Comparison of IMDS and RoHS by RSJ Technical Consulting

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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:
ê	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.
ê	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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