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News Briefs:
 
Oct 26, 2010: Michael Wurzman presents on California Green Chemistry at the AIAG IMDS/REACH Summit

New EU adds eight new substances to the REACH candidate list June 2010

California updates Prop 65 chemical list April 2010

JIG-101 edition 3.0 released March 2010

IPC issues new 175X family of declaration standards February 2010

EU amends list of ELV exemptions February 2010

CPSIA issues new timeline for testing of children's products December 2009


EU expands scope of its Ecodesign Directives to energy-related products October 2009

China proposes 'the catalog' for RoHS Phase 2 October 2009

China plans expansion of PEANCS (new chemical substances) June 2009

EU recommends first list of substances requiring authorization under REACH April 2009

California approves the Green Chemistry Initiative September 2008

NGO ChemSec releases 'SIN' list (Substitute It Now) September 2008

US adopts CPSIA for lead & phthalates in children's products and for lead paint August 2008

EU Court of Justice ends decaBDE exemption for RoHS April 2008


EU releases draft of proposed RoHS changes (known as RoHS2) 2008

EU considers adding medical devices and monitoring & control instruments to RoHS

EU considers adding new prohibited substances to RoHS

RoHS2 would rely upon standards developed by European standards organizations

EU releases its study on the 'simplification' of RoHS


EU releases its study of the costs and benefits of RoHS


Eight EU Member States are cited for RoHS & WEEE transposition failures

California governor vetoes bill to expand RoHS October 2007

Northeastern US states propose Model Electronic Recycling Act 


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IMDS vs RoHS

Directive 2000/53/EC - ELV
Directive 2002/95/EC - RoHS

IMDS is the material data system used to implement the Directive on End of Life Vehicles (ELV). In colloquial usage, IMDS is frequently used as a synonym for ELV.

ELV and RoHS are often confused because they both are directives of the European Union that (1) restrict the use of heavy metals in consumer products and (2) mandate recycling and treatment of waste products. However, ELV and RoHS are targeted at different product types, require different compliance mechanisms and have employ different enforcement strategies. Please see our comparison of key features below:

Name of Directive
ELV RoHS
End of Life Vehicles Restriction of Hazardous Substances
Directive 2000/53/EC Directive 2002/95/EC
Effective June 1, 2002 Effective June 1, 2006
Covered Products
Vehicles Electrical and electronic equipment
Type-approval categories: WEEE categories:
M1. passenger vehicles with no more than 8 seats
N1. cargo vehicles weighting up to 3.5 tonnes
L2e & L4e. three-wheeled vehicles with side cars
1. large household appliances
2. small household appliances
3. IT & telecommunications equipment
4. consumer equipment
5. lighting equipment
6. electrical & electronic tools (except large-scale stationary industrial tools)
7. toys, leisure & sports equipment
10. automatic dispensers
Applies to all components in the vehicle, including electrical & electronic components Does not apply to electrical & electronic components in other types of equipment (such as vehicles)
  Does not apply to spare parts for EEE put on the market before July 1, 2006
Prohibited Substances
4 heavy metals only 4 heavy metals plus
2 flame retardants

Lead, mercury, cadmium, hexavalent chromium

Lead, mercury, cadmium, hexavalent chromium,
PBB and PBDE

Effective July 1, 2003 Effective July 1, 2006
Maximum Concentration Values
In homogeneous materials In homogeneous materials

0.1% by weight for lead, mercury and hexavalent chromium

0.1% by weight for lead, mercury, hexavalent chromium, PBB, PBDE

0.01% by weight for cadmium 0.01% by weight for cadmium
Exception for recycled materials if used as a feedstock (not intentionally introduced)  
exemptions
Listed in Annex II Listed in Annex
Approved if the use of these substances is unavoidable Approved if elimination/ substitution is technically/ scientifically impracticable (or if negative environmental, health or consumer safety impacts outweigh the benefits)
Manufacturer compliance
Type-approval is required
before product can be placed
on the market
Products placed on the market are presumed to be compliant
IMDS database requires material data sheets for all materials and components Product must show RoHS compliance symbol
Location of prohibited substances must be identified Manufacturer must be able to show Due Diligence in keeping prohibited substances out of product
Location of substances on GADSL list must also be identified
Separate Collection of Waste
Separate collection of ELV Collection of EEE separate from unsorted municipal waste
Free of charge to final holder Free of charge to final holder
Mandatory Voluntary
Owner of vehicle must register vehicle with Member State Product must show WEEE separate collection symbol
Owner must show “certificate of destruction” to deregister vehicle  
Recycling Goals
Effective January 1, 2006: Effective December 31, 2006:
Cars produced after 1979:
80% by weight reuse/recycling 85% by weight total recovery

WEEE categories 1 & 10:
75% by weight reuse/recycling 80% by weight total recovery

Cars produced before 1980:
70% by weight reuse/recycling 75% by weight total recovery

WEEE categories 3 & 4:
65% by weight reuse/recycling 75% by weight total recovery

Effective January 1, 2015:
85% by weight reuse/recycling
95% by weight total recovery

WEEE categories 2, 5, 6 & 7:
50% by weight reuse/recycling 70% by weight total recovery

Reuse: components are refurbished and used for their original purpose. Recycling: materials are processed so that they can be used for another purpose. Total Recovery: includes reuse/recycling plus energy recovery

Waste Treatment

Per Annex I of
Directive 2000/53/EC (ELV)
Per Annexes II & III of
Directive 2002/96/EC (WEEE)

Producer pays beginning
July 1, 2002

Producer pays beginning
August 13, 2005

Treatment centers must be permitted/inspected yearly Treatment centers must be permitted/inspected yearly
Manufacturer must provide treatment centers with: Manufacturer must provide treatment centers with:
Instructions on dismantling vehicle, removal of all fluids, storage and testing of components which can be reused Identity of different components and materials; location of dangerous substances and preparations; reuse and treatment information
(6 months after placing vehicle on market) (12 months after placing EEE on market)

This summary is intended to give you an easy-to-understand overview and does not constitute legal advice. The actual standard in the original language should be reviewed and used for all business, legal, and product compliance purposes.

If you need assistance in understanding or managing your IMDS reporting requirements (including IMDS managed services), we stand ready to help you. Just email us or give us a call at 972-679-8996 for a quick and personalized response.

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Quick Tutorial:

    STANDARDS:    
What are Standards?
New What is JIG-101?
New What is IPC-1752?
What is the IEC?
What is TC 111?

What is the WTO?
What is TBT?

       USA:        What is CPSIA?
CPSIA timeline
CPSIA exemptions

What is California Green Chemistry?
What is Proposition 65?What is California RoHS?
What is California WEEE?


      EUROPE:     

What is ELV?
      ELV exemptions

What is IMDS?

What is GADSL?

Compare IMDS vs RoHS

What is EuP?
What is ErP?
What is Ecodesign?
Implement. Measures

What is
REACH?
What are SVHCs?
      Proposed SVHCs
      New Candidate list
      Priority substances
About Pre-registration

About REACH fees
What is SIN list?

What is RoHS
?
     RoHS exemptions
What is 
WEEE?
What is Due Diligence?

What is RoHS2
?
What is New Approach?
New Legislative Framework?

What is the CE Mark?
What about Packaging
?
What about Batteries?
        
      JAPAN:      
Design for Environment
What is Japan RoHS?
What is J-Moss?

      CHINA:      
What is China REACH?
What is China RoHS?
      Phase 1
      Phase 2
What is Clean Production?

        
      KOREA:      
What is Korea RoHS?
What is EPR System?

    HYPERLINKS:   
red hyperlinks are links to official government documents (usually in .pdf)

              
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