MITSUBA GROUP
GREEN PURCHASINGGUIDELINE
Version 4.1
The environmental requirements for suppliers.

October 2020

MITSUBA CORPORATION© 2020, MITSUBA Corporation - All rights reserved.

1

INTRODUCTION

Today, the awareness towards environmental concerns has been raised even more in thewhole society, while the company, as well, is strongly being demanded to create arecycling-oriented society.

We have addressed a decrease in environmental burdens as one of the most critical businesschallenges because we think that we should seek for the environmental management bearing
always in mind what a society really desires.

Our products are being realized using materials delivered from a number of our suppliers. For
this reason, our in-house environmental management activities will not be good enough toreduce environmental burdens; it will absolutely be imperative to realize environmental
management activities based on supply chain involving our suppliers.

In addition, global production and sales have been increasing more than ever.

Under such circumstances, we will continue our efforts for environmental burden reduction by
establishing and maintaining the Environmental Management System for worldwide supply
chain.

Your understanding and support will be greatly appreciated for our approach to the global
environmental protection.

© 2020, MITSUBA Corporation - All rights reserved.

2

INDEX
1. POSITION OF THIS GUIDELINE ..................................................................... 4
2. BASIC STANCE OF MITSUBA GROUP .......................................................... 5
2.1

CORPORATE PHILOSOPHY ..................................................................................... 5

2.2

ENVIRONMENTAL DECLARATION .......................................................................... 6

2.3

ACTION GUIDELINE.................................................................................................. 6

3. APPROACH TO ENVIRONMENT OF MITSUBA GROUP ................................ 7
3.1

ESTABLISHMENT OF EMS ....................................................................................... 7

3.2

SUBSTANCE OF CONCERN (SOC) MANAGEMENT ............................................... 7

4. POLICY OF GREEN PURCHASING ................................................................ 7
5. REQUIREMENTS TO SUPPLIERS .................................................................. 8
5.1

ESTABLISHMENT OF EMS ....................................................................................... 8

5.2

SOC MANAGEMENT ................................................................................................. 8

5.3

5.4

5.2.1

INTENDED SCOPE........................................................................................... 8

5.2.2

RESTRICTED SUBSTANCES LIST OF MITSUBA .......................................... 8

5.2.3

SOC MANAGEMENT SYSTEM ........................................................................ 9

INVESTIGATION ON SOC ......................................................................................... 9
5.3.1

SUBMISSION OF EVIDENCE .......................................................................... 9

5.3.2

SUBMISSION OF IMDS DATA ......................................................................... 9

5.3.3

SPECIFIED CHEMICAL SUBSTANCES ........................................................ 10

SUBMISSION OF DECLARATION .......................................................................... 10

6. APPENDICIES ............................................................................................... 10
7. CONTACT FOR INQUIRIE ............................................................................. 11© 2020, MITSUBA Corporation - All rights reserved.

3

1. POSITION OF THIS GUIDELINEMITSUBA Group Green purchasing guideline clarifies basic approach to environment which is commonlyused in MITSUBA Group companies; besides, it explains requirements from MITSUBA Group to suppliers.
Japan

MITSUBA Corporation
Tatsumi Corporation
Higashinihon Diecasting Industry Co., Ltd.
Momimo Manufacturing Co., Ltd. [Toyo Electric Manufacturing Co., Ltd.
Sun-You Corporation
Oshima Electric Works Co., Ltd
AMCO Corporation
Mitsuba Sankowa Corporation
Mitsuba Logistics Co., Ltd

America

U.S.A.

American Mitsuba Corporation.

MexicoCorporacion Mitsuba de Mexico, S. A. DE C. V.

BrasilMitsuba do Brasil Ltda.
Mitsuba Autoparts do Brasil Indústria Ltda

Europe

Asia

Italy

Mitsuba Italia S.p.A.

Hungary

Mitsuba Automotive Systems of Europe Kft.

FranceMitsuba Manufacturing France S.A.

TurkeyMitsuba Turkey Otomotiv A.S.

ThailandThai Summit Mitsuba Electric Manufacturing Co., Ltd.

Philippines

Mitsuba Philippines Corporation

VietnamMitsuba Vietnam Co., Ltd.

India

Mitsuba India Private Ltd.

Indonesia

PT. Mitsuba Indonesia
PT. Mitsuba Automotive Parts Indonesia

Asia

China

Guangzhou Mitsuba Electric Co., Ltd.
Guangzhou Mitsuba Electric (Wuhan) Co., Ltd.
Mitsuba Electric (Dalian)Co., Ltd.
Mitsuba Shihlin Electric (Wuhan) Co., Ltd.
Mitsuba China (Hong Kong) Ltd.
Changzhou Shihlin Mitsuba Electric & Engineering Co., Ltd.

AfricaMoroccoMitsuba Morocco SARL AU

RussiaRussiaMitsuba Rus LLC

See website of MITSUBA Corporation for companies of MITSUBA Group. (http://www.mitsuba.co.jp)© 2020, MITSUBA Corporation - All rights reserved.

4

2. BASIC STANCE OF MITSUBA GROUP
2.1

CORPORATE PHILOSOPHY

Mission Statement

Together with those who support it, MITSUBA will provide
pleasure and peace of mind to the people of the world bycreating technology in harmony with society and theenvironment.

Management Policy

1.
2.
3.

We will make MITSUBA the brand of choice on a global scale.
We will use our technology as a driving force to take up the challengeof creating new markets.
MITSUBA will bring out the best in its associates, as its associates
bring out the best in Mitsuba.

Guidelines for Action

VisionChallenge
Speed
Remaining true to our vision, we will respond to each challenge
in a determined and Speedy fashion.

Company message

The Spirit of Technological Growth.

© 2020, MITSUBA Corporation - All rights reserved.

5

2.2

ENVIRONMENTAL DECLARATION

Environmental Declaration
We will work to achieve a continuous harmonization with our natural environment by means oftechnical developments harmonized with society and the environment.
1.

We will endeavor to save resources and energy in all its corporate activities, including
development, production and sales.

2.

We will endeavor to reduce waste materials and polluting substances as well as achieve correct
processing of those materials.

3.

We will endeavor to achieve harmony with the local environment while also endeavoring to secure
a living environment where all can live in peace.

2.3

ACTION GUIDELINE

The action guideline is a concrete guiding principal to move the “Environmental Declaration” into action.

Environmental Action Guideline
1. We will attempt to make sparing and effective use of limited resources.
2. We will endeavor to save on energy in our corporate activities, in order to fulfill our corporate
responsibilities with regard to global warming.
3. We will endeavor to find substitutes for ozone destroying substances in order to protect the ozone
layer.
4. We will manage chemical substances properly and use abolition of harmful chemical substances
including not using it for our products.
5. We will establish an environmental management system and endeavor to observe in company
regulations that are stricter than public laws.
6. We will positively participate in social activities relating to the environment.

© 2020, MITSUBA Corporation - All rights reserved.

6

3. APPROACH TO ENVIRONMENT OF MITSUBA GROUP
3.1

ESTABLISHMENT OF EMSMITSUBA Group considers global environmental protection as an important management issue, so that westarted establishing EMS: Environmental Management System from 1997 to make continued efforts to
reduce environmental burdens. These activities include not only prevention of global warming and natural
resources saving with emissions recycling, but also reduction of environmental burdens related to theoperation of respective companies and departments.

The perspective of Life Cycle Assessment (LCA) with regard to not only production step but also use anddischarge step of the product is crucial to achieve continuous reduction of environmental burdens which iscontemplated by ISO14001 Environmental Management System. We will work on this task.

3.2

SUBSTANCE OF CONCERN (SOC) MANAGEMENT

Since “Agenda 21: Sound Management of Hazardous Chemicals“ was adopted by Rio Summit (UNConference on Environment and Development) in 1992, the management of chemicals, especiallyhazardous substances included in waste material of vehicles and home electric appliances, has been acritical issue of concern around the world.

As for automobiles, there exist “EU ELV Directive 2000/53/EC”, “RoHS Directive 2002/95/ EC”, “Act on the
Evaluation of Chemical Substances and Regulation of Their Manufacture, etc.” of Japan, and “EU REACH
regulations EC 1907/2006” etc.

We will set forward the management of chemicals included in our products and establishing of SOC
management system for the whole supply chain.

4. POLICY OF GREEN PURCHASING
Previously, we had asked our suppliers for its cooperation as to quality, cost and delivery due date.
However, what the society is now asking for our products is the reduction of environmental burdens basedon life cycle which consists of procurement including supply chain production, us e and discharge. In
concrete terms, chemical management of products, resource savings, energy savings and prevention ofenvironmental pollution.
In order to respond to these demands, we must seek your support for green purchasing.

© 2020, MITSUBA Corporation - All rights reserved.

75. REQUIREMENTS TO SUPPLIERS
5.1

ESTABLISHMENT OF EMS(1)Establish EMS: Environmental Management System that meets ISO14001 or what is equivalent to theformer.

(2)

Acquisition of such certification systems as Eco Action 21, Eco Stage and Environmental
Management System Standard (KES) in Japan will also be considered as that Environmental
Management System is already built as with the acquisition of ISO14001.

(3)

Likewise, regulations for small and medium scale businesses established in other cou ntries having
fewer burdens are acceptable as well.

(4)

Proceed with activities related to environmental conservation in case of not yet being certified.
(Development of objective and action plan, role sharing, compliance with regulations, reduction ofenergy, reduction of waste, management of chemicals, environmental education, audit, etc.)
The detail is shown in Appendix 2 “EMS: SELF ASSESSMENT CHECKLIST”.

5.2

SOC MANAGEMENT

5.2.1 INTENDED SCOPE(1)Object of SOC management is what MITSUBA Group companies procure.

a

Materials and parts Including the ones not for auto parts and samples.

b

Sub materials Solder, Adhesive, Grease, metal working lubricant, tape, marker, etc.

c

Packing material Including not only carton but shocking absorber, band and ink etc.

5.2.2 RESTRICTED SUBSTANCES LIST OF MITSUBA
Comply with the Restricted Substances List of MITSUBA specified in MES A015 “Restricting the use ofhazardous substances”.
*The list consists of the tables 1, 2 and 3.
Table

Class

Description

Table 1GADSL (Global Automotive

List of prohibited and declarable substances created by Global

Declarable Substance List)

Automotive Stakeholder Group (GASG) consisting of automotive(including substances whose

manufacturers and their suppliers in Europe, the USA, and Japan.

classifications are modified

The GADSL is revised on a periodic basis. This guideline shall always

by MITSUBA)

refer to the latest version. (For details, see the URL below.)
GADSL URL: http://www.gadsl.org/

Table 2

List of Voluntarily Prohibited

List of substances that Mitsuba voluntarily designates as “prohibited”

Substances Not Covered bywhile they are not listed in GADSL.

GADSLTable 3REACH Substances List

List of authorized substances whose use is restricted by REACH.

© 2020, MITSUBA Corporation - All rights reserved.

8

TableClass

Description
New application of the substances in the list will be prohibited at thetime of issue of this standard.
Current application of the substances will also be prohibited after thesunset dates, regardless of destination or SOP timing.
However, the substances currently prohibited in Table 1 and Table 2 by
MITSUBA are not included in this List.
For details, refer to European Chemicals Agency (ECHA) website.

5.2.3 SOC MANAGEMENT SYSTEM(1)

Establish SOC Management System.
(Clarification of role sharing, human development, control criteria, supplier management, parts control,internal audit, etc.)(2)

See Appendix 3 “SOC MANAGEMENT SYSTEM REQUIREMENTS” for the further retails.

(3)

We may perform audit of your SOC Management System.

5.3

INVESTIGATION ON SOC

5.3.1 SUBMISSION OF EVIDENCE(1)

We will request our suppliers to submit some evidence to prove non-inclusion of specified SOC,
according to the request from our customers or in case that we consider that its necessary.

(2)

The evidence to prove non-inclusion of SOC is an analysis data which indicates that only sub
threshold SOC is contained. Four substances specified in ELV Directive (Pb, Cd, Hg, Cr6+) are
subject to this requirement. We will request you to submit the same evidence clarifying a substancename in case of other substance.

(3)

We will make a request on a case by case basis if our customer specifies types of analysis equipment,
ISO17025 Certification of laboratory, analysis date and language to be used etc.

5.3.2 SUBMISSION OF IMDS DATA
(1)IMDS (International Material Data System) data signifies complete constituent data by deliveredmaterial, which is reported by such tools as IMDS system, JAPIA Standard Material Datasheet etc.

(2)

We will request you to report a material constituent in IMDS data. Especially, constituent specified inTable 1 (GADSL) in MES A015 “Restricting the use of hazardous substances” must be reported
regardless of quantity.

(3)

It is allowed not to disclose up to 10% of constituents treating it as MISC (others) in case you cannot
give a full disclosure for confidentiality reasons. In such case, grand total should be 100% summing© 2020, MITSUBA Corporation - All rights reserved.

9up MISC and disclosed part.
Also note that MISC should not include any prohibited substance specified in Table 1 in MES A015
“Restricting the use of hazardous substances”.

(4)

We will request you to report again in case that an undisclosed constituent treated as MISC becomes
declared substance due to the revision of Table 1 (GADSL) in MES A015 “Restricting the use ofhazardous substances” or in the case of any changes in the declared details due to material changes.

(5)

It will eventually be necessary to collect data from material suppliers through supply chain to prepare
IMDS data; it is advisable to try to collect data of delivered materials on a regular basis regardless ofrequirement to submit report.
In addition, IMDS data will be required to obtain model certification for vehicle. We will seek our
suppliers’ support to meet the submission deadline.

5.3.3 SPECIFIED CHEMICAL SUBSTANCES(1)

Due to legislative trends regarding chemicals in the countries, we may ask our suppliers help to dosome survey on whether specific chemical substance is being used or not, based on requirementsfrom customers or at the discretion of us In such cases, we will seek our suppliers support to makeinquiries to material suppliers etc.

5.4

SUBMISSION OF DECLARATION(1)

We will request our suppliers to pledge that no chemicals prohibited by the Restricted Substances Listof MITSUBA specified in MES A015 “Restricting the use of hazardous substances” are included in thepurchased product delivered from them and that substances required to be reported should be
declared regardless of quantity used.

(2)

We will request our suppliers to submit “Declaration”, according to the request from our customers orin case that we consider that its necessary.

(3)

Please report using a supporting data: Appendix 1 “DECLARATION OF CONFORMITY TO THE
MITSUBA CHEMICALS REGULATION”.

6. APPENDICIES(1)Appendix 1 “DECLARATION OF CONFORMITY TO THE MITSUBA CHEMICALS REGULATION”(2)

Appendix 2 “EMS: SELF-ASSESSMENT CHECKLIST”(3)

Appendix 3 “SOC MANAGEMENT SYSTEM REQUIREMENTS”(4)

Appendix 4 “GLOSSARY”© 2020, MITSUBA Corporation - All rights reserved.

10

MITSUBA Group Green Purchasing Guideline is disclosed at web site of MITSUBA Corporation:
http://www.mitsuba.co.jp/purchase/index.htm

7. CONTACT FOR INQUIRIE
Submit inquiries related to this guideline to the contact below in English or Japanese.

Attn: Purchasing Planning Section, Purchasing Department
E-mail: greenkobai@mitsuba.co.jp
TEL: +81-277-52-0171, FAX: +81-277-54-6920© 2020, MITSUBA Corporation - All rights reserved.

11

Appendix 1

Attn: MITSUBA Corporation, Purchasing Dept. (When submitting to MITSUBA Corporation)

DECLARATION OF CONFORMITY TO THE “MITSUBA CHEMICALS REGULATION”

We will pledge that no chemicals prohibited in the Restricted Substances List of MITSUBA
specified in MES A015 “Restricting the use of hazardous substances” are included in thepurchased products (raw material, part, auxiliary material, product, equipment and supply)
which we are currently delivering and will deliver in the future, and that we declare the quantityof the substances required to be reported when the quantity we use exceeds the threshold.

We also pledge to observe this guideline as to prohibited substances and substances required
to be reported which will be added in the future GADSL revision.

Fill out date

Supplier nameName of person in charge

Signature© 2020, MITSUBA Corporation - All rights reserved.

12Appendix 2_EMS: SELF ASSESSMENT CHECKLIST(Please fill out below in the case of not being certified according to ISO14001 or equivalent .)

№

Item

ISO requirements(Reference)

1

Environme
ntal policy

Environmental
policy (4.2)

2

Plan/OrganizationObjective, Target
and Action plan
(4.3.3)

3

Environme
ntal impact
assessme
nt/Operati
on andmaintenance control

4Complianc
e

5

Risk
management

6

Enlighten
ment/Discl
osure ofinformation7

Responsetonon-confor
mity

8

9

Self-evalu
ation
Documents control

Environmental
aspect (4.3.1)/
Operation andmaintenancecontrol (4.4.6)/
Surveillance andmeasurement(4.5.1)

Legal and otherrequirements(4.3.2)/Complianceevaluation (4.5.2)
Preparation andresponse to
emergency (4.4.7)
Competence,
Education Training
and Consciousness(4.4.2)/
Communication(4.4.3)
Non-conformity
andcorrective/preventi
ve action (4.5.3)
Environmental
Management
System audit(4.5.5)/
Management
Review (4.6)
Documents (4.4.4)

Evaluation criteria
1) There is a company philosophy regarding environmental
conservation.
2) Policy on environmental conservation is already established and
it is pledge d on continuous improvement and pollution prevention.
3) It is pledge d on observation of regulations throughenvironmental policy.
4) Environmental policy is documented, communicated to all theemployees and accessible to the third party.
1) There are objectives as well as target to achieve policy.
2) Organization and person in charge are clearly identified toachieve objective and target
3) There is an action plan in which means and method to achieve
objective and target are identified.
1) Impact by business activities on following items are evaluatedand identified; effort s for improvement are being made.
A. Air pollution
B. Water pollution
C. Noise/Vibration
D. Prohibited substance (See the List of regulated chemicals)
E. Wastes
F. Energy (Amount consumed of Electricity/Gas/Fuel etc.)
2) Supervisor is designated for specified phenomenon (including
machines/operation) control is in place.
3) There is product assessment mechanism to provide withenvironmentally friendly products

Eval.

―

1) Acts/codes and industry norms etc. related to environment are
identified; control is in place2) There is adequate control over facilities/ equipment regarding
related environmental laws.
1) Emergency response on environmental conservation is well
prepared having established procedure
1) Training programs necessary for personnel within the system
are identified and being implemented to achieve her/his objective.
2) Training programs especially for those who involve in some
operation causing huge impact on environment are being
implemented; a list of those operators is available.
3) Information on environmental conservation of the company isbeing disclosed.
1) Procedures to implement corrective/preventive actions in caseof non-conformity on Environmental Management System arealready established.
1) Self-evaluation on progress status of plan as well as
achievement status of objective are being implemented; evaluation
results are reported to directors.
2) Self-evaluation results are reflected in environmental policy,
plan and organization for continuous improvement.
1) Responsibility and procedures to implement previous questions
are determined and documented.

Note) Fill out in evaluation section. (Y: Yes / No: Not Applicable)© 2020, MITSUBA Corporation - All rights reserved.

13

Appendix 3_SOC MANAGEMENT SYSTEM REQUIREMENTS

1. Organizationa

Determine internal role sharing as to SOC Management.
E.g. Control of regulation/customer requirements, supervision/control of suppliers (when necessary)
input/control of data, etc.

2. Policya

The directors should give internal indications as to SOC Management.
E.g. Quality/Environmental Policy, or through meetings.

bDefine, when necessary, the degree of risk on SOC inclusion in material. (If a high risk component isused.)Note) Based on our experiences, there exist significant risks with plastic, paint, ink, marker, tape andplating in the case of being produced in developing countries and with PVC regardless of country oforigin.

3. Man/Machinea

Foster internal human resources who can judge if a material conforms or does not conform to the
SOC regulations and customer requirements.

b

Foster those who can operate IMDS or JAPIA Standard Material Datasheet which is a tool in
automobile industry.

c

Do adequate employees training on SOC according to business contents.

dEnable to do SOC analysis with internal equipment or by an external laboratory)

4. Management standardaInform all the employees of SOC related regulations and customer requirements as well as control
items within the company.

© 2020, MITSUBA Corporation - All rights reserved.

14

5. Customer responseaSubmit IMDS data of material and evidence to prove non-inclusion according to customer’s
requirements.
Note)
IMDS data: Specification of material chemical constituent.
Evidence: Analysis results of 4 substances specified in ELV directive for prove non -inclusion.

b

Control response to customer requirements to avoid delay. (Please inform in case of delay)

6. Product designaGive indications of SOC management as output of product design, if applicable.
E.g. Design and specification (in case of dedicating in product design)

7. Process designaGive indications of SOC management as output of process design.
E.g. Control plan, Work instruction sheet.
(Including sub material and packing material for exportation such as marker, ink etc.)b

Pay attention to incorrect use, mix, contamination and chemical changes, if applicable.
E.g. plating, soldering (in the case that there exists a risk due to incorrect use, mix, contamination andchemical changes)

8. Purchasinga

Add SOC Management status to the items of supplier selection and continuous evaluation.

b

Inform suppliers of SOC management standard of your company.
E.g. Green purchasing guideline(Except a case in which supplier is considered to have sufficient knowledge.)cVerify, when needed, management status of supplier by documents and visit etc.

d

Make a request at an early stage for suppliers to submit IMDS data and evidence to prove
non-inclusion of SOC (if necessary).
Note: IMDS data has come to be required for model certification of vehicle; it is getting to be required
before mass production start.

e

Obtained IMDS data among others should not be controlled as individual data but as internally shareddata.

© 2020, MITSUBA Corporation - All rights reserved.

15

9. Surveillance, MeasurementaConfirm, depending on material/component risk, that SOC is not included.
Note) Acquisition of complete constituent data of corresponding material and evidence to prove
non-inclusion of SOC; or analysis at your own or by third party.

10. History controla

Implement traceability control (usage history on material/component), if applicable.

11. Change controlaVerify SOC according to changes to be implemented in case that you would modify internal process,supplier or material.
E.g. Process audit, Acquisition of IMDS data/evidence to prove non-inclusion of Substance ofConcern, Material analysis, Process audit of suppliers.

12. Non-conforming productaDefine procedure when SOC related problems occur.
E.g. Rules on control of non-conforming products.

b

Report to your customers when SOC related problems occur.

13. Evaluation/ImprovementsaAudit internal SOC Management status on a regular basis.
E.g. Departments such as product design, process design, purchasing, production, inspection andshippingb

Report an audit result to directors to implement required improvements.

14. Analysis method of SOCaAnalysis method of SOC is as follows.
Qualitative
analysis
methodQuantitative
analysis
methodTarget elements
Lead, Cadmium, Mercury
All Chromium
All Bromine containing
fire retarding materials
Hexavalent chromium
Lead, Cadmium, Mercury
Hexavalent chromium

Analysis method
Xray fluorescence analysis method
Xray fluorescence analysis method
Xray fluorescence analysis method
Colorimetric test paper (Diphenylcarbazide method),
IEC 62321 (Spot test)
Inductively Coupled Plasma (ICP),
Atomic Absorption Spectroscopy (AAS)
Diphenylcarbazide spectrophotometric method(EN 15205. ISO 3613)© 2020, MITSUBA Corporation - All rights reserved.

16

Target elements
Bromine containing fire
retarding materials (PBB
and PBDE)b

Analysis method
Gas Chromatograph Mass Spectrometry (GC/MS)

Consideration of Qualitative analysis method
At the X ray fluorescence analysis, when the result shows that Chromium/Bromine is under thethreshold value, it means Hexavalent chromium/Bromine containing fire retarding material (PBB,
PBDE) is under the threshold value.
The color appears when Hexavalent chromium is about 200ppm by analysis method of IEC 62321.
IEC 62321 is effective for screening contains or not contain, but when Hexavalent chromium is
detected, quantitative analysis is necessary.

cConsideration of quantitative analysis method
We accept EN 15205 and ISO 3613 for Hexavalent chromium analysis method.
However when calculate ppm of Hexavalent chromium, the numerator is weight of Hexavalentchromium the denominator is weight of chromate film.
Some laboratory is calculating as weight of Hexavalent chromium divided by weight of chromate film
plus Zinc coating, but many customers do not accept.
If there are two results as per EN15205 and ISO3613, EN15205, which is recommended by manycustomers, has priority.
The threshold value of EN 15205 is 0.1μg/cm2 = 0.1 percent = 1,000 ppm.

d

Example of calculation

Chromate film

Hexavalent chromium derived 5µg from 50cm 2 surface area plating parts.
The quantity = 5µg / 50cm 2 = 0.1μg / cm2

Zinc Plating film

Thickness of chromate film: 0.2μm, Specific gravity: 5g/cm 3
Source: JIS H8625 “Chromate conversion coatings on electroplated zincand cadmium coatings”, and ISO3613 “Metallic and other inorganic coatings - Chromate conversion
coatings on zinc, cadmium, aluminum-zinc alloys and zinc-aluminum alloys - Test methods”.

Total mass of chromate film of 50cm 2 surface plating parts. Do not include Zinc coating.
= surface (50cm2) × chromate film thickness (0.2μm) × specific gravity (5g/cm 3)= (50cm2) × (0.00002cm) × (5g/cm 3) = 0.005g = 5,000μg© 2020, MITSUBA Corporation - All rights reserved.

17

Then ppm of Hexavalent chromium in chromate film (P) is,P = 5 / 5,000 = 0.001 = 0.1% = 1,000ppm

This means that when thickness of chromate film is 0.2μm, specific gravity is 5g/cm 3,0.1μg / cm2 = 1,000ppm© 2020, MITSUBA Corporation - All rights reserved.

18

Appendix 4_GLOSSARY

1. IMDS DATA
(1)IMDS data signifies constitutional component data of material used, which is sometimes called“environmental data”.
Case 1. Standard components of cold rolled steel plate (SPCC)
Component
Iron
Manganese
CarbonPhosphorus
Sulphur

CAS No.
7439-89-6
7439-96-5
7440-44-0
7723-14-0
7704-34-9

Content percentage (%)
99.55
0.30
0.075
0.050
0.025

Case 2. Component example of PET resin including 20% of glass
Component
Polyethylene Terephthalate
GF-FiberMisc., not to declare(2)

CAS No.
25038-59-9
systemContent percentage (%)
71
20
9IMDS data requires parts mass, percentage of recycle material used, and material identification etc.
as well as information specified above.

(3)

IMDS data is an ingredient specification of material. Please make inquiries to material manufacturers.

(4)

Some material ingredient is prohibited to use or required to be reported when used.

(5)

It is permitted not to disclose up to 10% of constituent treating it as MISC (others) in case you cannot
give a full disclosure for confidentiality reasons. In such case, grand total should be 100% summing
MISC and disclosed part up.
Also note that MISC should not include prohibited substance and substances required to be reported
which are stipulated in GADSL

2. GADSL(1)GADSL (Global Automotive Declarable Substance List) refers to the controlled chemicals list that iscommonly used across industries and that was established by auto manufacturer, auto components
supplier and chemical manufacturer. http://www.gadsl.org/(2)

Chemicals included in GADSL are classified into three categories:- P (Prohibited): Impossible to use in over threshold level or intentional.
- D (Declarable): Possible to use; but required to be report ed regardless of quantity used.
- P/D (Prohibited and Declarable): It depends on the chemical or the purpose.
For example, using asbestos (category P) is completely prohibited and lead (category P/D) is© 2020, MITSUBA Corporation - All rights reserved.

19

prohibited except for certain purposes such as for batteries.

3. IMDS SYSTEM(1)IMDS is a system to collect the complete integrant data efficiently.
It is a system to collect, through supply chain, information on materials and chemicals included inapproximately thirty thousand pieces of components constituting the vehicle, in order to response to
EU ELV Directive which includes regulations on SOC of new model vehicle, used cars and recycle
percentage etc. https://www.mdsystem.com/(2)

IMDS is an online system, so that it is required to be online all the time. In addition, it is necessary toregister a company ID etc.

4. JAPIA Standard Material Datasheet(1)

JAPIA Standard Material Datasheet having the same purpose as IMDS, is an agreed by Japan Auto
Parts Industries Association (JAPIA). http://www.japia.or.jp/(2)

JAPIA Standard Material Datasheet is an offline system, so that always on connection is not required
after having downloaded JAPIA Standard Material Datasheet.

(3)

JAPIA Standard Material Datasheet complies with IMDS.

5. Evidence to prove non-inclusion of SOC(1)

The evidence to prove non-inclusion of SOC is an analysis result on SOC included in material. SOC
usually means such substances as regulated by EU ELV Directive, which include Lead, Cadmium,Mercury and Hexavalent chromium.
Some clients have also added PBB and PBDE among Bromine containing fire retarding materials
which are regulated by EU RoHS.

(2)

SDS (Safety Data Sheet) is an instruction manual for users who actually handle those materials, sothat structural components are roughly described. For that reason, this sheet is inadequate as anevidence to prove non-inclusion. MIL Sheet is inappropriate as well because of the same reason.
MIL sheet does not work as an analysis result to demonstrate non-inclusion of Lead and Cadmium.

6. FYI: Case examples(1)

Product containing Hexavalent chromium was shipped because service parts were used as mass
produced products;(2)

Use of vinyl tape containing Lead produced prior to July 1, 2006 (when RoHS was started.)(3)

The judgment was failed because Bromine found by X ray fluorescence analysis (wrong inspection© 2020, MITSUBA Corporation - All rights reserved.

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method).

7. FYI: Case examples Use of SOC in the past
SOC gives a big impact on health and ecosystem, but on the other hand it has convenient aspects. As amatter of fact, it was used in diverse ways (and is still being used in some cases).

(1)

Lead was used for water pipes, lead pellets, toys, fishing weights and leaded gasoline as it is soft. For
automobile, Lead was used for lead battery, wheel balance weight, solder, shaft bearing, lamp glass,paint, plastic stabilizer, red and yellow colorant, rubber vulcanization accelerator, rubber stabilizer,
grease, carbon brush and free cutting steel. It means that recycled material can contain SOC in casethat low technical level is applied to recycling.

(2)

Cadmium was contained in Cadmium plating, Nickel-Cadmium rechargeable battery, polyvinyl
chloride stabilizer, colorant, brass impurities, silver solder impurities.
Recycled PVC carries a significant risk to include SOC. Old PVC material is, as well, at a h igh risk ofinclusion.

(3)

Hexavalent chromium was included in chromate coating on Zinc plating. Now it requires strict control.
Do not ship out goods plated with Hexavalent chromium.

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