The International Material Data System (IMDS) has long been a cornerstone of materials compliance in the automotive industry. It provides a reliable framework for suppliers and manufacturers to report substances in vehicle components, supporting compliance with directives such as the EU End-of-Life Vehicles (ELV) directive and alignment with the Global Automotive Declarable Substance List (GADSL).
As sustainability expectations and substance regulations expand across sectors and jurisdictions, companies increasingly find that certain compliance and reporting requirements go beyond the scope of traditional IMDS submissions. In these cases, collecting Full Material Disclosure (FMD), the practice of capturing complete substance-level data for a product, can help bridge critical data gaps and ensure readiness for evolving demands.
IMDS: A Proven System for Automotive Compliance
IMDS was developed to streamline the exchange of material information between suppliers and original equipment manufacturers (OEMs) in the automotive sector. It enables:
- Standardized, hierarchical reporting of materials and substances
- Compliance with automotive-specific substance restrictions and declarations
- Structured data entry aligned with component-level design and sourcing
IMDS remains essential for meeting core regulatory requirements and is a shared language across the automotive supply chain. However, as regulatory scopes widen and environmental transparency becomes a cross-sector expectation, companies may need additional data collection practices to complement what IMDS currently captures.
What Is Full Material Disclosure and Why Is It Essential?
Full Material Disclosure (FMD) refers to the practice of reporting all known substances in a material or product—often down to a threshold of 100 parts per million (ppm). Unlike compliance declarations that indicate the presence or absence of known restricted substances, FMD offers a comprehensive substance inventory, enabling companies to evaluate products against:
- Current and future regulatory lists
- Internal sustainability targets
- Circularity or eco-design principles
FMD is not a system or software; it’s a data approach that expands transparency and allows companies to be proactive in managing material-related risks and opportunities.
When IMDS Isn’t Enough: Scenarios That Require Full Material Disclosure
There is no one-size-fits-all answer to when FMD should be pursued. In many cases, IMDS provides sufficient information to meet regulatory requirements. But the need for FMD often arises in the following scenarios:
Compliance with Emerging or Non-Automotive Regulations
While IMDS supports automotive-focused regulations, other laws may require different or more granular data. Examples include:
- EU REACH Candidate List and SCIP database: Requires identifying and reporting substances of very high concern (SVHCs) at the article level, even when not covered under ELV or GADSL.
- PFAS restrictions in U.S. states: Some jurisdictions mandate disclosure or phase-out of PFAS (per- and polyfluoroalkyl substances), which may not be fully tracked in standard IMDS submissions.
- California Proposition 65: Requires businesses to disclose exposure to listed chemicals in consumer products, many of which may fall outside the scope of automotive-focused declarations.
Cross-Sector or Multi-Industry Product Use
Components used in multiple sectors (e.g., electronics, medical devices, or consumer products) may face additional compliance obligations, such as:
- RoHS and WEEE for electrical and electronic equipment in the EU
- Packaging directives requiring heavy metal content disclosure
- Green building certifications with material transparency criteria (e.g., LEED, WELL)
Sustainability and Circularity Goals
Companies pursuing environmental targets often rely on full material visibility to assess:
- Recyclability and reuse potential
- Lifecycle impacts and embodied carbon
- Substitution opportunities for hazardous substances
FMD supports these efforts by enabling early and informed design decisions.
How to Collect and Manage Full Material Disclosure Data
Adding FMD to existing compliance workflows doesn’t mean replacing IMDS; it means layering additional detail where needed. Here’s how companies are approaching it:
Conduct a Regulatory and Customer Landscape Review
Identify which compliance frameworks and client expectations apply beyond automotive regulations. Determine where current IMDS submissions provide sufficient data and where they don’t.
Prioritize Products and Suppliers Strategically
Focus FMD collection efforts on components or materials most likely to contain substances of concern or those with high exposure to evolving regulations.
Collaborate with Suppliers
When requesting FMD, clearly communicate why full disclosure is needed and how the data will be used. Consider providing standardized templates or examples as they can improve response quality.
Centralize and Harmonize Material Data
Use tools that can store and manage both IMDS and FMD data types. While IMDS is used for submissions, many companies maintain internal systems to house full substance inventories for broader reporting needs.
Monitor and Maintain Data Over Time
As substance lists change and regulations evolve, material data should be reviewed periodically to ensure ongoing compliance and transparency.
Bridging Compliance and Sustainability with Better Data
IMDS remains a vital part of the compliance landscape, especially in the automotive industry. However, as regulations grow more diverse and sustainability goals become more ambitious, companies are finding that additional material data, collected through full material disclosure practices, provides the flexibility and foresight needed to stay ahead.
By strategically supplementing IMDS with substance-level data, organizations can:
- Proactively address new regulatory requirements
- Reduce future compliance risk
- Support product circularity and design innovation
- Consider greater sustainability targets
- Strengthen supplier engagement and transparency
In Summary
Full material disclosure doesn’t replace IMDS; it complements it. Together, they provide a more complete foundation for responsible material management in a changing regulatory and environmental landscape.
Tetra Tech has extensive experience with IMDS reporting and full material disclosure practices and can support your team whether you’re responding to new regulatory requirements, improving supplier engagement, or exploring deeper sustainability insights. Click below or contact us today at [email protected].
