Q.01

What is IMDS?

IMDS (International Material Data System) is the car industry's shared online database for material data. Suppliers use it to declare the materials and substances in the parts they supply, and vehicle manufacturers (OEMs) use that data to meet the legal and customer requirements placed on them. In the system's own words, it is "the automobile industry's material data system", where "all materials present in finished automobile manufacturing are collected, maintained, analysed and archived" (IMDS public pages). It is an industry tool, not a regulation, though suppliers are expected to use it as a condition of doing business.

Approach: I searched the public IMDS guidance documents and the GADSL reference list in our datasets, and opened the official IMDS public website (public.mdsystem.com).

Origin and operator

  • Audi, BMW, Daimler, EDS (now DXC Technology), Ford, Opel, Porsche, VW and Volvo developed it together. DXC Technology runs it, and most global OEMs now use it (IMDS public pages).
  • It went live in 2000. Its aims were to help OEMs record and report what materials go into a vehicle, support recycling and reuse, and record Substances of Concern. By 2016 it was used by 35 vehicle manufacturers (about 60 brands) and suppliers at every tier [1].

How it works

  • The basic unit is the Material Data Sheet (MDS). Suppliers build them up from materials and the substances in them and send them to their direct customer.
  • An ordinary safety data sheet (MSDS) "does NOT contain sufficient information to create a material", because you need the full breakdown of every substance [2].
  • Whoever creates a material MDS "is considered legally responsible for the validity of the data" [2].
  • Only substances expected to still be in the vehicle at end of life go into the ingredients. Processing chemicals are left out, and the GADSL works the same way [3].

Who has to provide data

  • The IMDS Steering Committee is the group of global OEMs that sets IMDS requirements. Its July 24, 2026 position paper says it applies to all organisations supplying products or materials anywhere in the automotive supply chain.
  • If your products go into automotive assemblies or sub-assemblies, "you are responsible for providing the required IMDS datasheet to your customer." PPAP (Production Part Approval Process) documents may also be required, even if your contract doesn't mention them.
  • The paper links this to quality management audited under IATF 16949:2016 [4].

Regulations it supports

  • IMDS data is used to show compliance with the EU End-of-Life Vehicles (ELV) Directive 2000/53/EC and REACH, and to manage restricted substances [5].
  • A supplier describes IMDS as supporting the duty under REACH Article 33 to pass information to customers, alongside RoHS and customer-specific OEM requirements [6].
  • GADSL (Global Automotive Declarable Substance List) is the industry's list of substances that must be declared. It covers substances that are regulated, expected to be regulated, or shown to pose a significant risk. Declaring a substance "does not mean, however, that the substance is prohibited" [7][8].
  • Related DXC tools (IMDS-PLUS, CDX and MaCS) build on IMDS data to check against GADSL, ELV, SCIP, REACH, RoHS, product carbon footprint (PCF) and recycled-content requirements [9].

I can look up whether a specific substance is on the GADSL, or what the ELV or REACH Article 33 duties mean for your parts.

Q.02

Who needs to submit an IMDS material data sheet?

Any company that supplies products or materials used to build vehicles anywhere in the automotive supply chain has to submit an IMDS material data sheet (MDS), and it goes to its direct customer. The IMDS Steering Committee is the group of global vehicle manufacturers (OEMs) that governs IMDS. Its July 24, 2026 position paper says this applies to "all organizations that supply products or materials used anywhere in the automotive supply chain." It adds that if you supply products used to make automotive assemblies or sub-assemblies, "you are responsible for providing the required IMDS datasheet to your customer" [4].

Approach: I searched the public IMDS guidance in our datasets: the Steering Committee position paper, the IMDS user manuals, newsletters and the IMDS Efficiency and Effectiveness guideline.

Who sends it, and to whom

  • Every supplier at every tier sends to its direct customer. The data sheet goes to "the company that uses your product in its manufacturing process (your direct customer)", along with any documents your customer requires under the contract, engineering or quality requirements. Depending on the customer and the vehicle programme, PPAP (Production Part Approval Process) documents may also be needed, "even if it is not specifically stated in your commercial or contractual agreements." The paper ties this to quality management audited under IATF 16949:2016 [4].
  • Material and raw-material suppliers are included. The 2007 IMDS Efficiency and Effectiveness guideline (V.1.2) says "Raw materials supplied to a next tier level must be reported in IMDS as materials." This also covers materials mixed from inputs bought from different suppliers [10].
  • Traders are included too. The same guideline says every business unit supplying products into the automotive supply chain falls under the requirement. Units that trade components, semi-components or materials "are not exempted" [10].
  • What counts as a "component". IMDS uses a sender-recipient model: anything one business unit ships to another along the supply chain to build a vehicle is a component. That covers components, semi-components and materials, "It does not cover basic substances" [11].

What a supplier has to do in turn

  • Collect material data on all automotive products coming in from its own suppliers. Its own component MDSs must reference that supplier data [10].
  • Use only IMDS-trained staff to check incoming MDSs and to create MDSs for customers, and assess its sub-suppliers with the Efficiency and Effectiveness Questionnaire [10].

How the request usually arrives

  • A customer can send an MDS Request inside IMDS. It must name the supplier and the deadline, and must give the part/item number [12].
  • Requests are optional: "there is no IMDS requirement to use it," and customer and supplier decide between themselves whether to use them [13].

Cost

  • Under the IMDS Terms of Use (as changed from 1 July 2017), basic IMDS use is "free of charge only for suppliers and sub-suppliers of the member companies."
  • An OEM using IMDS for its own obligations at the end of the supply chain must sign a separate contract with DXC [14].

The duty to submit comes from your customers and the industry, not from law: the position paper presents it as an OEM purchasing requirement. It is not a legal obligation in itself.

Q.03

How does IMDS relate to REACH?

IMDS is not part of REACH. REACH places no duty on anyone to use it. In practice it is the car industry's main way of passing REACH substance information along the supply chain, and the REACH lists are built into it. IMDS flags Candidate List SVHCs, Annex XIV and Annex XVII substances. It tracks authorisation status for Annex XIV materials, sends warnings ahead of sunset dates, and has a SCIP function. SCIP is the ECHA database for articles that contain Candidate List substances, a duty that follows from REACH Article 33. All of this sits on top of the GADSL declarable-substance list.

Approach: I searched the public IMDS guidance in our datasets: user manuals 14.5 to 15.4, the IMDS-a2 and IMDS-PLUS manuals, the newsletters, the SCIP training note, the February 2026 Candidate List flagging notice and the IMDS reference list covering REACH Annex XVII and the Candidate List. I did not open the REACH legal text itself for this answer.

1. Candidate List (SVHC) flagging

  • IMDS shows a "REACH-SVHC" flag next to the GADSL category. SVHC substance names are always underlined in the ingredients tree, and the flag is explained as "on Candidate list" [15].
  • The flags are updated whenever ECHA adds substances to the Candidate List. In the 4 February 2026 update, for example, n-hexane and several bisphenol AF entries already in IMDS were "Flagged as SVHC" [16][17].
  • The IMDS reference list maps each Candidate List entry to its IMDS substance, GADSL classification and SVHC flag. Short-chain chlorinated paraffin entries, for example, show "SVHC flag in IMDS added with GADSL 2026 Update" [18].

2. Confidentiality cannot hide SVHCs

  • You can mark a substance as confidential in a material data sheet only if it is not on the GADSL or the Candidate List. If it is added to either list later, that data sheet "must not be sent or referenced anymore, because substances of concern must be disclosed" [15].
  • The IMDS check returns an Error for any data sheet that holds confidential substances of concern. Since Release 15.1 such entries are automatically disclosed the night after the flag is set [19].

3. Article 33 and SCIP

  • IMDS Newsletter 58 describes the SCIP duty as follows. From 5 January 2021, Article 9(1) of the Waste Framework Directive (as amended by Directive (EU) 2018/851) requires suppliers to report to ECHA any article or complex object containing Candidate List substances "according REACH Article 33 requirement". The duty applies to any European supplier delivering such articles to professional customers.
  • The IMDS Steering Committee built a SCIP function so suppliers can meet that duty directly from IMDS (Release 13.0) [20].
  • Newsletter 55 gives three cautions:
    • Only substances in ECHA's Candidate List package can go to SCIP through the system-to-system interface. The IMDS substance list flags some extra SVHCs that "clearly fulfil the requirements of article 59.10 REACH".
    • Default values that IMDS offers for SCIP fields are used "under the full responsibility of the data owner".
    • "System acceptance of data by SCiP does not necessarily mean compliance" [21].
  • A supplier case study describes IMDS as supporting the Article 33 duty to pass information on to customers [6].

4. Annex XIV (authorisation)

  • Material data sheets carry REACH regulatory information. Fields include "Still in production", "EEA produced" and "Material Auth. Status" (Done / In progress / ? / Not intended). You can search by Annex XIV substance and by sunset date or last application date [22][23].
  • Four weeks before a substance reaches its sunset or last application date, IMDS emails the companies whose materials will then have "an invalid authorization state", naming the substance and material affected [24].

5. Annex XVII and reporting

  • IMDS-a2 and IMDS-PLUS can check materials and articles for "REACH relevant substances (REACH SVHC, Annex XIV, Annex XVII)" [25][26].
  • The SCIP substance report gives weight and percentage data at article and homogeneous-material level. It lists Candidate List, Annex XIV and Annex XVII membership [27].

6. Data rules that matter for REACH

  • An ordinary SDS is not enough to build an IMDS material, because the full substance breakdown is needed [2].
  • The check gives a warning when a plastic or elastomer material is declared as 100% one substance. The reason given is that "additives may contain certain substances from REACH (e.g. plasticizers)" [19].

The legal duties (Article 33, SCIP notification, authorisation, restriction) stay with you under REACH and the Waste Framework Directive. IMDS is the industry's tool for collecting and passing on the data. It does not prove compliance.

I can check whether a particular substance is on the Candidate List, Annex XIV or Annex XVII, and how IMDS and the GADSL flag it.

Q.04