The Global Automotive Declarable Substance List (GADSL) is an industry success story on collaboration and agreement in the automotive supply chain, from OEMs to chemical producers. The objective is to produce one definitive agreed-upon list of declarable substances throughout the industry. This list is updated at least yearly, with the latest release that occurred February 1, 2015.
This latest list includes several amendments and inclusions, so companies within the automotive industry are advised to review the list to understand whether and how they may be affected. If any of the substances identified on the GADSL are contained in materials being used and they are above the declaration threshold, they must be reported in IMDS submissions.
Since the GADSL contains substances that must be legally declared to customers (e.g. REACH Substances of Very High Concern), material data sheets (MDSs) must be updated and sent to those customers if they are affected by a substance in addition to GADSL.
If a substance was previously marked as “Confidential” in an MDS and that substance is subsequently added to the GADSL, then material information in IMDS must be updated and passed on to customers. Failure to do so will result in the material being assigned an error flag, making it unusable by the entire supply chain.
As a reminder, GADSL substances contain the following classifications:
D = Declarable - A substance with this designation must be declared if it exceeds the defined threshold limits.
P = Prohibited - A substance with this designation is either prohibited by regulation for use in certain applications, or may not exceed regulated threshold limits.
The IMDS MDS for the materials must contain all of the actual GADSL substances present in the material, regardless of its GADSL classification.
To enable the smooth flow of IMDS data throughout the supply chain, IMDS records should not be rejected if they contain substances listed as “D” on the GADSL.
More information, including the updated GADSL can be found on www.gadsl.org.