# GM GMW3059 ## Customer & Industry Requirements ###### Restricted and Reportable Substances for Parts ## GM Requires Full Material Disclosure on Every Part You Ship. Can You Prove Compliance Across Your Entire BOM? GM GMW3059 compliance demands substance-level reporting through IMDS for every component, assembly, and material supplied to General Motors globally. The CG4110 substance list updates without fixed schedules—adding new prohibited and declarable substances tied to evolving regulations like REACH, RoHS, and PFAS restrictions. Suppliers must submit complete material data sheets before PPAP approval, and any composition change triggers mandatory resubmission. Certivo automates restricted substance tracking from supplier declaration through IMDS-ready validation and OEM evidence generation. ## GADSL + CG4110 ### Substance lists governing prohibited and declarable thresholds - **0.1% w/w**: Reporting threshold for declarable substances in homogeneous materials. - **100%**: Full material composition disclosure required via IMDS. ## Regulation Overview - **Jurisdiction**: United States / Global (GM OEM-specific, applied across all GM supply regions) - **Regulatory Body**: General Motors – Materials Engineering, North American Engineering Standards - **Regulation Number**: GMW3059 (with CG4110 supplement) - **Effective Date**: May 1998 (latest published revision: Issue 16, 2018; CG4110 updated periodically) - **Official Source**: [www.gmw3059.com](https://www.gmw3059.com/) / [www.mdsystem.com](https://www.mdsystem.com/) (IMDS) - **Key Threshold**: 0.1% w/w in homogeneous materials for declarable substances ## What Is GM GMW3059? GM GMW3059 is General Motors' worldwide engineering standard for restricted and reportable substances and the cornerstone of GM's chemical compliance requirements. For supply chain teams, the primary obligation is managing substances classified as Prohibited (P) or Declarable (D) under GM's CG4110 substance list—chemicals restricted due to health, environmental, or regulatory concerns. CG4110 incorporates the Global Automotive Declarable Substance List (GADSL) by reference and adds GM-specific requirements including conflict minerals, recycled content, and biocide reporting. GM updates CG4110 to reflect evolving regulations including EU REACH, EU RoHS, and emerging PFAS restrictions. Companies supplying parts to GM containing declarable substances above 0.1% w/w must report full material composition through IMDS and comply with the prohibited substance waiver process. ## Key Components / Sub-Frameworks - **Obligation**: Defines compliance framework, IMDS reporting requirements, waiver process - **GMW3059 (Base Standard)**: Master specification governing restricted and reportable substances - **Obligation**: Substance-level reporting; prohibited substance waiver via Appendix A - **CG4110 (Substance List)**: Detailed list of prohibited (P) and declarable (D) substances with thresholds - **Obligation**: All GADSL-listed substances must be reported per classification thresholds - **GADSL Integration**: Global Automotive Declarable Substance List incorporated by reference - **Obligation**: Mandatory for all components; required before PPAP approval - **IMDS Reporting**: International Material Data System submission for full material disclosure - **Obligation**: Declaration and due diligence through GM supply chain channels - **Conflict Minerals**: Reporting of tin, tantalum, tungsten, gold (3TG) per Dodd-Frank / OECD guidance - **Obligation**: Required to support GM sustainability targets and ELV obligations - **Recycled Content**: Reporting of recyclate use in IMDS submissions ## Key Compliance Requirements ### Who Must Comply - All Tier 1, Tier 2, and sub-tier suppliers providing materials, components, or assemblies to GM globally - Suppliers of "black-box" items where the supplier holds the design - Aftermarket component and accessory suppliers shipping to GM - Suppliers of carryover parts carried into new model years or platforms - Resourced or redesigned component suppliers inheriting prior part obligations - Raw material and chemical suppliers providing inputs to GM-bound components ## Key Thresholds #### 0.1% w/w - Reporting threshold for declarable (D) substances in homogeneous materials #### Prohibited (P) - Substance banned for all or specific automotive uses; requires GM waiver (Appendix A) if present #### 10% wildcard limit - Maximum percentage of material composition reportable under IMDS generic wildcards #### 100% disclosure - Full material composition required in IMDS—no unreported content above wildcard allowance ## Core Obligations 1. **IMDS Full Disclosure**\n `Submit complete material composition for every supplied part via IMDS` **DEADLINE**: Before PPAP approval; updated upon any composition change 2. **CG4110 Substance Reporting**\n `Report all GADSL and CG4110 substances exceeding threshold limits` \n **DEADLINE**: At initial submission and upon any list update 3. **Prohibited Substance Waiver**\n `Submit Appendix A waiver with GM Materials Engineering sign-off for any P-classified substance` \n **DEADLINE**: Prior to delivery of affected parts 4. **Recycled Content Reporting**\n `Declare recycled content in IMDS submissions per GM requirements` \n **DEADLINE**: With each IMDS submission 5. **Composition Change Notification**\n `Update IMDS submissions after any material composition change or CG4110/GADSL update` \n **DEADLINE**: As soon as possible after change ## GMW3059-Specific Pain Points ###### The CG4110 Update Cascade GM updates CG4110 to reflect new regulatory developments—REACH SVHC additions, RoHS exemption changes, PFAS restrictions. Each update potentially affects thousands of parts across your portfolio. Without automated regulatory intelligence and horizon scanning, your team discovers updates weeks late, then spends months tracing which parts contain newly restricted substances. ###### The IMDS Submission Bottleneck GM requires 100% material composition in IMDS before PPAP approval. Your Tier 2 supplier sends a PDF declaration in Korean. Another sends an Excel file missing CAS numbers. A third uses proprietary material codes with no substance breakdown. Your team manually re-enters data into IMDS for 500 parts, introducing transcription errors that trigger GM rejections and delay production launch. ###### The 0.1% Threshold at Homogeneous Material Level GMW3059 applies the 0.1% reporting threshold at the homogeneous material level—not the part or assembly level. A trace additive in a coating, a plasticizer in a seal, or a flame retardant in a connector housing can each individually trigger reporting obligations. ###### The Multi-Regulation Overlap Burden GMW3059 does not exist in isolation. The same parts shipped to GM must comply with overlapping regulations. Suppliers often collect separate declarations for each framework from the same suppliers, increasing the risk of conflicting submissions across regulatory systems. ## Certivo in Action ### Certivo Workflow Summary - **Collect Substance Declarations**: Launch campaigns to collect material composition data from your entire supplier base. - **Extract Substance Data**: Validate against current CG4110 and GADSL substance lists. - **Generate IMDS-Ready Data**: Produce validated material data sheets and OEM evidence packages quickly. ## Related Regulations Certivo validates one submission against multiple OEM and regulatory requirements through AI-native compliance automation.