rec019 data on a regular base (e.g. GADSL changes)

– By doing so, a company knows those components that are subject to legal regulations, e.g. phase out of exemptions, REACH-SVHC

– Can react accordingly to stay compliant in terms of the parts themselves but as well to related documentation

– If specific components are not covered by Rec019 but needs reporting acc. to O5A, they can be added as separate declaration => Fulfillment of the ECJ – Judgement

© Robert Bosch GmbH 2016. All rights reserved, also regarding any disposal, exploitation, reproduction, editing,

distribution, as well as in the event of applications for industrial property rights.

AIG Recommendation on Rec019 –

Change of the internal calculation method

No need to change the Rec019 reporting, but...

Required adjustment of the internal 0.1% w/w calculation for Rec019 datasheets

• Rec019 PCBA Material Data Sheets does not include the weights of the individual articles

• The O5A CL substance threshold calculations should be made based on the percentage in the homogeneous material instead.

• From the above it is clear that the use of IMDS Rec019 is in line with the REACH Article 7.2 and 33 texts and the ECJ Judgement, and also with the principle of proportionality.

Other ongoings

• China – A sub group of the IMDS SC is currently negotiating with CATARC on how a transfer of data

can be done considering the given prerequisites

– A Chinese Steering Committee has been established

• IMDS Service Provider – The contract with DXC has been prolonged for another 5 years

• A new group has been established – HDCV (heavy duty commercial vehicles). Co-workers are welcome!

Other ongoings

In cooperation with the industry associations AIAG, CLEPA and JAPIA, the IMDS SC will publish the following IMDS Recommendations as a new version on 10th November 2017:

• IMDS 005: Leather

• IMDS 007: Steel Flat Products (strips and sheets), Metallic Coated (hot-dipped or electrolytically)

• IMDS 008: Electroplated (electrolytically deposition) fasteners, now also containing content of IMDS 009 Components with electrolytically deposited coatings

• IMDS 012: Automotive Sealer and Adhesive Products

• IMDS 023: “Preliminary” MDS during the Prototype Phase

The following Recommendations will be deactivated on 10th November 2017, because those are covered by other Recommendations.

Desription Comment

IMDS 009 Components with electrolytically deposited coatings to be removed, combined with IMDS 008 IMDS 014 Automotive Lighting to be removed, covered by IMDS 001 IMDS 015 Automotive Steering Systems to be removed, covered by IMDS 001 IMDS 017 FRP Fiber Reinforced Plastic Products (Thermosets) to be removed, covered by IMDS 001 IMDS 020 Thermal systems to be removed, covered by IMDS 001

To Sum up

Don´t underestimate your power to improve…

• If you receive an updated MDS, please update your information and pass it on to your customers

• Don´t forget to also maintain your REC019 data AND fulfil the Rec019 Reporting Rules (see previous slides)

• Provide Chemistry Manager Regulatory information latest when requested

• Taker over responsibility on MMDS quality and help to improve

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Often it is difficult to find

the necessary motivation

But sometimes, the motivation

finds you…!