Tier 2 supplier can't/ wont submit IMDS

[anneliesehuss]

My company is in truck industry(cemi) and our customers are just now starting to hop on board with common automotive regulations, such as IMDS and my company is just now getting into it. And as quality manager, I have reached out to our suppliers to request their IMDS submission.

We have a tier 2 supplier (distributor) that "supplies" a component for our assembly process. However, the component is no longer being manufactured or purchased. (We must have bought a lifetime supply). However I still need to submit my IMDS and include the component.

The supplier(distributor) states that because the component is no longer manufactured, there is no one who can or has the information to submit IMDS, and the only way to do so is to have the component remanufactured.

It is being requested that I just make the IMDS myself out of the base material. My question is... is that legal? If we don't manufacture a product can we (legally) submit it to IMDS? Seems like maybe not? I cannot find anything outright stating it's illegal.

 

[IMDSDATA]

My company is in truck industry(cemi) and our customers are just now starting to hop on board with common automotive regulations, such as IMDS and my company is just now getting into it. And as quality manager, I have reached out to our suppliers to request their IMDS submission.

We have a tier 2 supplier (distributor) that "supplies" a component for our assembly process. However, the component is no longer being manufactured or purchased. (We must have bought a lifetime supply). However I still need to submit my IMDS and include the component.

The supplier(distributor) states that because the component is no longer manufactured, there is no one who can or has the information to submit IMDS, and the only way to do so is to have the component remanufactured.

It is being requested that I just make the IMDS myself out of the base material. My question is... is that legal? If we don't manufacture a product can we (legally) submit it to IMDS? Seems like maybe not? I cannot find anything outright stating it's illegal.

Legal is a complex answer

It is contrary to what your company agreed to when you signed up to use the IMDS - see TOS

Also since you likely do a PPAP - it may be contrary to what you promise on a PPAP

 

[Golfman25]

Your suppler is under no obligation to submit something for an obsolete part. Similar to what would happen if the supplier was out of business. I don’t see any reason you can’t submit the IMDS as part of your submission. If you know the raw material and the weight you should be ok.

 

[leftoverture]

I agree if you have the material composition data, you can submit it yourself (but be sure you have accurate data to support your submission). Similar situations have come up for my company, not for IMDS but for other regulations, and I have told my customer the "product is obsolete so information is not available" and, if they would like, we can "UAI or quote a replacement" that meets their (new) requirement. In many cases we have inventory agreements in place so they are responsible for paying to scrap the now obsolete material if they choose not to use it. In all but one case, they have chosen to UAI. Kind of funny how financial obligations can change the tune.

 

[Ron Rompen]

I agree with Golfman. Essentially, in the IMDS submissions you are disclosing what materials/chemicals are in the product you are supplying.

In the past I have had to create IMDS reports for products which were supplied to me, but which the supplier was unable (or unwilling) to submit IMDS information. I queried my instructors about this (cant recall who it was, this was a loooooong time ago) and they informed me that there was no issue with me doing this, as I was providing information on a product which -=I=- supplied.