IMDS Compliance for Automotive Manufacturers: Requirements, Reporting & Material Data Management

IMDS compliance requires more than submitting material data. Automotive manufacturers and suppliers need accurate Material Data Sheets (MDS), correct substance and material information, GADSL checks, OEM-specific requirements, validation, submission, approval and ongoing change management.

The International Material Data System (IMDS) is the automotive industry's central platform for exchanging material and substance information across the supply chain. But managing IMDS effectively means controlling the data behind each submission—not simply entering information into the system.

This guide explains how IMDS compliance works, what data needs to be managed, where submissions commonly fail, and how automotive compliance teams can build a more controlled workflow.

What is IMDS?

IMDS is a global automotive material data system used by manufacturers and suppliers to exchange information about the materials and substances contained in vehicle components.

The data supports activities including:

• Material and substance reporting
• Regulatory and restricted-substance checks
• GADSL declarations
• End-of-life vehicle requirements
• Customer and OEM requirements
• Material compliance assessments
• Recycling and circularity reporting
• Product carbon footprint and related sustainability data

IMDS should therefore be treated as part of the broader automotive product compliance process, rather than as an isolated reporting system.

For broader context, see our automotive compliance overview.

What information is contained in an IMDS submission?

An IMDS submission is built around a Material Data Sheet (MDS).

Depending on the component and material structure, the MDS can contain information such as:

• Components and subcomponents
• Materials
• Basic substances
• Substance percentages
• Material classifications
• Material weights
• Recycled or recyclate information
• Regulatory information
• GADSL-related substance declarations
• Supplier and recipient information

The structure matters because automotive manufacturers ultimately need to understand what substances are present, where they are present, and at what level.

Incorrect material structures or incomplete substance information can therefore create problems even when an MDS has technically been submitted.

How does the IMDS compliance workflow work?

A typical IMDS process looks like this:

Supplier data → Material information → MDS creation → Validation → Regulatory checks → OEM requirements → Submission → Approval → Change monitoring

Each stage can introduce risk.

1. Collect supplier material data

The quality of the final IMDS submission depends heavily on the quality of upstream supplier information.

Incomplete declarations, inconsistent weights, missing substances or incorrect material structures can create rework later in the process.

This is particularly important when compliance teams manage multiple tiers of suppliers.

2. Build the MDS

The supplier creates the appropriate Material Data Sheet using the required component, material and substance structure.

The data needs to represent the actual material composition and follow applicable IMDS recommendations and customer requirements.

3. Validate the data

Validation should happen before submission—not only after an OEM rejects the MDS.

Typical checks include:

• Missing material information
• Incorrect material structures
• Weight inconsistencies
• Substance declaration problems
• GADSL issues
• Regulatory information
• Required fields
• Customer-specific requirements

For a deeper look at common failure points, see IMDS data quality problems in automotive material declarations.

4. Apply regulatory and customer requirements

IMDS data does not exist independently of the regulatory environment.

Compliance teams may need to consider GADSL, REACH-related information, ELV requirements, customer-specific requirements and other applicable rules.

GADSL is particularly important because its classifications and reporting thresholds influence how substances are handled in automotive material declarations.

However, a reporting threshold should not automatically be interpreted as a permitted-use limit. Automotive companies also need to consider applicable legislation and OEM requirements.

5. Submit to the correct recipient

The MDS is then submitted through IMDS to the relevant customer or OEM.

Submission requirements can differ by customer. Automotive suppliers therefore need to manage recipient-specific expectations rather than assuming that one submission approach works for every OEM.

6. Manage approval and corrections

A rejected or returned MDS requires investigation, correction and resubmission.

This is where data traceability becomes important.

Teams need to know:

• What was rejected?
• Why was it rejected?
• Who needs to correct the data?
• What changed?
• Was the corrected MDS resubmitted?
• Was it ultimately accepted?

Without a controlled workflow, these activities often move into spreadsheets, email chains and manual follow-ups.

IMDS reporting and submission

IMDS reporting is not simply a matter of completing an MDS and pressing submit.

Before submission, suppliers should verify:

1. The correct component structure is used.
2. Material weights are accurate.
3. Materials are classified correctly.
4. Basic substances are complete and accurate.
5. Applicable regulatory information is provided.
6. GADSL-related requirements have been addressed.
7. Required recycled-content or recyclate information is available where applicable.
8. Customer-specific requirements have been checked.
9. The MDS has passed internal validation.
10. Supporting evidence can be retrieved if the customer challenges the submission.

This makes pre-submission validation a critical part of the IMDS process.

IMDS data quality: where submissions fail

Common IMDS data-quality problems include:

• Incomplete material disclosure
• Incorrect material structures
• Polymer materials containing incomplete substance information
• Incorrect or missing GADSL declarations
• Weight discrepancies
• Missing recyclate information
• Incorrect use of published materials
• Regulatory information gaps
• Supplier data that does not match the actual product

These issues can result in rejected MDSs, repeated supplier requests and delays to customer approval.

The practical challenge is often not the IMDS interface itself. It is getting accurate, complete and consistent material information from suppliers.

IMDS, GADSL and regulatory information

GADSL—the Global Automotive Declarable Substance List—is an important part of automotive material reporting.

GADSL identifies substances that may require declaration based on automotive industry requirements. Its classifications include categories such as declarable and prohibited/declarable substances.

However, GADSL should not be treated as a replacement for regulatory assessment.

Automotive compliance teams may need to evaluate IMDS data against multiple sources, including:

• GADSL
• REACH requirements
• ELV requirements
• ACEA Regulatory List information
• OEM-specific requirements
• Other applicable chemical and product regulations

This is one reason why maintaining material data as a reusable compliance dataset is more valuable than treating every IMDS submission as a one-off exercise.

IMDS and ELV compliance

IMDS data also supports end-of-life vehicle compliance because material and substance information can be used to assess vehicle materials, restricted substances and circularity-related requirements.

The European regulatory framework has also moved beyond the original ELV Directive. Regulation (EU) 2026/1738 was adopted in July 2026 and establishes new circularity requirements for vehicle design and end-of-life vehicle management, repealing Directives 2000/53/EC and 2005/64/EC.

This makes the connection between material data, IMDS and ELV/circularity requirements increasingly important.

See our existing guide on IMDS, ELV and circular economy compliance.

IMDS recommendations and system updates

IMDS requirements evolve.

The system has moved through multiple releases, including IMDS 15.2, 15.3 and 15.3.1. Release 15.3 introduced changes including additional chemical-presence analysis options, expanded tree functionality, request IDs in MDS request inbox/outbox, weekly emails for unnoticed requests and updated validation checks. Release 15.3.1 subsequently changed the treatment of the “rest” portion for main constituents in metals.

IMDS recommendations also change. In 2026, IMDS Recommendation 001 was updated and Recommendation 026 on Regulatory Information became valid.

For automotive teams, this means IMDS compliance cannot be treated as a static procedure.

The process needs to account for:

Release changes → recommendation changes → regulatory changes → affected data → supplier action → validation → resubmission

Our existing IMDS Recommendation 019 guide provides a deeper look at recommendation-specific requirements.

IMDS and product carbon footprint

IMDS is also expanding beyond traditional material compliance data.

Product carbon footprint information has become part of the evolving IMDS ecosystem. IMDS announced an update to Recommendation 027 for Product Carbon Footprint in June 2026.

This creates a broader opportunity for companies to connect:

Material composition → regulatory compliance → environmental data → lifecycle information

That same material dataset can also support wider product-information requirements.

For example, see our DPP and FMD compliance guide.

IMDS and Full Material Disclosure

IMDS and Full Material Disclosure (FMD) are related, but they should not be treated as identical concepts.

FMD provides detailed information about product and material composition, while IMDS is the automotive industry's system for exchanging structured material information.

FMD can therefore act as an important upstream data source for automotive material compliance workflows.

See our FMD full material disclosure guide and our resources on IPC-1752A material disclosure and IPC-1754 material disclosure.

For supplier-facing workflows, our guide on getting FMD data without repeatedly chasing suppliers covers the data-collection problem upstream of compliance assessment.

Managing IMDS data across the product lifecycle

IMDS compliance does not end when an MDS is accepted.

Material information can change because of:

• Supplier changes
• Material substitutions
• Manufacturing changes
• Regulatory updates
• GADSL changes
• OEM requirements
• Product revisions
• New substance restrictions
• Changes to recyclate or sustainability requirements

A controlled process should therefore connect material changes to compliance impact.

When a material changes, teams should be able to determine:

Which products are affected? Which suppliers need to respond? Which MDSs need to be reviewed? Which regulatory checks need to be repeated? Does a new submission need to be made?

This is where IMDS management moves from document administration into ongoing product compliance management.

What can be automated in IMDS compliance?

The repetitive parts of the process are strong candidates for automation.

Depending on the organization's workflow, automation can support:

• Supplier data collection
• Supplier reminders and follow-ups
• MDS ingestion
• Data-quality checks
• GADSL validation
• Material and substance mapping
• BOM-level checks
• Expiry and renewal tracking
• Approval workflows
• Change monitoring
• Compliance status updates
• OEM-ready reporting
• Audit evidence

The objective is not to automate regulatory judgment.

The objective is to reduce manual work around collecting, validating, routing and maintaining compliance data so specialists can focus on exceptions and decisions.

Regilient's IMDS/ELV compliance software is designed around this workflow, including IMDS/CAMDS data handling, GADSL validation, supplier engagement, BOM checks and compliance reporting.

IMDS compliance checklist

Before considering an IMDS workflow complete, automotive compliance teams should be able to answer:

• Do we have complete material composition data?
• Is the MDS structure correct?
• Are material and component weights consistent?
• Are basic substances correctly declared?
• Have GADSL requirements been checked?
• Have regulatory requirements been assessed?
• Have OEM-specific requirements been checked?
• Has the MDS been validated before submission?
• Can we track rejected and corrected submissions?
• Can we identify affected products when material data changes?
• Can we demonstrate the evidence behind a compliance decision?
• Can suppliers be followed up systematically?
• Can compliance teams monitor changes after approval?

If several of these activities still depend on spreadsheets and email, the underlying IMDS process is likely creating unnecessary operational risk.

IMDS compliance is a data-management problem

The biggest IMDS challenge for many automotive organizations is not creating an MDS.

It is maintaining accurate, structured and traceable material data across suppliers, products, regulations and customer requirements.

The strongest IMDS workflows therefore connect:

Supplier data → FMD/material information → MDS → validation → GADSL/regulatory checks → OEM requirements → submission → approval → change management

That creates a reusable compliance data layer rather than a collection of isolated submissions.

For organizations managing large supplier networks and complex BOMs, this approach can reduce manual follow-up, improve data quality and provide a more reliable audit trail.

Explore more IMDS resources

Explore the Regilient IMDS topic hub for additional resources on automotive material data, IMDS, ELV and related compliance requirements.