Question 1:

We are to create an IMDS entry with different materials for our customer. We get these materials from our sub-suppliers and then combine them into a complete IMDS entry.

Now we have an adhesive in use, which burns completely at about 150 degrees and is no longer present afterwards (adhesive is only used to fix two other materials). The component where the adhesive is used reaches a temperature of far more than 600 degrees.

My question is: Should the adhesive be included in the IMDS or not?

Answer:

In our opinion, the adhesive does not need to be shown. Here you can apply rule 4.4.1.C from Rec001. The adhesive, which apparently disappears completely during production, would then be treated as a process chemical. It should not be reported:

Rule 4.4.1.C: Process chemicals used in the production of a material/part that are not contained in the end material/part must not be reported.

Question 2:

Is IMDS applicable for two and three-wheeler vehicles? If yes, where can I find information?

Answer:

The End-of-Life Vehicles Directive (ELV) applies to vehicles of categories M1 and N1 Here to read up:

https://en.wikipedia.org/wiki/Car_classification

Independently of that IMDS is included in the purchasing conditions of many OEMs. Therefore, the supplier has no other possibility than to fulfil the IMDS obligations. BMW, for example, has been doing this for a very long time and also requires entries in the IMDS for ‘two-wheelers’.

Question 3:

Concerning the SCIP database, what does the date in January 2021 mean? Must products that are newly launched on the market be listed in the database before market entry? What about products that are already on the market: Do they have to be included in the database on that date or should they be entered from then on?

Answer:

All products supplied, whether they have been on the market for five years or on 5 January 2021 for the first time, must be registered in the SCIP database (if an SVHC greater than 0.1% w/w, taking o5a into account, is present).

According to ECHA:

The notification obligation for affected products will come into force on 5 January 2021. When the notification obligation comes into force, a notification must be available in the SCIP database for all products on the market on that date.