For suppliers in the automotive industry, submitting accurate and compliant data to the International Material Data System (IMDS) is a non-negotiable part of doing business. IMDS helps original equipment manufacturers (OEMs) track material content and ensure vehicles meet environmental regulations such as ELV (End-of-Life Vehicles Directive) and REACH, but understanding common IMDS submission rejection reasons is key to avoiding costly setbacks.
Here are five of the most common reasons OEMs reject IMDS submissions:
1. Incorrect or Incomplete Material Data
What happens:
OEMs often reject submissions when materials are listed incorrectly or not detailed down to the required 100% disclosure level. Every substance in a component must be accounted for, including minor additives and processing aids.
Why it matters:
Regulations like ELV require full material transparency to identify restricted substances such as lead, mercury, cadmium, and hexavalent chromium.
How to avoid it:
- Use standardized material classifications from IMDS’s published lists.
- Ensure every material includes the proper CAS number and weight percentage.
- Validate that the structure is complete, reaching 100% disclosure.
2. Use of Outdated or Prohibited Substances
What happens:
Submissions that include restricted substances, especially if they exceed thresholds or lack exemption codes, are flagged and often rejected outright.
Why it matters:
OEMs must prove regulatory compliance for the entire supply chain. Even small amounts of banned substances can jeopardize a vehicle’s marketability.
How to avoid it:
- Regularly consult the GADSL (Global Automotive Declarable Substance List).
- Monitor updates to regional regulations such as REACH or Proposition 65.
- Apply proper exemption codes with clear justifications, if applicable.
3. Improper Tree Structure or Assembly Hierarchy
What happens:
If your submission doesn’t reflect the actual product’s structure, such as incorrect nesting of parts or materials, OEMs may reject it as misleading or inaccurate.
Why it matters:
A clear, logical tree structure ensures traceability from finished parts to base materials, which is essential for lifecycle analysis and compliance verification.
How to avoid it:
- Build the IMDS tree to mirror the physical product: assemblies > semi-components > materials > substances.
- Use consistent naming conventions and avoid unnecessary levels or placeholders.
- Validate the hierarchy with internal engineering or design teams.
4. Missing or Invalid Supplier Data
What happens:
When a submission includes purchased parts that are not supported by valid MDS (Material Data Sheet) entries from upstream suppliers, the OEM cannot verify the full composition.
Why it matters:
OEMs rely on complete data across the supply chain. Missing data creates compliance blind spots.
How to avoid it:
- Request valid MDS submissions from all tiered suppliers early in the process.
- Avoid using “dummy” data for placeholders—this is a common red flag.
- Track the acceptance status of referenced MDSs within the IMDS system.
5. Failure to Meet OEM-Specific Requirements
What happens:
Each OEM has its own IMDS guidelines, sometimes including unique field entries, material classifications, or specific document attachments. Failing to meet these company-specific rules often leads to rejections.
Why it matters:
OEM-specific requirements ensure consistency within their internal systems and compliance with brand-level sustainability strategies.
How to avoid it:
- Carefully review each OEM’s published IMDS guidelines (available via the IMDS portal or OEM websites).
- Set up internal checklists tailored to major OEMs you supply.
- Stay in contact with the OEM’s IMDS point of contact when clarification is needed.
Summary: Avoiding Rejection Is About Proactive Compliance
Understanding IMDS submission rejection reasons is critical. These rejections are not just technical setbacks; they reflect broader compliance risks and supply chain inefficiencies. By focusing on data accuracy, staying current with regulatory changes, and customizing submissions for each OEM, suppliers can drastically reduce the chances of rejection.
For specialized support, Tetra Tech offers expert-led IMDS training, supplier engagement tools, and hands-on consulting services to help your team meet compliance requirements with confidence.
Contact us at [email protected] to learn how we can support your IMDS program.
