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IMDS 15 is already in effect. What makes it different from previous releases is not UI polish or regulatory list updates, but a structural change in what IMDS is expected to carry: Product Carbon Footprint (PCF) data alongside material and substance information.
If carbon reporting is still treated as a CSR exercise, suppliers will struggle to remain sourcing-relevant over the next few cycles.
Let’s break down what has changed, what is live today, and why this matters now.
What Is IMDS 15 and Why Should You Care?
IMDS 15 is the current production version of the International Material Data System.
- IMDS 15.0 went live in July 2025
- IMDS 15.1 followed in October 2025
- IMDS 15.2 is scheduled for 21 January 2026
As of 2026, the automotive supply chain is operating fully under IMDS 15.x.
The headline change is not cosmetic:
Carbon data is now structurally supported inside IMDS.
This shift is driven by external pressure, not by IMDS in isolation:
- The EU Green Deal and lifecycle-based climate targets
- The Corporate Sustainability Reporting Directive (CSRD), in force for large companies from FY 2024 reporting
- The EU Battery Regulation, adopted in 2023, with mandatory PCF requirements rolling in from 2025 onward
- Growing demand for Scope 3 emissions transparency across global supply chains
OEMs must now account for product-level emissions. That pressure is cascading directly to suppliers — and IMDS is the system expected to carry that data.
What’s Changing in IMDS 15?
IMDS 15 introduces the foundation for carbon reporting rather than immediate enforcement.
Key changes live since IMDS 15.0 (July 2025) include:
- Support for Product Carbon Footprint (PCF) data fields at material and component level
- Alignment with cradle-to-gate lifecycle scope, consistent with ISO 14067
- Improved regulatory clarity for SVHCs, MCCPs, and material classification
- Stronger data-quality controls around misuse of “rest” materials
IMDS 15 does not automatically approve or reject products based on carbon thresholds. Instead, it enables consistent, traceable carbon data to be exchanged across the supply chain.
Why Does PCF in IMDS Matter Now?
1. OEMs are already demanding PCF
Automakers including Audi, BMW, and Volkswagen have been running supplier PCF pilots since 2023–2024.
By 2025, PCF requests are increasingly appearing in sourcing and engineering workflows.
2. PCF is becoming a sourcing quality metric
Cost, weight, and recyclability are no longer enough. Carbon intensity is now evaluated alongside traditional criteria in RfQs and design reviews.
3. Lost readiness equals lost business
IMDS itself does not disqualify suppliers — OEMs do.
Suppliers that cannot provide product-level, traceable PCF data face:
- RFQ exclusions
- sourcing delays
- manual remediation under tight deadlines
4. Regulatory pressure is rolling in by category
The EU Battery Regulation already mandates PCF for batteries. Other product categories are expected to follow similar lifecycle-based disclosure models over time.
Carbon reporting is no longer optional — it is becoming commercially enforced before it is universally regulated.
How PCF Is Reported via IMDS (15.x Reality)
IMDS 15 does not turn carbon reporting into spreadsheets.
The emerging reporting flow looks like this:
- Upstream suppliers provide cradle-to-gate PCF values (kg CO₂e) for materials
- Component suppliers aggregate PCF across the full BOM structure
- IMDS records PCF data alongside mass, recyclability, and substance declarations
- OEM systems apply validation and decision logic using IMDS data as input
PCF data complements existing material and substance declarations. It does not replace RoHS, REACH, GADSL, or ELV compliance — it converges with them.
Preparing Your Organization for IMDS 15
You do not need to wait for another IMDS release.
Suppliers that started preparation in 2024–2025 are already ahead by:
- Training engineering and compliance teams on ISO 14067 PCF methodology
- Engaging Tier-2 and Tier-3 suppliers for carbon data collection
- Updating internal MDS templates to support PCF fields
- Auditing BOMs for carbon hotspots (aluminium, steel, copper, rare earths)
- Aligning PCF workflows with PLM and supplier data systems
By 2026, PCF readiness is becoming a baseline expectation rather than a differentiator.
How Acquis Helps You Stay Ready for IMDS 15
Acquis is built for the 2025–2027 transition phase, where:
- IMDS structurally supports PCF
- OEMs commercially enforce carbon transparency
- Regulations apply PCF requirements selectively by product category
With Acquis, manufacturers can:
- Use PCF-ready supplier templates for structured data collection
- Automate carbon rollups across complex BOM hierarchies
- Co-validate PCF alongside GADSL, ELV, REACH, and RoHS requirements
- Maintain audit-ready evidence for OEM and regulatory review
- Export IMDS-aligned data without rework or duplication
Whether you’re a Tier 1 managing thousands of submissions or a Tier 3 building PCF capability for the first time, Acquis helps you move before carbon becomes a hard gate.
Reach out to our IMDS compliance experts
Bottom line
- IMDS 15.0: Live since July 2025
- IMDS 15.1: Live since October 2025
- IMDS 15.2: Go-live 21 January 2026
- OEM PCF pressure: Active since 2024
- Regulatory PCF mandates: Rolling in from 2025 onward
IMDS has structurally caught up. OEM expectations are already moving faster.