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IMDS Reporting Requirement Specification

Keykert 4904 2004 Revision 01

Released October 28, 2005

Released 10/28/2005

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

Table of Contents

General Information / Objective.....................................Page 3 IMDS Reporting Requirements......................................Page 4 IMDS / PPAP / APQP..................................................Page 5 Delinquent Reporting...................................................Page 6 Submission Requirements...........................................Page 6-8 Rejection Codes.........................................................Page 9-10 IMDS Structural Illustrations...........................................Page 11-12 IMDS Training information............................................Page 13 Keykert/Kiekert IMDS contacts......................................Page 14 Appendix A...............................................................Page 15-18 (DPS form) Appendix B...............................................................Page 19-20 (IMDS Definitions) Appendix C...............................................................Page 21-22 (Examples of common reporting errors) Appendix D...............................................................Page 23-24 (Searching for ILI-metals) Revision history ..........................................................Page 25

All revisions and additions are highlighted in grey

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

The objective of this specification is to provide Keykert USA and Kiekert de México suppliers with: Guidelines and requirements for reporting to Keykert USA and Kiekert de México Reporting requirements for the International Material Data System (IMDS) Additional information and supporting instructions for using IMDS and reporting via IMDS (e.g.: ILI-metals, IMDS Recommendations, etc.) IMDS definitions/terminology Four components for creating and releasing component/material data via IMDS: 1) IMDS registration ­ suppliers must be a registered IMDS user 2) Define materials via IMDS 3) Construct product tree structure (MDS) 4) Submit/Release Material Data Sheets (MDS) to Keykert IMDS ID #1875 Access IMDS @ http://www.mdsystem.com

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Keykert USA, Inc. and Kiekert de México IMDS Reporting Requirements Materials One hundred percent (100%) of all materials must be detailed in IMDS using either specific or generic (where permissible) material designations. Substances All substances that are contained in a material (specific and/or generic) shall be fully disclosed. Keykert/Kiekert will not accept submissions with information classified as confidential. The use of generic substances or "jokers" is acceptable; however, "joker/wildcard" declaration shall not exceed 10% of the mass of the homogeneous material. Generic substances are not permissible in lieu of disclosing prohibited or declarable substances. The four restricted heavy metals (hexavalent chromium (Cr6+), lead, cadmium, and mercury) must be fully disclosed regardless of their percentage or weight. All prohibited or declarable substance defined by the GADSL list (Global Automotive List of Declarable Substances), and/or Keykert/Kiekert internal requirements shall be disclosed. It is the responsibility of the supplier of the parts and/or raw materials to ensure compliance with the requirements of: The latest ELV Directive (2000/53/EC) including supporting amendments (e.g.: Annex II) Current GADSL list For all applicable customer specific requirements (e.g.: Keykert4904 2004, FoMoCoWSS-M99P9999-A1, etc.) Current IMDS system reporting requirements (e.g.: version 3.1 - polymeric part marking requirement) Suppliers are responsible for ensuring that all submissions are in accordance to this IMDS reporting specification (4904 2004), as well as, all applicable IMDS Recommendations. All IMDS reporting to Keykert USA is to be provided in English. Submissions received in other languages are subject to rejection.

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IMDS/Production Part Approval Process (PPAP) and Advance Product Quality Planning (APQP) requirements Material certifications must accompany all PPAP submissions per AIAG's PPAP guidelines. An IMDS submission is required for each component prior to or at the time of PPAP submission. PPAP submission will not be accepted until all applicable parts are submitted, reviewed, and approved via IMDS, and is in accordance to Keykert/Kiekert PPAP guidelines. Based on IMDS volume, IMDS submissions and all supporting documentation should be submitted at least four weeks prior to the PPAP due date. All IMDS submissions are reviewed in the order they are received. Substances detailed on material certifications must match the substance breakdowns detailed in IMDS unless ILI-metals are used. If a supplier's IMDS submission is rejected for any reason, full PPAP approval will not be granted until the submission has been corrected, re-submitted (full PPAP approval is required before the release of final tooling payments), and approved. IMDS reporting has been integrated into the APQP process. Impurities caused by prohibited substances shall be recorded qualitatively and risk estimates should be discussed in a dialogue. Production & Production intent Suppliers All prohibited substances must be declared and approved prior to use. Declaration shall be made via Keykert/Kiekert's Declarable/Prohibited Substance Reporting and Approval Form (FCD-0334). When declarable or prohibited substances are present, the form must be completed and submitted early in the development phase (see appendix A). This will allow adequate time for re-design and/or re-validation with an alternate material, should either Keykert/Kiekert and/or our customer not approve the current application.

**Substances not approved by Keykert must be eliminated from the product. **

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

Delinquent Reporting Suppliers that do not report their parts via IMDS and/or are delinquent in reporting will: Be charged a daily administrative cost per missing part until all submissions are received and approved (amount to be negotiated according to cost incurred by Keykert/Kiekert) Not receive PPAP approval Not have pending tooling orders honored for payment (partial payments may be withheld) Have points deducted from supplier rating Placed on probation Placed "new business hold" and may be subject to de-sourcing of current business Suppliers will subsequently be responsible for charge-backs incurred by Keykert/Kiekert from our respective customers as a result of missing, inaccurate, or false IMDS reporting and/or usage of prohibited/restricted substances not approved by Keykert USA, Inc. Keykert USA / Kiekert de México IMDS Submission Requirements When an IMDS submission is required An IMDS submission is required: With all PPAP submission and/or revision level bumps A change in mass of a part exceeding the tolerance listed on the production part drawing or the Part Submission Warrant (PSW) When design, specification or material changes occur When using alternative materials, as detailed on the Keykert drawing When suppliers of products or services are changed Upon request, if non-compliance to legal conditions are suspected When revisions to the GADSL change the status, reporting requirement, or threshold of a substance IMDS system enhancements or changes may affect how data is reported, and may result in a re-submission in some cases (if applicable, suppliers will be notified) All components within a purchased assembly must be created as "components" and NOT as a "semi-components" via IMDS. *Note: A semi-component as defined in IMDS is not applicable for Keykert/Kiekert components; therefore, semi-components shall not be used in any submission to Keykert/Kiekert.

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If the assembly contains components that have Keykert/Kiekert part numbers, the Keykert/Kiekert part numbers must be detailed (including the revision level) for each applicable component. If an assembly contains components that do not have Keykert/Kiekert part numbers then the component(s) may be detailed with PIA (Purchased In Assembly) as the part number. A PIA part number is only acceptable if the part/component within a purchased assembly Does Not have a Keykert/Kiekert part number. Supplier Reporting Requirements Suppliers shall submit all parts to Keykert USA via IMDS ID #1875 and must include the following: Keykert/Kiekert part number and revision level (e.g. 4900210000) Keykert/Kiekert part description (e.g. IVH Catch Complete) as detailed on the drawing Detail 0 for Recyclate information (required for all plastic parts) Detail application codes, when applicable Certify polymeric parts are appropriately marked (in accordance to ISO 11469/1043/1629) Full disclosure of all applicable materials, substances, coatings, and plating (in their cured state) Material names shall define the material. The use specification numbers (e.g.: WSS-M21P27-A1 instead of Magni Plating) or generic descriptions are not permissible Materials and Substances It is imperative to preserve the integrity, accuracy, and reliability of each submission; therefore, suppliers are required to either create their own materials, or only utilize materials that have been created by their material supplier(s). *Note1: Metals are an exception. Please see "Reporting of Metals (Steel)" for material reporting requirements. Suppliers are responsible for the accuracy of the data sent to Keykert regardless of its originating source(s). Substances cannot be directly attached to a component or semi-component, they must be attached to a material. *Note 2: Substances shall be reported in their cured state Plastics and Rubbers Refer to IMDS recommendation 003 for rubber and recommendation 010 for plastics. All plastic and rubber materials must be created in accordance to these recommendations (see IMDS public pages).

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

For polymeric materials, the designated marking codes in the "Symbol" field. Metals (Steel) Due to many range variations in reporting metal (steel) materials, which has resulted in rejections by the OEMs, the IMDS Committee has pre-loaded over 12000 metal materials into IMDS. Keykert/Kiekert has reviewed and adopted the ILI Metals listing. Suppliers are required to select metals (steel) from the ILI Metals list in lieu of creating their own metal materials in IMDS. Non-compliant submissions will not be accepted (see exceptions below). **Exception: Suppliers may create their own metal (i.e. steel) material if: The material is not already created in IMDS (pre-approval via a DPS form is required) When there is a significant difference between the suppliers' metal and the metal detailed in IMDS (pre-approval via a DPS form is required) *Note: Advance notice does not constitute acceptance, but failure to submit advance notice will result in an automatic IMDS rejection. Coatings and Surface Treated Metals Submissions for components that have a coated or treated metal substrate must have at least two materials in the IMDS tree ­ one for base metal material and one for the applicable coating. Coating shall be reported in their cured state, and not as with the chemistry of the process chemicals or products.

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

Rejection codes Many reporting errors are similar in nature. To reduce the amount of time and detail required to reject an IMDS submission, effective November 1, 2005 Keykert/Kiekert will begin utilizing a code system for rejecting IMDS submissions. When applicable, the code table listed below will be used to reject incorrect submissions; however, when a more descriptive reason for a rejection is required, the additional information will be detailed on the IMDS rejection screen.

Rejection Non-ILI metal used without prior Keykert USA approval Part number incorrect / incomplete Part description incorrect / incomplete Misc. substance exceed 10% Submission inconsistent with drawing and/or documentation Improper tree structure (including use of semi-components) Prohibited/Declarable substance exceeds threshold limitations Material substances not fully disclosed MDS submitted to wrong ID Min/Max variation % exceeds allowable range (max +/- 5%) Recyclate information missing for plastic parts Missing certification for marking of polymeric parts Measured weight tolerance shall not exceed +/- 5% Drawing and reporting weight difference is exceed +/- 10% **

Code 010 020 022 030 040 050 060 070 080 090 100 110 120 130

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

Reasons / codes for IMDS rejections: Usage of non ILI-metals w/o previous Keykert approval (code 010) Incorrect part number format used (code 020): o Part number shall be detailed as 10-digits without spaces, dashes or symbols (i.e. 4700201003) Detailing incorrect part name/description (code 022) o All submission must have a Keykert/Kiekert part name/description as detailed on the drawing Exceeding the allowable misc. declaration of 10% per material (code 030) including, but not limited to: o Pigments portions or flame retardants o Plasticizers, or further additives Materials and/or documentation discrepancies (code 040) o Material certs do not match IMDS submission and/or material detailed on drawing Incorrect tree structure (code 050) o Materials listed without substances o Materials listed as components o Parts created as semi-components Prohibited or Declarable substances exceeds threshold limits (code 060) Material substance are not fully disclosed (code 070) o Iron missing in steel o Plating not disclosed o Labels/Stickers (that remain affixed to the component) Part submitted to wrong IMDS ID (code 080) Basic substance min/max variation exceeds allowable range (code 090) o Substance content Allowable range · Up to 10% ± 1% · 10-20 % ± 2% · 20-50% ± 3% · 50-100% ± 5% *Note: Ranges above are for metals only - not plastics. See Recommendation 010 for the allowable ranges of plastics. Recyclate information missing (code 100) Certification missing for marking of Polymeric Part (code 110) Measured weight tolerance exceeds +/- 5% (code 120) When the difference between calculated mass on drawing and measured weight in IMDS exceeds +/- 10% (code 130)** **Exception: When weight is defined as a CC the +/- 10% rule does not apply. In cases, when a tolerance is permissible it shall be specified on the drawing. When a submission is rejected, a new (corrected) submission is required within three business days. An action plan detailing corrective action is required if a new (corrected) submission cannot be completed within three business days. Rev-01 Released 10/28/2005 10 Printed Copies are Uncontrolled

IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01 IMDS Tree Symbols and Structure Illustrations

Component Material Semi-Component Substance N/A for Keykert/Kiekert submissions

Illustrations of Correct IMDS Tree Structures

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Illustrations of Incorrect IMDS Tree Structures

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

Training information www.mdsmap.com

www.imds-elearning.com

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

Keykert USA's Contact List Tracey Herrod Standards and Materials Coordinator 46941 Liberty Drive Wixom, MI 48393 Phone: 248-960-4100 Fax: 248-960-5393 Email: [email protected] Dennis Cruz Director of Purchasing 46941 Liberty Drive Wixom, MI 48393 Phone: 248-960-4100 Fax: 248-960-5368 Email: [email protected] Ernie Mullins Quality Manager 1101 Highview Drive Webberville, MI 48892 Phone: 517-521-1700 Fax: 517-521-5296 Email: [email protected]

Kiekert de México Contact List Tracey Herrod Standards and Materials Coordinator 46941 Liberty Drive Wixom, MI 48393 Phone: 248-960-4100 Fax: 248-960-5393 Email: [email protected] Victor Romero Purchasing Manager KM 14.5 Autopista Puebla-Orizaba Chachapa, Pue. México CP 72990 Phone: 52-222-8918428 Fax: 52-222-8918427 Email: [email protected] Miguel Martell Quality Manager KM 14.5 Autopista Puebla-Orizaba Chachapa, Pue. México CP 72990 Phone: 52-222-8918421 Fax: 52-222-8918404 Email: [email protected]

Send ALL restricted/reportable and IMDS questions and correspondence to [email protected]

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01 Appendix A Declarable / Prohibited Substance Reporting and Approval Form

All prohibited substances must be declared and approved by Keykert USA prior to use. Declaration shall be made via the: Declarable/Prohibited Substance Reporting & Approval Form (also known as DPS form) When declarable or prohibited substances are present, the form must be completed and submitted early in the development phase of a program. The DPS form is available on-line @ http://supplier.keykertusa.com When to submit a DPS A DPS form is required: When a supplier creates metals (non-ILI metals) in IMDS When Keykert is design responsible but the supplier's processes are inclusive of substances that are declarable or prohibited in accordance to the GADSL list and/or customer specific requirements (DPS required upon business award) When Keykert is not design responsible and the supplier's materials or processes contain substances that are either declarable or prohibited in accordance to the GADSL list and/or customer specific requirements (DPS required upon business award) How to complete and submit a DPS A supplier can complete a DPS form in one of two ways: By component/per material, or By material (blanket approval) for multiple components (in cases where a supplier uses the same material for multiple components) To submit a DPS form by component ­ per material Complete the DPS form (including applicable part numbers and revision levels) Ensure substance weight percentages total 100% Detail purpose or usage for all declarable or prohibited substances Select the applicable destination location All materials detailed on the DPS form shall match materials detailed on material certifications (trace amounts can be detailed as misc. up to 10% as long as the substances are not prohibited or declarable) Submit the completed DPS form and applicable material certification(s) to Keykert USA for review and approval.

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

By material (blanket approval) for multiple components Create Material and Development Sample Report in IMDS Complete DPS form Ensure substance weight percentages total 100% Detail purpose or usage for all declarable or prohibited substances Select the applicable destination location Materials reported on the DPS form must match materials detailed on material certifications (trace amounts can be detailed as misc. up to 10% as long as the substances are not prohibited or declarable) Submit the completed DPS form, a material certification for the requested material, a copy of the IMDS Initial Sample Test Report, and the IMDS ID version to Keykert USA for review and approval. In order to certify a material for multiple components, the supplier must submit both the IMDS version and the Initial Sample Test Report for the material. When the material is approved all applicable components may be submitted with the approved material (with the same IMDS version number). When the material changes (i.e. new version created in IMDS) the supplier is required to submit an updated DPS form, material certification, sample test report, and the new IMDS version number to certify the material.

Send completed DPS forms and all applicable material certifications to [email protected]

All forms will be reviewed within the APQP process to ensure "substances of concern" are eliminated when required and/or minimized to allowable percentages when feasible. In order to allow for a timely review, supplier must submit all DPS forms and/or IMDS submissions (with all supporting documentation) at least four weeks prior to the PPAP due date.

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Use "By Component" tab for by component per material DPS submissions. An electronic copy of this form is available on-line @ http://supplier.keykertusa.com

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Use "By Material" tab for blanket approval of a material DPS submissions. An electronic copy of this form is available on-line @ http://supplier.keykertusa.com

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01 Appendix B Definitions

Basic substances ­ chemical elements or chemical compounds as they exist naturally or are produced, this includes stabilizing agents and production-related impurities (with the exception of solvents) which can be separated without any effects on stability or change in composition. *Note 1: Substances cannot be directly attached to a component or semi-component, they must be attached to a material. *Note 2: Substances shall be reported in their cured state. Component ­ is a complete assembly or a component within an assembly that builds up a complete part. Declarable/reportable substances ­ are permissible within set limitation but must still be declared. Material ­ composition of a component or semi-component, and consisting of one or more basic substances. Prohibited substances ­ are prohibited for all or certain application purposes by law. They may not be contained in amounts, which exceed their set limitations. Material Data Sheet (MDS) ­ the complete description of a supplied product (can be a component semi-component or material). Pre-Consumer Recyclate (a.k.a post-industrial) - is recycled material from a manufacturing process that is subsequently used for a different manufacturing process, whether from the same company or scrap received from another company. Home scrap or regrind is NOT considered pre-consumer recyclate material. PreConsumer Recyclate is reported as the percent of the material's weight that is preconsumer recycled material. Post-Consumer Recyclate - is recycled material originating from products or materials that have served their intended end use, and have been recovered or otherwise diverted from the waste stream for the purpose of recycling. *Note: Pre and Post Consumer Recyclate is not applicable for any Keykert/Kiekert components (as detailed on Keykert drawings per WI-0069). Semi-component ­ an item becoming a component through a further processing step, like cutting to size. It is otherwise identical to a component, but does not have a fixed weight until it is attached to the assembly level part. Rev-01 Released 10/28/2005 19 Printed Copies are Uncontrolled

IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

*Note: A semi-component as defined in IMDS is not applicable for any Keykert/Kiekert part; therefore, it shall not be used in any submission to Keykert/Kiekert. Recycled Material Content Recycled content (post-industrial and post-consumer) is required for all non-metallic parts (e.g. polymeric materials ­ plastics and elastomers). Detail zero in the appropriate fields for metallic parts.

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01 Appendix C Examples of common reporting errors

Creating and reporting materials with a specification number instead of the material name (steel detailed as SAE J403 instead of 1010 Hot Rolled, or plating detailed as GMW3359 instead of Zinc Plating) Example 1 Materials may not be detailed with the specification number as the material name. The material name should be descriptive enough so that the material is easily identifiable (e.g.: plating or zinc plating). Specification numbers must be detailed in the "Norms/Standards" section.

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Exceeding allowable 10% joker/miscellaneous requirement: Example 2

Note: The content of the two joker materials is 20%, which exceeds the maximum allowable 10% misc. allowed per component. Example 3

Note: The content of the joker and confidential materials exceeds the maximum allowable 10% misc. allowed per component.

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01 Appendix D Conducting an ILI-Metals material search

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IMDS Reporting Requirement Specification KEYKERT 4904 2004 rev-01

Revision History Revision Date 10/01/2004 10/03/2005 Revisions -Initial release of IMDS Reporting Requirement Spec 4904 2004 -Replaced reference to ILRS with GADSL -Added rejection code table -Updated submission requirements -Updated DPS form -Revised DPS reporting requirements -Updated correct/incorrect IMDS tree structures -Move IMDS definitions to Appendix B -Added appendix D ­ Searching for ILImetals -Added Reference to Recommendations 003 and 010 for plastics and rubbers -Added reporting requirements for coatings and platings -Added Table of Contents Revision Level 00 01 Release Date 10/15/2004 10/28/2005

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