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Is IMDS required for Shipping cap received from our suppliers

R

ram4302

#1
Hi all,

I have one doubt Whether IMDS is required for Shipping cap and desiccant received from our suppliers? We are going to ship the parts to OEM which they will remove and won't be used in Cars.

ISO/TS 16949:2009 states the following requirement about IMDS

7.4.1.1 Statutory and regulatory conformity
All purchased products or materials used in product shall conform to applicable statutory and regulatory
requirements.

Please give your feedback

:thanx:
 
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Kales Veggie

People: The Vital Few
#2
Re: Whether IMDS is required for Shipping cap received from our suppliers

Correct. ELV (the main regulation driving IMDS) is concerned about what at the end of the vehicle life is turned into salvage. Items removed during assembly are not declared in IMDS. This would also include protective film that is removed by the consumer.

(exemption is that if you ship this part as a spare part to the EU, and you are required to submit the info into IMDS then you have to comply with REACH and then the cap / desiccant / packaging materials must be declared.
 
R

ram4302

#3
Re: Whether IMDS is required for Shipping cap received from our suppliers

Thank you for your reply.My view is We as a Tier 1 requires IMDS from our supplier who are supplying Shipping cap and desiccant.
In OEM perspective IMDS is not required for the items which are not going to be used in the end item.TS requirement states as "All purchased products or materials used in product shall conform to applicable statutory and regulatory requirements"

Is my View is correct? Please clarify
 

Kales Veggie

People: The Vital Few
#4
Re: Whether IMDS is required for Shipping cap received from our suppliers

Thank you for your reply.My view is We as a Tier 1 requires IMDS from our supplier who are supplying Shipping cap and desiccant.
In OEM perspective IMDS is not required for the items which are not going to be used in the end item.TS requirement states as "All purchased products or materials used in product shall conform to applicable statutory and regulatory requirements"

Is my View is correct? Please clarify
TS says "used in product". A shipping cap is not not used product. Desiccant is not used in product.

Once the cap / desiccant is include in the MDS, it cannot be removed by downstream IMDS users.

So, I would not include these. I have rejected MDS for that reason and I have created MDS, leaving out caps (e.g. Turbo Chargers, protective caps on fittings)
 
T

TShepherd

#5
Thanks Kees,

:thanx:

Your response for the cap that is not being used in the end product was right on target - going through that as we speak with a customer.

Also wondering about Service parts that are beyond 10 years old - one of our OEMs is requesting (demanding) that we submit IMDS for service parts that were already shipped out to the customer as much 17 years ago, which is a little unreasonable I think.

We are handling that request (demand) by telling them that when Service Parts are ordered we can and will submit IMDS because our suppliers can't go back and get the information to provide a submission to us - but will submit to us when material is ordered.

Tom
 

Kales Veggie

People: The Vital Few
#6
Thanks Kees,

:thanx:

Your response for the cap that is not being used in the end product was right on target - going through that as we speak with a customer.

Also wondering about Service parts that are beyond 10 years old - one of our OEMs is requesting (demanding) that we submit IMDS for service parts that were already shipped out to the customer as much 17 years ago, which is a little unreasonable I think.

We are handling that request (demand) by telling them that when Service Parts are ordered we can and will submit IMDS because our suppliers can't go back and get the information to provide a submission to us - but will submit to us when material is ordered.

Tom
That is a general industry problem that is very hard to deal with. (last time buy long time ago, suppliers out of business, etc.)
 

TPMB4

Quite Involved in Discussions
#7
Correct me if I'm wrong but I thought IMDS was created when manufacturers had to work to various end of life legislation. With this in mind I would have thought that any part made before these regulations are outside of their requirement. So if that is correct then surely 17 year old parts, being older than IMDS, could be excused an entry on the IMDS. Anything made or supplied since the introduction of IMDS would most likely had a MDS completed at least by the Tier 1 suppliers I reckon so not an issue.

I can't see how customers can force the issue with parts made prior to legislation but we do sometimes have to dance to their tune so perhaps not. I reckon in our product range we could sort out an MDS for a product of that age but I doubt many auto suppliers could
 

Kales Veggie

People: The Vital Few
#8
Correct me if I'm wrong but I thought IMDS was created when manufacturers had to work to various end of life legislation. With this in mind I would have thought that any part made before these regulations are outside of their requirement. So if that is correct then surely 17 year old parts, being older than IMDS, could be excused an entry on the IMDS. Anything made or supplied since the introduction of IMDS would most likely had a MDS completed at least by the Tier 1 suppliers I reckon so not an issue.

I can't see how customers can force the issue with parts made prior to legislation but we do sometimes have to dance to their tune so perhaps not. I reckon in our product range we could sort out an MDS for a product of that age but I doubt many auto suppliers could
Yes, ELV requirements are part of the annual type approval / homologation, so parts designed for older vehicles do not have to comply "newer" regulation.

REACh does not have a grandfather clause.
 
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