Issue: Polymeric parts marked question not answered
EU law 2003/138/EC establishes component and material coding standards for vehicles pursuant to ELV.
Your component contains at least one material with one of the following classifications:
- 5.1.a Filled Thermoplastics
- 5.1.b Unfilled Thermoplastics
- 5.2 Thermoplastic Elastomers
- 5.3 Elastomer
- 5.4 Duromers
- 5.4.1 Polyurethane
- 5.4.2 Unsaturated polyester
- 5.4.3 Other duromers
- 5.5.1 Plastics (in polymeric compounds)
- 5.5.2 Textiles (in polymeric compounds).
These classifications trigger the Polymeric parts marked question: Are your polymeric part(s) marked according to the applicable ISO Standards? The applicable standards are the following:
- ISO 1043: Plastics — symbols and abbreviated terms
- 1043-1: Plastics — symbols and abbreviated terms. Part 1: Basic polymers and their special characteristics
- ISO 1043-2: Plastics — symbols and abbreviated terms. Part 2: Fillers and reinforcing materials
- ISO 1629: Rubbers and latices — Nomenclature. (This does not apply to the labelling of tires.)
- ISO 11469: Plastics — Generic identification and marking of plastic products
- ISO 18064: Thermoplastic elastomers — Nomenclature and abbreviated terms
The question is triggered no matter what the amount of polymeric materials is present in the part. It is good practice to answer the question for all parts. While leaving it blank is allowed, some customers may insist on an answer, so answering the question whenever it is asked can save you rework in IMDS.
There are three possible answers to the question. Each answer is discussed below.
Yes (Parts marked as required by law.)
If the the weights of all the materials in the part with classifications 5.1x, 5.4.x and 5.5.x are added together and that weight exceeds 100g, then the part should be marked. NOTE: It is the sum of the weight of the materials NOT the weight of the part that should be considered when answering the question. A part could weigh more than 100 grams but contain less than 100g of 5.1.x, 5.4.x and/or 5.5.x materials. This part would not be required to be marked.
If the the weights of all the materials in the part with classifications 5.2 and 5.3 are added together and that weight exceeds 200g, then the part should be marked. NOTE: It is the sum of the weight of the materials NOT the weight of the part that should be considered when answering the question. A part could weigh more than 100 grams but contain less than 200g of 5.2 and/or 5.3 materials. This part would not be required to be marked.
The question is triggered no matter what the amount of polymeric materials is present in the part. It is could practice to answer the question for all parts. While leaving it blank is allowed, some customers may insist on an answer, so answering the question whenever it is asked can save you rework in IMDS.
If your parts are not marked and are not required to be marked by law, you should select Yes. Why? Because the law does not require the part to be marked and the part is not marked, therefore it is marked as required by law. More specifically,
- You should select Yes as your answer, if your part contains less than 100g of 5.1.x, 5.4.x and/or 5.5.x materials and is not marked.
- You should select Yes as your answer, if your part contains less than 200g of 5.2 and/or 5.3 materials and is not marked.
No (Parts not marked as required).
If the part should be marked, but is not, you should answer the question No. If your part is not marked and it should be, contact your customer to discuss a solution to this issue.
Not Applicable (Parts do not require marking due to specifications of weight, geometric restriction or surface requirements.)
This option is appropriate if your part is required to be marked; but something about the part specifications prevent the marking. For example, a plastic film may not be marked because the surface requirements make it impossible to mark. Or a part may be so twisted and convoluted geometrically that there is not a surface suitable for marking. If you have a part that should be marked and isn’t, find out why. Make sure the lack of marking was not just an oversight.
Additional guidance on parts marking is available here.
Action Required:
If the correct answer to the question is Yes, revise your answer to the question and resubmit.
If the correct answer to the question is Not applicable, revise your answer to the question and resubmit.
If the correct answer to the question is No, revise your answer to the question and resubmit. Contact your customer to discuss a solution to this issue.