Critical Raw Materials (CRM)
From February 2021, the “Critical Raw Materials” Group will be listed in the Global Automotive Declarable Substance List (GADSL, on www.GADSL.org), requiring these substances to be reported in IMDS data sheets.
The list of associated CAS numbers for the Critical Raw Material is here. (August 2023)
It is expected that IMDS data containing these Critical Raw Materials starts to be populated in 2021, with mandatory reporting commencing in 2022.
Why do we need to declare critical raw materials?
The EU Commission has identified in several communications, including the Waste Framework Directive, the new Battery Regulation or the Circular Economy Action Plan that a more robust approach is needed in the management and recovery of critical raw materials. They expect industries to know where these materials are used and to use these materials responsibly. Recycling and recovery targets for producers as well as labelling obligations are also on the strategic landscape.
Why are these substances listed separately in IMDS and not in GADSL?
Typical substances listed in GADSL are listed due to current or potential restrictions relating to Health and Safety. Although the GADSL should not be treated as an exclusion list, it is sometimes misused in this way.
Critical raw materials on the other hand are critical to industry for several reasons but usually not because of their hazard properties. Their listing therefore is not an indication that their use should be restricted.
Whether to list these substances separately in GADSL or IMDS is constantly being reviewed and may be amended with future releases of GADSL.
How have the critical raw materials been prioritised?
The list of critical raw material substances has been prioritised based on the EU Commission’s critically assessment. Only those substances defined as very high, high and moderate, were chosen in the definition in the development of this list, as these are the most applicable to emerging low CO2 technologies, whose usage is going to increase in the next few years.
Source: European Commission - Critical Raw Materials for Strategic Technologies and Sectors in the EU - A Foresight Study, page 10 (to enlarge the picture, please right-click and open in separate browser tab)
What is the reporting threshold?
For new data sheets (those created with a new MDS ID after February 28th 2022) the reporting threshold is 0.1%.
For existing data sheets for which MDS ID (version 1) has been created earlier than Feb 28th, the data sheet content only needs to be amended if the Critical Raw Material substance content exceeds 1% and it is not currently declared. This applies to all version updates of this material.
Where can I go to find more information?
Please see the EU Commission’s website on Critical Raw Materials.
