GADSL explained for automotive suppliers using REACH and IMDS
GADSL means Global Automotive Declarable Substance List. Learn what its reporting flags mean and how it differs from IMDS, REACH and legal substance bans.
GADSL means Global Automotive Declarable Substance List, the shared list of declarable substances for materials and parts expected to remain in a vehicle at the point of sale. It supports supply-chain reporting through IMDS, but it is not legislation or a blanket list of banned substances. Official IMDS guidance explains the purpose and the scope.
A listing does not settle whether that use is legal where the vehicle will be sold. You still need the entry's classification, the reporting threshold and the underlying law.
What the GADSL list covers
The Global Automotive Stakeholders Group develops GADSL, with automotive manufacturers, tier suppliers, and the chemical and plastics industries involved. The aim is to harmonize substance information across the supply chain, so suppliers are not working from many different company lists. Scope covers substances expected to remain in the material or part at the point of sale. It doesn't cover every chemical used in a factory. See the official scope guidance.
Get the current documents from gadsl.org. The site calls its guidance the master document and provides a reference list with CAS numbers for substances within listed groups. Check the entry in both. A copy that dropped the guidance is an easy way to over-read the flag.
What D, P and D/P mean
The flags split declaration from prohibition. D is not a ban. IMDS defines the classifications as follows:
| Flag | Meaning |
|---|---|
| D | Declarable when the applicable reporting threshold is exceeded. D alone does not mean prohibited. Check that entry's threshold. |
| P | The IMDS summary calls this prohibited in all applications. Read the detailed entry and the underlying law before treating it as a worldwide ban. |
| D/P | Prohibited in some applications and declarable in the other cases. The detailed GADSL documents say which application is which. |
A reporting threshold is not a permissible concentration. Exceeding it tells you when to declare the substance. It does not tell you the material can legally be used. Do not paste one percentage onto the whole list. Official IMDS guidance separates reporting thresholds from permitted concentrations.
How GADSL relates to IMDS and EU law
IMDS is the reporting system
GADSL is the substance-declaration list. IMDS, the International Material Data System, is the material-data reporting system that uses it. The list is independent of IMDS, and company-specific exceptions still matter. IMDS describes GADSL as a voluntary industry initiative that does not replace contractual agreements between suppliers and vehicle manufacturers.
But a customer requirement can still make the declaration mandatory for that supplier. Treat an accepted submission and legal compliance as separate checks. One does not prove the other. The official IMDS guidance on critical raw materials also says GADSL should not be treated as an exclusion list. List membership alone is not a reason to stop every use.
REACH automotive duties are separate
REACH Article 33 is an EU duty, not a US rule, and a GADSL flag does not replace it. Official IMDS guidance describes communication to the article recipient when a Candidate List substance of very high concern is present above 0.1% by weight of the article. That 0.1% figure is a REACH article threshold, not a universal GADSL threshold.
The same REACH guidance says most of the relevant Candidate List substances will be added to GADSL. The lists are not the same. After a Candidate List update, recheck IMDS data, including information obscured by confidentiality or wildcards.
ELV restrictions come from legislation
The EU End-of-Life Vehicles Directive is the legal example. Article 4(2)(a) of the 30 March 2023 consolidated text restricts lead, mercury, cadmium and hexavalent chromium in vehicle materials and components, subject to Annex II exemptions. That text is a dated consolidation. Check the current act, and the exemption that fits the application, before you treat a use as allowed. The restriction comes from the directive, not from membership of GADSL.
How often the list is updated
GADSL is revised over time. Check the dated release documents and IMDS update notices, rather than assuming one fixed annual update.
For the material in front of you, read the current entry and its application, then report it in IMDS where a declaration is required. Read the underlying law and the customer terms separately.
RegAffairs AI explains GADSL and its relationship to REACH and IMDS.