|
Comparison of 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 |
|
Instructions due 6 months after placing vehicle on market |
Instructions due 12 months after
placing EEE on market |
| |
|
| |
|
|
This comparison
of IMDS and RoHS is designed to
provide you with an accurate, easy-to-understand overview of the
topic. However: |
|
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We
have not attempted to cover the
implementation issues that need to be addressed at your
company or in your supply chain. For this type of assistance,
please
email
or
call us at 972-679-8996 to inquire about our services. |
|
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This summary
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. |
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Technical Consulting
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