Table of Contents
- What is IMDS data quality?
- Why do automotive material declarations have data-quality problems?
- 1. Incomplete material composition
- 2. Incorrect material structure
- 3. Incorrect substance information
- 4. Weight discrepancies
- 5. Excessive use of joker or confidential substances
- 6. Missing application information
- 7. Incorrect substance ranges
- 8. Outdated MDS references
- 9. GADSL and regulatory substance-data problems
- 10. Supplier data is often the real bottleneck
- IMDS data quality vs IMDS validation
- A practical IMDS data-quality workflow
- Step 1 — Collect source data
- Step 2 — Check completeness
- Step 3 — Validate the MDS structure
- Step 4 — Check substance data
- Step 5 — Check weights
- Step 6 — Check regulatory and customer requirements
- Step 7 — Identify errors and warnings
- Step 8 — Send supplier correction requests
- Step 9 — Revalidate
- Step 10 — Maintain the audit trail
- Common IMDS rejection patterns
- How to reduce repeated supplier corrections
- Managing IMDS data quality at scale
- IMDS data-quality checklist
- The real objective: reliable product material data
Poor IMDS data quality can delay MDS approval, create repeated supplier corrections, and make automotive material compliance difficult to maintain across products and customers.
The problem is often not the IMDS submission itself. It starts earlier—with incomplete supplier data, incorrect material composition, inconsistent substance information, weight discrepancies, outdated MDS references, or missing application and regulatory information.
A reliable IMDS process therefore needs more than a final MDS check. It needs a controlled workflow for collecting, validating, correcting, resubmitting, and tracking material data.
What is IMDS data quality?
IMDS data quality refers to the accuracy, completeness, consistency, and usability of the material and substance information contained in an IMDS Material Data Sheet (MDS).
Good-quality IMDS data should allow a manufacturer or customer to understand:
- what material or component is being declared
- how the MDS is structured
- which materials and substances are present
- the composition and concentration ranges
- applicable substance information
- relevant weights
- supplier and part information
- applicable regulatory or customer requirements
- which version of the underlying data is being used
IMDS itself performs a range of checks on mandatory fields, content, and material composition. However, the IMDS Steering Committee states that these checks identify areas requiring further investigation and should not automatically be used to reject data without human review.
That distinction matters.
An MDS can pass a system check and still require a quality review.
Why do automotive material declarations have data-quality problems?
IMDS data is dependent on information flowing through the supply chain.
A typical chain looks like:
Supplier data → Material composition → MDS creation → Validation → Customer review → Approval
A problem at any stage can affect the final declaration.
Common causes include:
- Incomplete material composition
- Incorrect substance identification
- Incorrect CAS numbers
- Incorrect material classification
- Weight discrepancies
- Excessive use of confidential or joker substances
- Missing application information
- Incorrect substance ranges
- Outdated MDS references
- Supplier data that has not been refreshed after a material or product change
This makes IMDS data quality partly a supplier-data management problem, not just an IMDS-entry problem.
1. Incomplete material composition
One of the most common problems is insufficient information about what a material actually contains.
If the underlying supplier declaration does not provide adequate substance information, the manufacturer may not be able to determine whether the material satisfies the relevant IMDS, GADSL, ELV, OEM, or other requirements.
This can lead to:
- incomplete MDSs
- additional supplier requests
- manual investigation
- delayed approval
- repeated submissions
The issue therefore needs to be addressed at the source.
The objective is not simply to make the MDS look complete. It is to establish whether the underlying material data is sufficiently accurate and traceable.
2. Incorrect material structure
IMDS materials must represent homogeneous materials.
A material with multiple physically distinct layers or materials may need to be represented using the appropriate semi-component or component structure rather than being incorrectly represented as one homogeneous material.
Incorrect structure can affect:
- material composition
- substance percentages
- weight calculations
- regulatory assessment
- downstream customer review
This is why MDS quality needs to be checked at the material and component structure level, not only at the final submission level.
3. Incorrect substance information
Substance-level errors can occur when supplier information is:
- incomplete
- incorrectly mapped
- based on an incorrect CAS number
- assigned to the wrong material
- outside the expected concentration range
- not updated when the formulation changes
These errors can affect substance declarations and downstream compliance assessments.
The official IMDS Examiner checks include CAS-number checks, classification checks, substance-range checks, prohibited-substance checks, duty-to-declare checks and other substance-related controls.
4. Weight discrepancies
Weight is another important data-quality control.
An MDS may contain calculated and measured weights that do not align within the applicable tolerance.
Weight problems can originate from:
- incorrect component weights
- incorrect material percentages
- outdated BOM information
- incorrect material references
- changes in product design
- rounding or calculation errors
IMDS quality checks include tolerance and weight-related checks.
The practical solution is to reconcile IMDS information with the manufacturer's product and BOM data rather than treating the MDS as an isolated record.
5. Excessive use of joker or confidential substances
Confidential and joker substances can be useful in appropriate circumstances, but excessive or inappropriate use can reduce transparency and create additional review requirements.
IMDS quality checks specifically examine the use of joker and confidential substances against defined limits and recommendations.
A supplier correction process should therefore identify when insufficient substance information is being provided and determine whether additional disclosure is required.
6. Missing application information
Some substances require application information for the assessment to be meaningful.
For example, an IMDS quality check can identify whether applications have been defined for application-relevant substances.
Missing application information can therefore prevent a material declaration from being evaluated correctly.
The correction should address the underlying material/application relationship rather than simply removing the warning.
7. Incorrect substance ranges
Suppliers may provide concentration ranges rather than exact substance percentages.
Ranges need to remain within the applicable IMDS recommendations and customer requirements.
The IMDS Examiner includes checks for substance ranges and whether ranges comply with applicable recommendations.
Large or poorly justified ranges can make the declaration less useful for compliance assessment and may trigger additional investigation.
8. Outdated MDS references
Material and component information can change over the product lifecycle.
An MDS may reference an older version of another MDS even though a newer version is available.
The result can be:
- outdated material information
- inconsistent product data
- duplicate supplier follow-up
- incorrect compliance status
- additional customer review
IMDS quality checks can identify new versions of referenced MDSs as well as deleted or hidden MDS and module references.
This is why IMDS data quality should include version control and change monitoring, not only one-time validation.
9. GADSL and regulatory substance-data problems
GADSL-related issues can also affect material declarations.
A supplier may provide incomplete substance information, incorrectly classify a substance, or fail to provide information required for the applicable declaration.
The important distinction is that GADSL assessment depends on the underlying material and substance data.
Therefore:
Poor material data → poor substance assessment → poor MDS quality
The GADSL assessment should be part of the material-data workflow rather than a final manual check immediately before submission.
For the underlying MDS information requirements, see IMDS MDS Requirements.
10. Supplier data is often the real bottleneck
For many manufacturers, the internal IMDS team is not the only source of data.
Material information may come from:
- Tier 1 suppliers
- Tier 2 suppliers
- material manufacturers
- component manufacturers
- engineering teams
- procurement systems
- existing MDS references
This creates a practical problem:
You cannot validate information that you never received.
Supplier data collection therefore needs to be treated as part of the IMDS process.
A controlled workflow should identify:
- which suppliers have outstanding data requests
- which parts are affected
- what information is missing
- when the request was sent
- whether the supplier responded
- whether the response passed validation
- whether further correction is required
- whether the final MDS was submitted and approved
For the supplier-data collection problem, see Getting FMD Data Without Chasing Suppliers.
IMDS data quality vs IMDS validation
These two concepts are related but not identical.
IMDS validation asks:
Does this MDS meet the required structural and data checks?
IMDS data quality asks:
Is the information itself accurate, complete, current, traceable, and usable for compliance decisions?
For example, an MDS may have all mandatory fields completed but still contain incorrect supplier information or outdated material composition.
That is why validation should be one stage of the broader data-quality process.
See IMDS Validation for the specific validation workflow.
A practical IMDS data-quality workflow
A stronger process looks like this:
Step 1 — Collect source data
Obtain material, substance, component, weight, supplier, and application information.
Step 2 — Check completeness
Identify missing material declarations, missing substances, incomplete composition, missing weights, and missing supplier information.
Step 3 — Validate the MDS structure
Check component, semi-component, material, and substance relationships.
Step 4 — Check substance data
Review classifications, CAS numbers, concentrations, ranges, confidential substances, joker substances, and applicable declaration requirements.
Step 5 — Check weights
Compare MDS weights against the relevant product or BOM information.
Step 6 — Check regulatory and customer requirements
Assess relevant GADSL, ELV, regulatory, and OEM-specific requirements.
Step 7 — Identify errors and warnings
Separate issues requiring correction from items requiring human investigation.
The official IMDS guidance specifically states that system checks should identify areas for further investigation rather than automatically replacing human review.
Step 8 — Send supplier correction requests
Provide the supplier with a clear explanation of:
- the affected MDS
- the problematic data
- the required correction
- supporting evidence
- the resubmission deadline
Step 9 — Revalidate
The corrected MDS should be checked again before acceptance or submission.
Step 10 — Maintain the audit trail
Record:
- original submission
- identified issue
- supplier response
- corrected version
- validation result
- approval status
- relevant timestamps
This creates a repeatable process rather than a series of disconnected email exchanges.
Common IMDS rejection patterns
When an MDS is rejected or returned for correction, the underlying reason commonly falls into one of these categories:
Problem | Typical consequence |
|---|---|
Missing composition | Supplier clarification required |
Incorrect material structure | MDS correction |
Incorrect substance data | Compliance review delayed |
Weight discrepancy | Validation failure or customer query |
Missing application | Additional information required |
Incorrect substance range | Validation/review issue |
Outdated MDS reference | Data refresh required |
GADSL-related issue | Substance assessment required |
Customer-specific requirement missed | MDS rejection or resubmission |
Poor source data | Repeated supplier follow-up |
The key is to treat rejection as a data-correction workflow, not simply an IMDS administration task.
How to reduce repeated supplier corrections
A mature IMDS process should move from:
Submit → Reject → Email supplier → Wait → Correct → Resubmit
to:
Collect → Validate → Identify issue → Assign supplier action → Correct → Revalidate → Submit → Track approval
This reduces unnecessary cycles and makes supplier performance measurable.
Useful metrics can include:
- first-pass acceptance rate
- average correction cycles per MDS
- supplier response time
- percentage of incomplete declarations
- recurring error categories
- overdue supplier requests
- rejected MDSs by supplier
- MDSs requiring manual investigation
These metrics help identify whether the problem is concentrated in particular suppliers, materials, product lines, or data processes.
Managing IMDS data quality at scale
Manual review becomes difficult when manufacturers manage thousands of components and supplier declarations.
A scalable process needs to connect:
Supplier data
↓
Material and substance information
↓
MDS creation
↓
Automated validation
↓
Issue classification
↓
Supplier correction
↓
Revalidation
↓
Submission and approval
↓
Audit trail
The value of automation is not simply faster MDS checking.
It is the ability to maintain a consistent quality process across large numbers of suppliers, materials, components, and products.
Regilient's IMDS/ELV compliance capability connects supplier and material information with product compliance workflows. Explore IMDS/ELV Compliance Software
IMDS data-quality checklist
Before accepting or submitting an MDS, check:
The real objective: reliable product material data
IMDS data quality is ultimately bigger than getting one MDS accepted.
The objective is to maintain reliable material and substance data that can support product compliance throughout the product lifecycle.
That means connecting supplier declarations to:
- product and BOM information
- material records
- regulatory requirements
- customer requirements
- engineering changes
- compliance assessments
- evidence
- historical versions
When these connections are maintained, an MDS becomes more than a submission document. It becomes part of the product compliance data record.