Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs.

T

tekno9000

#1
Systems are about standardizing different customer requests. So why am I (and I am sure there are many people like me) getting requests from different customers for IMDS, RoHS, REACH-SVHC, Material composition declaration certs. etc?

Isn’t the intent of all these the same? Can someone please clarify the difference between all these requirements?

Do these substitutes each other?

I went though lots of individual threads on this subject matter. I am planning to make an excel sheet which will include all the requirements / differences of each for a quick reference (after I am done with submitting to my customer what he requires)

Thanks.

Dazed and Confused.
 
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andka907

Involved In Discussions
#2
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

REACH and End of life vehicle is a EU directive and have different purposes but at the same time almost the same.

REACH is not only for automotive companies - it is regarding all chemicals.
(Also a reporting system for EU in Helsinki if you import substances, very brief, it is alot of pages to read to understand)
ELV is more about the recycling of the cars (different type of vehicles, some type not included yet but prob will be - i.e phase out Cr6, lead - that's why automotive req you to report to IMDS)
RoHS - i am not so familar but I think it is toward electronics - substances in flame retardents, led also related to recycling etc

IMDS is a system to report the material used towards someone and there you can check whether it is OK/NOK or to use.

That is the difference
Please someone correct me if I am wrong.

But I agree, too many systems too many regulations making the world more complex than it has to - alot of waste in the supply chain - and many customers are talking about lean...
Some small companies will face extinction in Europe due to this REACH...
 

Kales Veggie

People: The Vital Few
#3
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

Systems are about standardizing different customer requests. So why am I (and I am sure there are many people like me) getting requests from different customers for IMDS, RoHS, REACH-SVHC, Material composition declaration certs. etc?

Isn’t the intent of all these the same? Can someone please clarify the difference between all these requirements?

Do these substitutes each other?

I went though lots of individual threads on this subject matter. I am planning to make an excel sheet which will include all the requirements / differences of each for a quick reference (after I am done with submitting to my customer what he requires)

Thanks.

Dazed and Confused.
Yes, it is confusing and it will not get any better in the near future.

Substitutes, not really.

From one perspective, REACh and ELV are opposites.

ELV lists the substances (6 basic and several 1000s derived) that have restrictions and applies to cars only. RoHS is similar to ELV, but then applied to electronics and electrical equipment.

REACh applies to all substances (except substances that are regulated by other regulation such as drugs and nuclear) and manufacturers and importers have to register these substances and have to proof that they are save. Words commonly used with REACh are SVHCs, Articles, Preparations and Substances.

In short: ELV and RoHS ban certain substances. REACh bans everything unless it is proven safe. All three of them are European regulations, but have a world wide following. It will effect the way you do business.

IMDS is an internet database used by the automotive industry to declare all substances in a vehicle to identify restricted substances from ELV and REACh.

Besides ELV, REACh and RoHS, there are many other under development and under implementation, such as California Green Chemistry, Canadian Challenge List, GHS, Chemical Branding, TSCA rewrite.

It is imperative for global companies that they know what substances they have in their product, so that they can respond to the different regulation in a quick and confident manner. (in short: No Market, No Data)

Many of these regulations include fines and sometimes jail time. Not to mention to loss of a companies image when violations become public. (and they will !)

So, if you receive one of those letters or some one requests that your document compliance, be very careful with what you sign. Your companies upper management have to know about it and some one with authority must sign this letter (if requested). More than likely by signing, your company is binding itself legally.

One last thing, if you buy parts / components from suppliers, your suppliers also have to be compliant with whatever your customer requires. It is imperative that your company sets up a process / system to manage all these requirements and cascades it to your supply base. (For many of these regulations, "I did not know" is not a valid defense in a court room or in front of a TV camera).
 
Last edited:

antoine.dias

Quite Involved in Discussions
#4
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

I second that completely except it is :
No data, no market.

If it is no market,........you don't need any data either :lmao:

Best regards and thank you,

Antoine
 
J

Jonazzz

#5
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

I think that the post from "Kales Veggie" is quite complete.

I would just add one major difference between the different directives(RoHS, ELV,...) and the legislation that REACH is.

Within REACH, the producer of the "Article" has the duty to inform the next player in the supplychain when a substance from the "Candidate List" is present in this "Article" whenever the threshold of 0,1% vs the total weight of the "Article" is tripped.

The other directives like RoHS and ELV do put information obligations on the producers, but only appraoch the "phase-out-of-substance" perspective.
RoHS and ELV do not force industry to have supplychain communication. It is more like a "pull" flow. In other words, most of the time the OEM will ask questions to Tier I, who in turn will forward this requirement to the Tier II and so on.

For REACH, I would dare to say, the aim would be to install a "push" flow of information. In other words, the communication starts with the first actor in the supplychain (the raw material manufacturer) and goes up-stream to the customer (OEM).

IMDS would be a "tool" that could be used for this kind of supplychain communication (well at least within the automotive industry).

But as stated before, REACH is a few 1.000 pages of legislation.

Lets see where we get.
 

Kales Veggie

People: The Vital Few
#6
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

I think that the post from "Kales Veggie" is quite complete.

I would just add one major difference between the different directives(RoHS, ELV,...) and the legislation that REACH is.

Within REACH, the producer of the "Article" has the duty to inform the next player in the supplychain when a substance from the "Candidate List" is present in this "Article" whenever the threshold of 0,1% vs the total weight of the "Article" is tripped.

The other directives like RoHS and ELV do put information obligations on the producers, but only appraoch the "phase-out-of-substance" perspective.
RoHS and ELV do not force industry to have supplychain communication. It is more like a "pull" flow. In other words, most of the time the OEM will ask questions to Tier I, who in turn will forward this requirement to the Tier II and so on.

For REACH, I would dare to say, the aim would be to install a "push" flow of information. In other words, the communication starts with the first actor in the supplychain (the raw material manufacturer) and goes up-stream to the customer (OEM).

IMDS would be a "tool" that could be used for this kind of supplychain communication (well at least within the automotive industry).

But as stated before, REACH is a few 1.000 pages of legislation.

Lets see where we get.
Correct.

Producers that must comply with RoHS and ELV have pushed the requirements down the supply chain (as they should !)

REACh requires raw material manufacturers to register their substances.

All cases, it relies on the supply chain to get accurate information to the top of the chain (either manufacturer or importer). Now this raises an interesting question on how well the supply chain is aware of these regulations and their understanding (and their liabilities).

In general, the automotive industry has done a very good job including the supply chain in these efforts.
 

andka907

Involved In Discussions
#7
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

No question about it, what you have stated

The problem is political and cost issue. Don't just read the paragraphs "because it is the law", think about the consequences and discuss it.
You might end up where the legal requirements will adhere to eachother with one directive instead of several - if you say something.

But on the other hand...all these demands and laws, it creates a lot of work opportunities - and limiting the free trade. As I said many micro and small companies will face extinction.

Hmmm it remind me of the old soviet union...

Out of the context:
It also remind me from a phrase from HBR - today's automotive makers are like Dinosaurs - large, slow and facing extinction...
 
J

Jonazzz

#8
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

Originally posted by andka907

No question about it, what you have stated

The problem is political and cost issue. Don't just read the paragraphs "because it is the law", think about the consequences and discuss it.
You might end up where the legal requirements will adhere to eachother with one directive instead of several - if you say something.

But on the other hand...all these demands and laws, it creates a lot of work opportunities - and limiting the free trade. As I said many micro and small companies will face extinction.

Hmmm it remind me of the old soviet union...

Out of the context:
It also remind me from a phrase from HBR - today's automotive makers are like Dinosaurs - large, slow and facing extinction...
I can agree with the fact that requirements, demands and laws are creating a lot of work and also could involve costs.

But isn't it all about (without being the "Green-Guy") protecting our environment for the next generations of human kind and actually gaining knowledge on what we put into our products we market?

I do agree that a lot of damage is already done, and also that a lot of companies have found a "work-around" these legislations, for example exporting their waste to third world countries, where "god-knows-how-and-where" this waste is treated,..., but these laws and directives are actually trying to get a stop to these processes (or least limit them).

A limit on free trade, maybe yes, maybe no.
On the other hand, if we want to keep importing stuff from LCC's containing chemicals that are banned since ages because we finally understood the harm they are doing..., let's be honest that is only in the advantage of us all.

A few months ago, somebody told me :"I'm wondering how my grand childeren will try to build cars from water and air, because that will be the only not restricted substances.".

Nevertheless if we at least make efforts to live up to the "philosophy" of the legislation and directives, our grand childeren might still be able to try to build cars.

I don't think anyone would like to be "holier than the pope" :) but limiting it to "cost and resources" would be a bit short.
 

Kales Veggie

People: The Vital Few
#9
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

I would look at the past at all the chemicals that were the latest and greatest and were going to solve many problems and worked so well:

- asbestos
- DDT
- PCBs
- Lead

Now, we have come to realize that these are not so good for us and environment.

That is why REACh is turning the table. Proof it is safe before you can use it.

REACh and REACh like regulation will not go away, but will increase. REACh is not easy to implement. The jury is still out on how it all is going to work (include ECHA's role and its efficiency)

In general, we ought to be good stewards of the earth and the world around us. Understanding the impact of chemicals we use is an important part of that stewardship.
 

andka907

Involved In Discussions
#10
Re: Difference between IMDS, RoHS, REACH-SVHC, Material composition declaration certs

First - thanks for a good discussion!

I agree that we have to keep the environment "clean" and of course there should be regulations of what chemicals that are approved and not approved. I love that I can drink clear water direct from a well.

The DDT comparsion is a superb comparsion...REACH is for EU (correct me if I am wrong), the DDT ban was or became an international agreement (more or less). The Climate conference, latest in Copenhagen, became the opposite of the DDT agreement with almost no demands.
So if it is world wide then there is no free trade issue.

By the way, here we are supplying to the industry, where the end product consumes non-reusable resources and emitting CO2 (oil-petrol-vehicles) and talking about a better environment. I like the business and wants to stay there, but just think about it...

So are we good stewards? I eat meat, drive my car, travel with a airplane to Egypt on holiday, work for a supplier to the automotive industry, buy imported products from China - calculate the CO2 emissions that I am responsible for - so I am obviously not a good steward...are any of you?

(Lead is still ok to use in certain amount and for some application but I guees you know that.)

Yes I agree that it has made a huge difference on environment.

Before REACH there were regulations, I don't know how in-/effective they were? Please tell me Kales if you know.

I know this for sure: The more complex a system becomes, the higher risk for errors and misinterpretations.

By the way, how many are performing a MET matrix or type of LCA?

Thanks again. I am learning by discussion and I can change my mind when someone comes with good opinions.
 
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