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Understanding ELV and IMDS Compliance

The document discusses various topics related to ELV Directive and IMDS system: 1. It provides definitions for key terms like ELV, IMDS, application codes, and discusses their importance in complying with the ELV Directive which aims to reduce waste from end-of-life vehicles and protect the environment. 2. It explains IMDS processes like receiving material data from suppliers, analyzing bills of materials, and submitting completed IMDS to customers. Various IMDS functions are also described like send/propose, analysis tools, and confidential substances. 3. Requirements related to ELV like prohibiting heavy metals, polymeric part marking for plastic components over a certain weight, and calculating reuse/recycle

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Anjali Deshpande
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0% found this document useful (0 votes)
92 views7 pages

Understanding ELV and IMDS Compliance

The document discusses various topics related to ELV Directive and IMDS system: 1. It provides definitions for key terms like ELV, IMDS, application codes, and discusses their importance in complying with the ELV Directive which aims to reduce waste from end-of-life vehicles and protect the environment. 2. It explains IMDS processes like receiving material data from suppliers, analyzing bills of materials, and submitting completed IMDS to customers. Various IMDS functions are also described like send/propose, analysis tools, and confidential substances. 3. Requirements related to ELV like prohibiting heavy metals, polymeric part marking for plastic components over a certain weight, and calculating reuse/recycle

Uploaded by

Anjali Deshpande
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Global PCCS Pvt Ltd

1. Tell me about yourself/introduce yourself?


Hi good afternoon. First of all I would like thank you for the opportunity. My name is XXXX, I have
completed by BE/BTech in Mechanical/Chemical engineering. I am from XXXX. My hobbies are playing
Cricket, reading books etc.. And I am quick leaner and adopt to situations.

2. What are your daily activities?


Currently I am working as a IMDS engineer & taking care of all IMDS projects.
 Firstly, I receive a request from customer to submit IMDS with Bill of materials.
 I will start with the BOM analysis, first identify in scope & out Scope parts.
 We will remove out scope parts like Service, software, Drawing parts from the study.
 Next, we will identify Buy parts & inhouse parts from in scope parts.
 And then we will contact suppliers for BUY parts if no IMDS through emails.
 Once we get IMDS submission from supplier we will validate and accept the parts if all
criteria meet.
 For non-responding suppliers we will send 3 reminder emails & one phone still no response
means we will escalate to team lead.
 Once we get complete Supplier MDS we will start creating in-house parts & make assembly
and submit to customer.

3. What Is ELV?
ELV is nothing but, End of Life Vehicles
It is a European Directive and came into force in 2002
It is applicable only for Automotive Industries
Main Objectives of ELV
 Prohibition of Heavy Metals
 Disposable System for Future Old Cars
 Follow RRR Calculation (RRR – Reuse Recycle &Recovery)
4. Why ELV Directive Came Into force?
To reduce the Waste generated from the Vehicles after ELV
To Protect the Human & Environment
Prohibition of Hazardous substances

5. What Is the difference between ELV & IMDS?


Well, ELV is nothing, but End of Life Vehicle and it is a directive enforced by European government.
The main objectives of ELV are Prohibit Heavy metals, create system for future old cars & to follow
RRR principle according to ISO22628 and IMDS is nothing, but International Material Data System and
it is a web-based system where we collect, analyse & archive the material data received from
manufactures. And to Comply with ELV directive IMDS system is used as a one of the best solutions.

6. What are the categories of vehicles included in ELV Directive?


There are two types of Vehicles included in ELV directive M1 & N1
M1 means Passenger vehicles less than or equal to 8 seats including driver seats.
Example – Car & Small cabs
N1 means vehicles used for carriage of goods having mass less than or equal to 3.5tones
Example – Pick-up trucks

7. What is Annex II document?


Global PCCS Pvt Ltd
AnnexII is a technical document, which describes about usage of application codes with certain
exemptions. Ex – Lead in Steel 0.35%, Lead Aluminium 0.4% & Lead in Copper 4%.

8. What is application code? And why it is necessary?


These are the Codes which are used to identify the applications.
It is necessary to track the heavy metal usage. (Why? Heavy metals are very hazardous so)

9. What is Send/Propose?
These are the two options used to transfer MDS to Customer.
Send option is used when we are sending MDS to only one recipient
Also, if we send it will go as an editable version, that is 123456/0.01 – ones customer accept the IMDS
version /0,01 will became /1
Propose option is used to transfer MDS to multiple customer/recipient
Also, if we Propose it will go as a full version, that is 123456/1 and we cannot edit same version if
customer rejects.

10. What is Datasheet and Module?


Datasheet is selected when we are sending to Customer. It is for external purpose.
Module is used for internal purpose, where supplier data & recipient tabs will be disabled.

11. What is the difference b/w Joker or wildcards & Confidential substances?
Joker or wildcards are highly confidential substances and only creator of IMDS can see what the exact
substances is used in that.

Confidential substances are nothing but substances which are marked as confidential and only Trust
user or administrator can see the composition. Normal user login cannot view the composition.

Why Jokers or Wild cards or Confidential substances are used?


Because some of the Suppliers don’t want to reveal their secret information to customer. So IMDS
given option to hide up to 10% of company proprietary information.
How Many Joker substances are there?
There are 9 joker or wildcards – Misc Not to declare, further additives not to declare, flame retardant,
inorganic modifier not to declare, not yet specified not to declare etc.
Not yet specified Joker cards can only be used in Prototype IMDS.
Is Joker/wildcards and highly confidential substances are same?
Yes, both are same only.

12. What is the difference b/w Analysis and where used Analysis?
Using analysis function, we can only analyse one MDS with respect to basic substances, Classification,
Application code substances etc.
And Using Where Used analysis we can analyse complete or Multiple MDSs present in the IMDS
database with respect to Basic substances, application code substances, biocidal substances group,
Reach substances group.

13. What is GADSL?


GADSL is nothing but “Global Automotive Declarable Substance List” There are nearly 4300
substances present in the list. This list updates every year February.
There are 3 categories
D- Declarable and these substances appear in Blue Colour in IMDS
Global PCCS Pvt Ltd
P – Prohibited and these substances appear in red colour in IMDS
D/P – Declarable /Prohibited and these substances appear in red colour in IMDS
Based on region wise or application wise some substances are declarable or Prohibited

14. What are types of ELV?


There are two type of ELV. That is Natural ELV & Premature ELV
Natural ELV means vehicles reaches its end of Life by its own
Premature ELV means vehicles reaches its end of Life due to some accidents or performance issue.

15. What is the difference b/w expired & Inactivated application codes?
Expired application codes mean, these are expired but we can use based on the vehicle type approval
date.
Prohibited application codes these are prohibited and should not use. Example – 20 Other
applications

16. What Is IMDS?


IMDS is nothing but International Material Data System. It is a web-based system. IMDS system is
managed or maintained by DXC technology.
In IMDS we collect the Data, analyse the data and archive the data.
IMDS is the Best Solution for ELV directive. How means, ELV Directive main objective is to calculate
the RRR, so to calculate the RRR we need a data and that data we will get from IMDS system.

17. What Is PPAP?


PPAP in nothing but, Production Part Approval Process.

18. What Is Polymeric part marking?


Recycling marking on the Plastic Components or Parts.
Polymeric part marking is required for Classification 5.1, 5.2, 5,3, 5.4 & 5.5.
For classification 5.1x, 5.4x & 5.5x polymeric part marking is required if the weight of component or
part more than 100g and Polymeric marking field should be answered. (No, Yes or Not Applicable)
Option “Not applicable” will be selected in case of not possible to mark because of component shape
or geometry.
For Classification 5.2 & 5.3 polymeric part marking is required if the weight of component or part
more than 200g and Polymeric marking field should be answered.

Why Polymeric part marking is necessary?


To easily identify the plastic parts during the recycling.

19. What are biocides?


a substance that destroys living things, especially a pesticide, fungicide, or herbicide.
Ex – Zinc Oxide, Thiram, Zhiram

20. What are the meanings of the criteria for Process Chemicals?
There are 3 categories,
Intended Use - Indicates that the liquid or gas is still present in the finished part at a significant level
(generally greater than 0.1%).
Reaction Residue - is used if a small amount (generally less than 0.1%) of the chemical is left in the
final part.
Global PCCS Pvt Ltd
Impurity - can occur during the manufacturing of the material or part. These substances are not
intentionally added to the material or part. The concentration in the material is minimal (generally
less than 0.1%).

21. What is Homogeneous material?


Material composition which cannot be separated mechanically into two or more different materials.
"Mechanical separation" here means that it is generally possible to separate materials by means of
cutting, trimming and abrasion. Homogeneous materials are for example plastics,

22. Assume you are manufacturing component and selling within INDIA. Do you need comply with ELV?
And why?
No Need to Comply with ELV. Because ELV is applicable for European region. If we are exporting to
Europe region then we need to comply with ELV directive.

23. If your suppliers asking you to create IMDS on behalf them, will you create MDS for them or not? If
no/yes why?
No, we will not create any supplier IMDS on behalf of them. It is against to IMDS rules.

24. What Is masterbatch structure?


Masterbatch structure will contains material under two materials (one is base material & one more is
colour master batch material.

25. What is the difference between Warnings and Errors?


With Warnings we can submit the IMDS, it is based on the customer requirement, good practise is
clear warnings before sending MDS to customer.

But with error we cannot submit MDS, we must remove all errors before submission.

26. What happens if deleted MDSs/Basic Substances are contained in an MDS?


We will get errors & warnings.

27. What do I have to report in IMDS?


We must report material data composition in IMDS system.

28. What is Weight Deviation?


It is a difference in measured weight & System calculated weight.

29. What are the types of Basic Substances?


There are 3 types of basic substances.
CAS Numbered – Normal Substances having unique CAS numbers – CAS – Chemical Abstract Service
Global PCCS Pvt Ltd
Joker or Wildcards – CAS number will be mentioned as SYSTEM
Pseudo Substances – No CAS numbers because these are mixture of substances, Ex –
PP(Polypropylene)

30. Who create the basic substances?


We don’t have option to create or add Basic substances in IMDS. We have to request to DXC
technology through system itself by using basic substances request function.

31. How many recommendations are there in IMDS and why they are important?
There are 24 recommendations.
001 talks about general rules and guidelines. It gives IMDS creation tips
001a talks about selection of material classifications.
All IMDS recommendations helps to create quality material Data sheet w.r.t all material
classifications.

32. What is RRR target?


85% Recyclable
95% Recoverable

33. How many Material Classifications are there?


There 9 Material Classifications.
1-4 is belongs to Metals and based on Production
5th belongs to Plastics & Polymers based on Properties
6th belongs to Process Polymers based on Applications
7th belongs to Glass & Ceramics based on Production
8th belongs to Electrical & Electronics, and it is deactivated. Because we need to use more specific
classification so.
9th belongs to Fuels & Auxiliary’s - based on Applications

34. How do process Project Request?

 We will receive a Bill of material from Customer


 We must do Bill of Material Analysis

35. Validation Criteria – Assume you are validating a Part in IMDS and what and all you check.
For Nissan:
Part number is correct or not – Correct format is 10 digit alphanumeric
Part Description (Should not contain any copy copy in description)
Supplier Code (It should be 5 digit including prefix N i.e., NA12B)
Preliminary MDS checked or Not
Weight of the Component (Will cross check with internal system)
Drawing information (But not mandatory)
Material Classification
Prohibited Substances
Application Codes (Based on the exemptions & threshold we will confirm)
For application code we will not reject directly, need to check codes & threshold %
Global PCCS Pvt Ltd

For Renault:
Part number is correct or not – Correct format is 10 digit alphanumeric
Part Description (Should not contain any copy copy in description)
Supplier Code (It should be 5 digits including)
Preliminary MDS checked or Not
Weight of the Component (Will cross check with internal system)
Part Index
Standard of Index
Designer Email ID
Drawing information (But not mandatory)
Material Classification
Prohibited Substances
Application Codes (Based on the exemptions & threshold we will confirm)
For application code we will not reject directly, need to check codes & threshold %

36. Tell me about yourself/introduce yourself?


Hi good afternoon. First, I would like to thank you for the opportunity. My name is XXXX, I have
completed by BE/BTech in Mechanical/Chemical engineering. I am from XXXX. My hobbies are playing
Cricket, reading books etc. And I am quick leaner I have been trained on IMDS & SCIP and ready to
join as IMDS Engineer. Thank you.

37. What is SCIP?


SCIP is nothing but Substance of Concern in Products /Articles and established under Waste Frame
Directive
It is a database developed by European Chemical Agency where all manufacturers, suppliers,
importers of Europe should notify their product if they contain any REACh substances /Candidate List
(233 Substances) more than 0.1%.
Why SCIP Database? – Because SCIP database ensure easy recycling and safety of recycling workers.

Who needs to report SCIP information?


Producer, manufacture, Suppliers & Importers of Europe region
What is the software’s used to report SCIP information?
Using I-UCLID & IMDS system we can notify into SCIP database
What Is SVHC?
Substances of Very High Concern - REACh Candidates List – 233 Substances

What is Article?
Article is nothing but defined Object or a Component. Example – Nut, Bolt, Tyre, Engine etc.

How do you report your Product information into SCIP database?


SCIP reporting can be done by using IUCLID or IMDS system.
I will explain by using ICLID software – SCIP reporting required only if SVHC % is more than 0.1% in
article
1. Login to ECHA account and click on ACCESS Cloud Services link
2. Update Legal Entity – (It is a manufacturing Site information)
3. Select Article Creation then create Dataset (Here we will update Article name, Article number,
Article category, Material Category and SVHC substance information)
Global PCCS Pvt Ltd
4. Next, we convert Dataset into Dossier (Dossier means it will convert as a report and cannot edit)
5. At last we will download dossier file in .i6Z format and submit into ECHA Submission portal
6. And we will receive SCIP submission number

38. What is REACh?


REACh is nothing but Registration, Evaluation, Authorisation & Restriction of Chemicals.
It is a European Regulation, and it is applicable to all industries.
What is the criteria for REACh?
If you are manufacturing any chemical or substances more than 1ton per year means you must
register under REACh.
What Is SVHC?
Substance of Very High Concern.
How many substances are present in REACh Candidate List?
There 233 substances are present. Recently this list updated in last month, 8 new substances are
added. This list updates every 6 months once.
What is REACH Authorisation list (Annexure 14)?
REACH includes an authorisation requirement to ensure that the dangers posed by substance of very
high concern (SVHC) are appropriately controlled and that those substances be gradually replaced by
appropriate substitute substances or technology.
What is REACH Restriction list (Annexure 17)?
The REACH Restrictions List, or Annex XVII, helps protect human health and the environment from
chemical dangers by prohibiting the manufacture, use, or placement of certain compounds on the EU
market.

Common questions

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Managing errors and warnings within IMDS submissions is crucial as errors prevent submissions, halting production processes and potentially leading to project delays. Warnings, while not prohibitive, indicate areas of potential improvement and compliance issues that could affect customer acceptance. Effective management ensures operational efficiency, smooth supply chain function, and minimization of compliance risks in the automotive industry .

The SCIP database complements IMDS by ensuring that any products containing REACh candidate list substances above 0.1% are notified, enhancing transparency and safety during recycling. Together, they manage hazardous substances by covering different regulatory grounds; IMDS provides detailed material composition data for manufacturing, whereas SCIP focuses on notification, helping manufacturers maintain compliance with European regulations for hazardous substances .

Validating parts in IMDS for clients involves checking part numbers, descriptions, and codes, ensuring compliance with weight, index standards, and regulatory requirements. These considerations ensure the accuracy, legality, and acceptability of parts, reflecting adherence to each client's specific standards and mitigating risks related to non-compliance, which could impact supply chain integrity and regulatory standing .

IMDS facilitates compliance with the ELV directive by providing a web-based system for collecting, analyzing, and archiving material data from manufacturers, enabling easier adherence to the directive’s requirements. It's important for automotive manufacturers as it helps in maintaining transparency in material composition, ensuring adherence to legal obligations, and helping to meet the RRR targets by providing necessary data to calculate these metrics .

Natural ELVs reach their end of life through regular use over time, whereas Premature ELVs reach end of life due to accidents or performance issues. These differences impact waste management as Premature ELVs might present unexpected challenges regarding the retrieval and processing of recyclable materials, and they might contribute to higher sudden waste outputs, complicating planned waste management strategies .

The ELV directive is significant in the automotive industry as it aims to reduce waste and improve the environmental impact of vehicles at the end of their lifecycle. It prohibits the use of heavy metals and promotes the reuse, recycling, and recovery (RRR) of materials, aligning with environmental protection objectives by minimizing hazardous substances and waste generation .

Automotive manufacturers need to report both IMDS and SCIP information to comply with distinct regulatory requirements: IMDS for detailed material data compliance under ELV directives, and SCIP under the Waste Framework Directive for products containing substances of concern. Non-compliance can result in legal penalties, restrictions on market access, and reputational damage, as these frameworks aim to ensure safety and environmental protection .

'Joker Substances' and 'Confidential Substances' in IMDS allow manufacturers to hide up to 10% of proprietary information by marking certain substances confidential or as jokers. This protection ensures that the exact composition of some substances can be kept secret from customers while still maintaining overall compliance with reporting requirements, thus balancing transparency and intellectual property protection .

Application codes in IMDS are used to identify the use of heavy metals within materials and play a crucial role in tracking and managing the application and exceptions of hazardous materials. This tracking is crucial in compliance with directives like the ELV by ensuring that the use of hazardous materials is tightly controlled and documented, allowing for better regulation and reduced environmental impact .

The GADSL influences automotive production and material selection by categorizing substances into declarable, prohibited, or both, thereby guiding manufacturers in choosing materials that meet regulatory and safety standards. Compliance with GADSL promotes sustainable material usage and helps avoid potential legal and financial consequences arising from the use of dangerous substances .

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