Already back in September 2019, the IMDS Steering Committee has decided to deactivate Rec019. Now, what are the implications for your company?

Suppliers of electronic components will probably have to submit a full material declaration (FMD). Even though there is no timetable set for the deactivation yet, it will be best if your start preparing now.

We would advise to start checking your own material data as soon as possible. This is the only way you can safely document the material composition of your products.
Of course we would also be happy to advise and support you in this process. Just contact us if you need help.

Our training "Electrical/Electronic Components" (No. 6173) will show you what requirements you need to consider given the current changes and how to apply the rules and guidelines for the creation of correct material data sheets in IMDS.

Some addional information on the background:

Many electronics suppliers are not automotive suppliers originally, hence they are not used to working with IMDS. It is for this purpose, that the IMDS Steering Committee has developed the Rec019 in 2003. It allowed IMDS users to use standard modules. These modules were made available by the ZVEI a few years later as semi-finished products with solid materials. Nevertheless, companies in the supply chain, and electronics companies, were required to obtain the necessary information on ingredients and materials from their suppliers. And this not only when there were indications that the electronic component contained substances on the Global Automotive Declarable Substance List (GADSL) that are not included in the REC 019 semi-finished product modules. Information had to and still must be provided at all times. This is stated in section 3.1 of Rec001:

In general, all components and materials being used throughout the supply chain must be disclosed. Upon special request by the customer, the supplier utilizing the IMDS reporting has to prove per evidence that he has collected all material data from its sub-tier levels.

However, during the review, the Steering Committee has determined that the REC019 semi-finished product modules cannot be used for REACH and ELV compliance. Hence the decision to deactivate Rec019 and to comply with the requirement of Rec001 to disclose all material data from its sub-tier levels throughout the entire automotive supply chain.

In our IMDS Information Portal you will find a presentation from our IMDS user meeting in October 2019 that covers this important topic.