IMDS Validation: How to Check MDS Data Before Submission

An IMDS submission can fail even when the required material information has been collected. The problem is often not missing data alone, but incorrect structure, inconsistent quantities, incomplete substance information, incorrect regulatory classifications, or data that does not meet customer requirements.

IMDS validation is the step that checks a Material Data Sheet (MDS) before it is submitted to an OEM or customer.

A practical validation process should verify the MDS structure, material composition, weights, substance declarations, regulatory information, application data, and customer-specific requirements before submission.

What Is IMDS Validation?

IMDS validation is the process of reviewing an MDS to determine whether the data is:

• complete
• structurally correct
• technically consistent
• compliant with applicable reporting requirements
• suitable for OEM submission
• supported by reliable supplier information

Validation is different from simply checking whether every field has been filled in.

An MDS can be technically complete but still contain data that requires correction before an OEM will accept it.

For automotive suppliers, validation should therefore happen before submission, rather than after an MDS has been rejected.

What Should Be Checked During IMDS Validation?

A useful IMDS validation process should cover several layers of the MDS.

1. Check the MDS Structure

Start with the structure of the Material Data Sheet.

Review whether the MDS correctly represents the product or component being declared, including:

• component and subcomponent relationships
• materials
• substances
• quantities
• node structure
• material classifications
• relevant references and identifiers

The structure should accurately reflect how the material or component is actually constructed.

Incorrect hierarchy or missing nodes can create problems further down the compliance assessment.

This is why MDS requirements and MDS validation are related but different: requirements define what needs to be provided, while validation checks whether the submitted data is usable and internally consistent.

2. Validate Material Composition

The material composition needs to represent the actual material being declared.

Review:

• material classification
• material name and description
• substance composition
• concentration ranges
• material weight
• applicable material categories
• confidential substances, where applicable

A common problem is receiving a declaration that appears complete but does not provide enough substance-level information to support the required compliance assessment.

Material composition should therefore be checked against the supplier's technical information and the actual component or material specification.

3. Check Weight Consistency

Weight errors are another common source of IMDS data problems.

The declared weight should make sense at the relevant levels of the MDS structure.

For example:

Component weight - material weights - substance composition

The numbers should reconcile logically.

Large discrepancies between declared component weight and the underlying material data should be investigated before submission.

Weight validation is particularly important when an MDS is built from multiple materials or subcomponents.

4. Check GADSL and Regulatory Information

IMDS data also needs to be reviewed against applicable substance reporting requirements.

This includes checking whether relevant substances have been correctly identified and classified according to applicable requirements such as GADSL and other regulatory information used within the IMDS workflow.

GADSL classifications distinguish substances according to their reporting status. Importantly, GADSL reporting thresholds are not the same as permissible-use limits.

The validation process should therefore confirm that:

• relevant declarable substances are identified
• classifications are correct
• applicable thresholds are respected for reporting purposes
• required regulatory information is present
• substance information is consistent with the material composition

This is an area where automated checks can significantly reduce manual review.

5. Check Application and Use Information

Substance information alone may not be sufficient.

Where applicable, review whether the MDS correctly describes how the material or substance is used in the component.

This can affect how regulatory information is interpreted and whether additional information is required.

The compliance team should verify that the declared application is consistent with the actual product design and supplier information.

6. Validate Supplier-Provided Information

The quality of an MDS ultimately depends on the quality of the underlying supplier data.

Before accepting an MDS, check:

• supplier identity
• source of the material information
• completeness of the declaration
• consistency with specifications
• data freshness
• missing information
• unexplained assumptions
• changes from previous declarations

A supplier submitting an MDS does not automatically mean the data is ready for OEM submission.

Validation should identify information that requires supplier clarification or correction.

This is particularly important for organizations managing large supplier networks and thousands of material declarations.

For broader supplier-data collection challenges, see Regilient's IMDS data quality guidance.

7. Check Customer and OEM Requirements

IMDS validation should not stop at generic data checks.

Automotive manufacturers and OEMs may have additional requirements affecting how material information must be provided.

Before submission, verify whether the relevant customer requires:

• specific material information
• particular declaration structures
• customer-specific substance requirements
• additional documentation
• specific MDS statuses
• particular submission or approval workflows

A technically valid MDS can still require changes if it does not satisfy the customer's requirements.

This is why validation should be connected to the actual submission workflow rather than treated as a generic data-quality exercise.

Common IMDS Validation Failures

Some recurring issues include:

These problems are often interconnected.

For example, a supplier change can alter material composition, which can change substance reporting, which can require a new validation and potentially a new OEM submission.

A Practical IMDS Pre-Submission Validation Workflow

A repeatable workflow can be structured as follows:

Step 1 — Receive the MDS

Collect the supplier's MDS and supporting information.

Step 2 — Check completeness

Confirm that the required product, component, material and substance information is present.

Step 3 — Validate structure

Check the MDS hierarchy and relationships between components, materials and substances.

Step 4 — Validate composition

Review material classifications, substance information and concentration data.

Step 5 — Reconcile weights

Check that the declared weights are logically consistent throughout the MDS.

Step 6 — Check regulatory information

Review GADSL and other applicable regulatory information.

Step 7 — Check supplier data quality

Identify missing, outdated or inconsistent information.

Step 8 — Apply OEM requirements

Check customer-specific requirements before submission.

Step 9 — Resolve exceptions

Return incomplete or incorrect MDS data to the supplier for correction where required.

Step 10 — Submit

Only after validation is complete should the MDS move into the OEM submission process.

IMDS Validation vs. IMDS Data Quality

These topics should not be treated as the same thing.

IMDS validation is the proactive process of checking an MDS before submission.

IMDS data quality is the broader problem of ensuring that the underlying material declarations remain accurate, complete, current and usable.

That distinction matters operationally.

A validation process can identify an incorrect MDS before submission. A broader data-quality process should also address why incorrect declarations continue to enter the system in the first place.

For recurring rejection patterns and supplier-data problems, see IMDS Data Quality Problems: A Practical Guide.

Can IMDS Validation Be Automated?

Yes. Many repetitive validation checks can be supported by software.

Automation can help teams:

• identify incomplete MDS data
• check material and substance relationships
• flag weight inconsistencies
• apply regulatory and substance rules
• identify missing supplier information
• track validation exceptions
• route corrections back to suppliers
• maintain validation records
• monitor changes in material information

The objective is not to remove compliance professionals from the process.

It is to reduce repetitive checking so compliance teams can focus on exceptions, regulatory interpretation, supplier escalation and final decisions.

This becomes increasingly important as organizations manage large numbers of suppliers, components and MDS records.

For organizations looking to automate IMDS and ELV-related workflows, see Regilient's IMDS/ELV compliance software.

IMDS Validation Checklist

Before submitting an MDS, ask:

• Is the MDS structure correct?
• Are all required components and materials included?
• Does the material composition reflect the actual material?
• Are substance concentrations complete and consistent?
• Do the weights reconcile?
• Have relevant GADSL substances been correctly identified?
• Is the required regulatory information present?
• Is the application/use information accurate?
• Is the supplier data current?
• Have customer-specific requirements been checked?
• Have all validation exceptions been resolved?
• Is the MDS ready for OEM submission?

If any of these questions cannot be answered confidently, the MDS may require further review before submission.

The Goal of IMDS Validation

IMDS validation should not be treated as a final administrative check.

It is a control point between supplier material data and OEM submission.

A stronger workflow connects:

This makes it easier to identify problems before they become submission rejections and provides a more consistent process for managing material compliance data across the automotive supply chain.

For organizations managing IMDS at scale, the longer-term objective is to connect supplier engagement, material data, validation, regulatory assessment and evidence into one operational workflow.