Hello from MDSKorea.
Responding to environmental regulations in the automotive industry is becoming increasingly complex. One of the most perplexing moments for compliance professionals is when data, submitted without issues using existing methods, is suddenly rejected. Missing out on the latest guidelines can result in carefully prepared data being rejected, leading to delayed project schedules.
Today, we provide a comprehensive overview of the key updates in the Global Automotive Declarable Substance List (GADSL) guidelines, revised as of March 1, 2026. We hope this update provides you with valuable insights on how to navigate and ensure compliance with these newly strengthened regulations.
---
1. 2026 Update Schedule and Transitional Period
GADSL is updated annually to reflect new scientific knowledge and environmental protection standards.
The 2026 guidelines were officially published on March 1st. This revision introduces new substances and changes the regulatory classifications of existing ones.
The guidelines stipulate that all Material Data Sheets (MDS) must comply with the latest version within a 12-month transitional period following publication. Please carefully review this timeline and cross-reference the substances in your key components with the latest GADSL database.
*These updates were applied to the IMDS system on March 20th.
2. Overview of P, D, and D/P Classifications
Navigating the alphabetical codes assigned to substances when entering IMDS data can often be challenging. GADSL broadly categorizes substances into three classifications based on their risk level and regulatory status:
P (Prohibited): Substances that are banned in at least one region/market or must not exceed regulatory threshold limits.
D (Declarable): Substances that must be declared if they exceed the threshold limit (A 'D' classification does not imply a ban or exclusion from use).
D/P (Declarable or Prohibited): Substances that require careful attention, as they may only need to be declared or may be strictly prohibited depending on their specific application.
[Important Notes on Applying Threshold Limits]
GADSL threshold limits are generally divided into two categories. Please consider the following:
Default Threshold: This is the standard value applied when no specific regulation exists. It applies at 0.1% per homogeneous material, not based on the total weight of the component or assembly.
Regulation-Based Threshold: If individual regulations set specific limits, the lowest applicable limit takes precedence. If a regulation does not specify a clear content limit, you must verify whether a "No intentional addition" clause applies.
3. California Battery Labeling
The most notable change in this revision is the new addition of the "California Battery Labeling Requirements" to approximately 203 existing substances.
Accordingly, the following condition has been specified for these substances:
"Any intentionally added content in batteries must be reported for California Battery Labeling Requirements."
Any intentionally added substances in batteries must be reported regardless of their content level. Since various substances such as Acetaldehyde (CAS: 75-07-0) and Acrylamide (CAS: 79-06-1) are subject to this rule, professionals handling battery-related components are strongly advised to carefully check the items that include the "California Battery Labeling Requirements" in this revision.
4. PFAS and PFCAs
The latest revision significantly reinforces the group entries related to PFAS (Per- and polyfluoroalkyl substances), which are strictly regulated as environmental pollutants globally. The following two groups are of key importance:
PFCAs (C9-C21) related substances: Perfluorocarboxylic acids with a carbon chain length of 9 to 21, along with related substances, have been added extensively. This reflects strengthening global regulatory trends, including European REACH.
PFHxS related substances: This group of substances, known as Perfluorohexanesulfonic acid, has been newly categorized and targeted for strict control in line with recent international trends toward usage bans.
*The following PFCA-related compounds will also be updated within the IMDS system.
5. Arsenic Compounds
Lastly, approximately 95% of the total Classification upgrades in this revision are concentrated on Arsenic compounds.
While the Arsenic group (GADSL#17) itself was already classified as D/P in the previous revision, the classification of about 144 individual subordinate substances has been changed from D to D/P. The Reason Code has also been upgraded to LR (Legally Regulated).
Therefore, when Arsenic compounds are contained, rather than simply reporting the amount, it is highly recommended to cross-check the "Action Required" section in GADSL to verify the specific application and ensure they are not used for prohibited purposes.
---
The core focus of the 2026 GADSL update is "strengthening battery regulations and expanding PFAS management."
Global environmental regulations are becoming increasingly stringent. The core of compliance work has evolved beyond simply reporting the presence of a substance, towards demonstrating regulatory conformity.
MDSKorea will continue to provide the most reliable and informative updates, enabling professionals to swiftly adapt to complex regulatory changes and enhance operational efficiency. Thank you.
Hello from MDSKorea.
Responding to environmental regulations in the automotive industry is becoming increasingly complex. One of the most perplexing moments for compliance professionals is when data, submitted without issues using existing methods, is suddenly rejected. Missing out on the latest guidelines can result in carefully prepared data being rejected, leading to delayed project schedules.
Today, we provide a comprehensive overview of the key updates in the Global Automotive Declarable Substance List (GADSL) guidelines, revised as of March 1, 2026. We hope this update provides you with valuable insights on how to navigate and ensure compliance with these newly strengthened regulations.
---
1. 2026 Update Schedule and Transitional Period
GADSL is updated annually to reflect new scientific knowledge and environmental protection standards.
The 2026 guidelines were officially published on March 1st. This revision introduces new substances and changes the regulatory classifications of existing ones.
The guidelines stipulate that all Material Data Sheets (MDS) must comply with the latest version within a 12-month transitional period following publication. Please carefully review this timeline and cross-reference the substances in your key components with the latest GADSL database.
*These updates were applied to the IMDS system on March 20th.
2. Overview of P, D, and D/P Classifications
Navigating the alphabetical codes assigned to substances when entering IMDS data can often be challenging. GADSL broadly categorizes substances into three classifications based on their risk level and regulatory status:
P (Prohibited): Substances that are banned in at least one region/market or must not exceed regulatory threshold limits.
D (Declarable): Substances that must be declared if they exceed the threshold limit (A 'D' classification does not imply a ban or exclusion from use).
D/P (Declarable or Prohibited): Substances that require careful attention, as they may only need to be declared or may be strictly prohibited depending on their specific application.
[Important Notes on Applying Threshold Limits]
GADSL threshold limits are generally divided into two categories. Please consider the following:
Default Threshold: This is the standard value applied when no specific regulation exists. It applies at 0.1% per homogeneous material, not based on the total weight of the component or assembly.
Regulation-Based Threshold: If individual regulations set specific limits, the lowest applicable limit takes precedence. If a regulation does not specify a clear content limit, you must verify whether a "No intentional addition" clause applies.
3. California Battery Labeling
The most notable change in this revision is the new addition of the "California Battery Labeling Requirements" to approximately 203 existing substances.
Accordingly, the following condition has been specified for these substances:
"Any intentionally added content in batteries must be reported for California Battery Labeling Requirements."
Any intentionally added substances in batteries must be reported regardless of their content level. Since various substances such as Acetaldehyde (CAS: 75-07-0) and Acrylamide (CAS: 79-06-1) are subject to this rule, professionals handling battery-related components are strongly advised to carefully check the items that include the "California Battery Labeling Requirements" in this revision.
4. PFAS and PFCAs
The latest revision significantly reinforces the group entries related to PFAS (Per- and polyfluoroalkyl substances), which are strictly regulated as environmental pollutants globally. The following two groups are of key importance:
PFCAs (C9-C21) related substances: Perfluorocarboxylic acids with a carbon chain length of 9 to 21, along with related substances, have been added extensively. This reflects strengthening global regulatory trends, including European REACH.
PFHxS related substances: This group of substances, known as Perfluorohexanesulfonic acid, has been newly categorized and targeted for strict control in line with recent international trends toward usage bans.
*The following PFCA-related compounds will also be updated within the IMDS system.
5. Arsenic Compounds
Lastly, approximately 95% of the total Classification upgrades in this revision are concentrated on Arsenic compounds.
While the Arsenic group (GADSL#17) itself was already classified as D/P in the previous revision, the classification of about 144 individual subordinate substances has been changed from D to D/P. The Reason Code has also been upgraded to LR (Legally Regulated).
Therefore, when Arsenic compounds are contained, rather than simply reporting the amount, it is highly recommended to cross-check the "Action Required" section in GADSL to verify the specific application and ensure they are not used for prohibited purposes.
---
The core focus of the 2026 GADSL update is "strengthening battery regulations and expanding PFAS management."
Global environmental regulations are becoming increasingly stringent. The core of compliance work has evolved beyond simply reporting the presence of a substance, towards demonstrating regulatory conformity.
MDSKorea will continue to provide the most reliable and informative updates, enabling professionals to swiftly adapt to complex regulatory changes and enhance operational efficiency. Thank you.