Q.01

What is GADSL?

GADSL is the Global Automotive Declarable Substance List. It is a voluntary automotive-industry list of substances that suppliers report to vehicle manufacturers (OEMs) when those substances are in parts and materials. It covers substances that are regulated, are expected to be regulated, or that the steering committee has agreed by consensus are scientifically shown to pose a significant risk to human health or the environment [1].

Who runs it and why

  • The list comes out of the Global Automotive Stakeholder Group (GASG). The GASG is made up of OEMs, tier suppliers and material suppliers, organised into three regions: Americas, Europe/Africa/Middle East, and Asia/Pacific. Each region nominates six members to a Steering Committee, which decides what goes on the list [1].
  • The aim is to replace each company's own declaration list with one industry list, and to keep declaration costs down across the supply chain [2].
  • The original publication is at www.gadsl.org. The German automotive association (VDA) republished it as VDA 232-101, and version 1.0 was released on 2005-01-25 [1][2].

Scope

  • It applies from production through to end of life. It only covers substances expected to remain in the material or part at the point of sale [2].
  • Processing chemicals are therefore not on it. IMDS guidance also states the list is not exhaustive: a CAS number that is missing from the list does not mean the substance is free of declaration or prohibition requirements [3].
  • Being listed does not in itself mean a substance is prohibited or must be phased out [2].

Classifications

  • D (Declarable): must be declared if it exceeds the defined threshold.
  • P (Prohibited): prohibited by regulation in certain applications, or not allowed above regulated thresholds [4].
  • Some entries are classed D/P. For example, lead carbonate hydroxide (CAS 1319-46-6) has two thresholds. Portable batteries (<5 kg) "shall not contain more than 0.01 %" lead by weight, with an exemption for portable zinc-air button cells until 18 August 2028. In all other applications the threshold for impurities is 0.1%, and "any intentionally added content must be reported." The entry gives its legal source as the REACH Candidate List [5].

How it works with IMDS

  • In the International Material Data System (IMDS), the automotive industry's material-declaration platform, basic substances carry GADSL "duty-to-declare" (D) and "prohibited" (P) flags [6].
  • Any GADSL substance in a material above the declaration threshold "must be reported" in the IMDS submission [4].
  • IMDS guidance says records should not be rejected just because they contain D-listed substances. The exception is where a B2B agreement says otherwise [4].
  • The current GADSL Reference List is the September 2026 update, which shows new and changed entries in red font [5]. Older IMDS guidance described the list as updated at least once a year [4].

Approach: I used the current GADSL Reference List and the public IMDS guidance, which includes the VDA 232-101 edition of the GADSL preface.

If you send me CAS numbers or substance names, I can look up their current GADSL classification and thresholds.

Q.02

How does it relate to REACH and IMDS?

GADSL is the industry's list of what to declare, REACH supplies much of its legal basis, and IMDS is the system where suppliers make the declarations. Many GADSL entries name a REACH instrument as their legal source: the Candidate List (SVHC), Annex XIV authorisation or Annex XVII restrictions. IMDS then flags those substances, so a supplier's data sheet (MDS) can be used for REACH Article 33 and SCIP reporting.

1. GADSL ↔ REACH: REACH is a legal source for many entries Each entry in the September 2026 GADSL Reference List has a "Legal source" field, and REACH appears there in three ways:

  • Candidate List (SVHC): 4-tert-butylphenol (CAS 98-54-4) is classed D, with legal source "Reg. (EC) No 1907/2006 (REACH Candidate List)" [7]. Decamethyltetrasiloxane (CAS 141-62-8) is also D, with the note "Changed EU Regulation: Now listed in REACH Candidate List" [8].
  • Annex XIV and Annex XVII together: DEHP, DBP and DiBP are classed D/P. Their legal source is REACH Annex XIV plus "(EU) 2018/2005 REACH Annex XVII, Entry 51", the action required is "REACH Authorisation Sunset Date", and the effective date is 2015-02-21 [9][10][11].
  • Annex XVII only: dimethylfumarate is classed P under REACH Annex XVII, with a reporting threshold of 1e-07 [12].
  • Substances still in the REACH pipeline: some entries cite "Included in list of substances under REACH PACT assessment" or ECHA calls for evidence (for example on MCCPs). This fits GADSL's scope, which covers substances expected to be regulated as well as those already regulated [8][1].
  • The list also cites non-EU laws, such as K-REACH, California battery labelling and China's GB/T 30512 [10]. So GADSL is broader than REACH.

The REACH reference lists that ACEA publishes on IMDS carry a GADSL classification column next to each Candidate List entry. They are also updated after each GADSL revision: version 4.5 (2026-09-11) is the "Post 2026 GADSL September update" [13][14].

2. IMDS ↔ GADSL and REACH: flags on basic substances

  • In the IMDS substance tree, a blue substance name means GADSL D (duty-to-declare), red means P or D/P, and underlined means the substance is on the REACH SVHC list [15]. So one substance can carry both a GADSL flag and an SVHC flag.
  • Each time ECHA updates the Candidate List, IMDS publishes a flagging notice. The 04-Feb-2026 notice says, for each new SVHC, whether it is in IMDS and on GADSL, and records the action taken:
    • Bisphenol AF (CAS 1478-61-1) was already GADSL D/P and is now "Flagged as SVHC".
    • n-hexane (CAS 110-54-3) is in IMDS as a process chemical and is not on GADSL, but was still flagged as SVHC [16].
  • IMDS's SVHC flagging can go further than ECHA's own lists. IMDS Newsletter 55 says the IMDS basic substance list flags some substances as SVHC that are not in ECHA's Candidate List/SCIP package "but clearly fulfil the requirements of article 59.10 REACH" [17]. ACEA's disclaimer explains why: the ECHA lists are not exhaustive. For example, hydrated salt forms that are not listed are still SVHCs and "must be reported when present above 0.1% (w/w)" [13].

3. Using IMDS data for REACH Article 33 and SCIP

  • IMDS Newsletter 58 explains that SCIP comes from Article 9.1 of the Waste Framework Directive (Directive (EU) 2018/851). From 05 January 2021 it requires reporting to ECHA of any article or complex object containing Candidate List substances "according REACH Article 33 requirement". The duty applies to EU suppliers delivering to professional customers [18].
  • IMDS added a SCIP function in Release 13.0 so suppliers can meet that duty directly from IMDS [18].
  • Default values provided for SCIP are the data owner's full responsibility. IMDS also warns that "System acceptance of data by SCiP does not necessarily mean compliance" [17].

4. What this means for a supplier

  • Use ECHA's official lists first, and treat the ACEA lists on IMDS (Candidate List with the Authorisation List, Annex XVII, EU POP, EU PIC) as an extra aid that is "not legally binding". The REACH Regulation text "is the only authentic legal reference" [13].
  • In IMDS, report only substances contained in the final material that are above the stated GADSL threshold, following Recommendation 001, Rules 4.4.1.B and 4.4.1.C [13].
  • For EU article producers, the ACEA Candidate List sheet also gives a notification status for Article 7(6) purposes. It is guidance only; producers are pointed to the ECHA Guidance [13].
  • IMDS SVHC reports show the GADSL/SVHC flag next to each substance's list memberships, such as "REACH Annex XVII Group 2" and "SCIP SVHC" for nickel [19].

Approach: I used the September 2026 GADSL Reference List and the public IMDS guidance: newsletters, Candidate List flagging notices, the ACEA reference lists for REACH, POP and PIC, and the user tips. I did not check the entries against ECHA's own Candidate List or the Annex XIV and Annex XVII texts.

Q.03

How often is the list updated?

The governing text says GADSL is updated once a year, but in practice it has recently been revised twice a year. In 2026 there was a 20 March update and a September update.

What the documents say

  • VDA 232-101 (2005 edition): "The GADSL will be updated and published annually in February." Declarations "should be performed according to this updated version" within 12 months of publication at the latest. Requests for changes "must be received by July 15 each year in order to be considered for the next version" [20]. The Steering Committee "meets annually or more at its prerogative" to decide on the list [1].
  • IMDS guidance: the material-creation tips say "The GADSL is only updated once a year." They add that the IMDS basic substance list itself can be updated at any time when a user asks the IMDS Service Center [3]. IMDS Newsletter 39 describes the list as updated at least once a year [4].

What has actually happened recently

  • 2026, first update: IMDS published the "GADSL Update of 20-Mar-2026". It included reclassifications such as triammonium arsenate changing from D to D/P [21].
  • 2026, second update: the "September 2026 GADSL Update" covered substances whose GADSL classification will change, including several perfluorooctyl sulphonyl derivatives [22][23]. The current Reference List is this September 2026 version [5].
  • Knock-on updates to the ACEA reference lists on IMDS: after each GADSL update, ACEA issues a revised version of its REACH, POP and PIC reference lists:
    • version 4.2, "Post 2026 GADSL Update", dated 2026-04-17;
    • version 4.5, "Post 2026 GADSL September update", dated 2026-09-11 [13].
  • Earlier example: in 2012, IMDS also brought in GADSL changes twice: on 28 June 2012 and in a 14 September 2012 update [24].

What this means for you: expect up to two GADSL revisions a year. Each one changes the D and P flags on basic substances in IMDS, and existing material data sheets (MDSs) may need updating. That applies in particular where a substance you marked "Confidential" is newly added to GADSL: you must update the material in IMDS and send the updated information to your customers, or the material gets an error flag [4].

Approach: I searched the GADSL Reference List and the public IMDS guidance: the VDA 232-101 preface, IMDS newsletters and user tips, the GADSL update notices, and the ACEA reference lists. The change-management rule I found is in the 2005 VDA edition. I did not find a newer published rule that formally sets a twice-yearly schedule.

Q.04