# Komatsu Green Procurement Standards Compliance

## Customer & Industry Requirements

###### Komatsu Green Procurement Guidelines & KES 07.000.1 Restricted Substance Requirements

## Komatsu Requires Substance-Level Data from Every Supplier. Can You Deliver It on Demand?

Komatsu Green Procurement Standards compliance demands environmental management certification, restricted substance reporting via JAPIA or IMDS datasheets, and registration on Komatsu's General Data Management System for Substances of Environmental Concern (GDMS). Komatsu's Midori-kai supplier network spans five global regions—and procurement from member companies accounts for 74% of total spend. Non-compliance triggers corrective action, suspension, or termination. Certivo automates substance data collection, extraction, and OEM-ready reporting across Komatsu Green Procurement Standards requirements.

### See How Certivo Automates Komatsu Green Procurement Standards Compliance

- **2,700+** Primary suppliers in Komatsu's global construction and mining equipment supply chain.
- **74%** Procurement value sourced from Midori-kai member companies (FY2024).
- **5 Regions** Midori-kai chapters enforcing green procurement globally.

## Regulation Overview

- **Jurisdiction:** Global (OEM-specific, applied to all Komatsu suppliers worldwide)
- **Regulatory Body:** Komatsu Ltd., Procurement Division
- **Regulation Number:** Komatsu Green Procurement Guidelines (April 2023 Revision); KES 07.000.1
- **Effective Date:** Originally established under 1992 Komatsu Earth and Environment Policy; current guidelines revised April 2023
- **Official Source:** Komatsu Sustainability Disclosure Site
- **Key Threshold:** Substance-level compliance per KES 07.000.1 banned and limited-use substance list

# What Are Komatsu Green Procurement Standards?

Komatsu Green Procurement Standards are OEM-specific environmental and chemical compliance requirements imposed on every supplier in Komatsu's global supply chain. These standards extend the Komatsu Earth and Environment Policy—established in 1992—into enforceable supplier obligations covering environmental management systems, greenhouse gas reduction, resource recycling, water risk, biodiversity, chemical substance management, and conflict minerals due diligence.

For supply chain teams, the core obligation is managing environmentally hazardous substances per Komatsu's internal technical standard KES 07.000.1, which defines banned and limited-use substances aligned with EU REACH SVHC requirements, EU RoHS restrictions, and Japan's domestic chemical regulations. Suppliers must register substance data via JAPIA datasheets or IMDS into Komatsu's GDMS platform. Komatsu tracks 247 SVHCs as of May 2025 and requires BOM-level substance transparency across all production vehicles and newly developed products.

Komatsu Green Procurement Standards compliance requires substance-level data—CAS numbers, concentration percentages, and material composition—from every supplier across the chain. When regulatory lists update, entire product portfolios require reassessment.

## Key Components / Sub-Frameworks

- **Obligation:** Compliance with banned/limited-use substance list; substance-level reporting  
- **KES 07.000.1:** Komatsu technical standard restricting environmentally hazardous substances in products  
- **Obligation:** Mandatory substance data registration via JAPIA or IMDS datasheets
- **GDMS Registration:** General Data Management System for Substances of Environmental Concern  
- **Obligation:** Required for all Midori-kai members; recommended for all suppliers  
- **Environmental Management System:** ISO 14001 or equivalent third-party certification  
- **Obligation:** CO₂ reduction of 2.5% per year (per basic unit vs. 2020) for Midori-kai members  
- **GHG Reduction:** Greenhouse gas emissions reduction targets aligned with SBT  
- **Obligation:** Investigation and reporting of mineral origin and refiner information  
- **Conflict Minerals:** 3TG due diligence per Dodd-Frank Act and EU CAHRA requirements  
- **Obligation:** Incorporated into business contracts; violations may trigger termination  
- **CSR Procurement Guidelines:** Overarching supplier code covering ESG, governance, and compliance

## Komatsu's April 2023 Guidelines Added Water Risk and Biodiversity Obligations—Plus Strengthened GHG and Resource Recycling Requirements. Has Your Supplier Data Been Updated?

Komatsu revised its Green Procurement Guidelines in April 2023, adding water risk reduction and biodiversity conservation as new supplier obligations. GHG emissions reduction and resource recycling requirements were strengthened. Midori-kai members now face a 2.5% annual CO₂ reduction target. Komatsu's SVHC tracking covers 247 substances as of May 2025, and declarations collected before the revision are already incomplete.

## Key Compliance Requirements

# Who Must Comply

- All Komatsu Midori-kai member companies across Japan, China, Thailand, North America, and Europe
- Tier 1 suppliers of products, parts, raw materials, and sub-materials
- Facility and construction service contractors operating at Komatsu premises
- Logistics providers handling Komatsu product and parts distribution
- Non-Midori-kai suppliers identified by Komatsu for substance data registration
- Sub-tier suppliers receiving flowdown requirements from Tier 1 partners

# Key Thresholds

- **KES 07.000.1 substance limits:** Banned and limited-use substance concentration thresholds per Komatsu technical standard
- **ISO 14001 certification:** Required for Midori-kai members within three years of joining
- **2.5% annual CO₂ reduction:** Per basic unit compared to 2020 baseline, mandatory for Midori-kai members
- **JAPIA/IMDS registration:** Required for designated products, parts, and materials on Komatsu's GDMS

## Core Obligations

1. **Substance Data Registration**  
   `Register material composition via JAPIA or IMDS datasheets on Komatsu's GDMS`  
   `DEADLINE: As specified by Komatsu per product designation`
2. **KES 07.000.1 Compliance**  
   `Ensure all supplied products conform to Komatsu's banned/limited-use substance restrictions`  
   `DEADLINE: Ongoing; validated through business operations`
3. **EMS Certification**  
   `Obtain and maintain ISO 14001, Ecostage, or equivalent third-party certification`  
   `DEADLINE: Within three years of Midori-kai membership`
4. **GHG Reporting**  
   `Record and report CO₂ emissions from manufacturing and logistics activities`  
   `DEADLINE: Annual reporting cycle`
5. **Conflict Minerals Due Diligence**  
   `Investigate and report 3TG content and country of origin upon Komatsu request`  
   `DEADLINE: Upon request; ongoing management system required`

## Komatsu-Specific Pain Points

### The Multi-Standard Overlap Problem

Komatsu's KES 07.000.1 references EU REACH, EU RoHS, and Japanese domestic chemical regulations simultaneously. Suppliers serving multiple OEMs face conflicting restricted substance lists, different reporting formats, and overlapping but non-identical thresholds. Your compliance team maps the same substances against three frameworks manually—and still cannot confirm whether the Komatsu-specific list has been fully addressed.

### The JAPIA/IMDS Data Entry Bottleneck

Komatsu requires substance data registered via JAPIA datasheets or IMDS entries on the GDMS platform. Your engineering team spends days translating supplier declarations into JAPIA-compliant formats. Material composition data arrives in PDFs, Excel files, and freeform emails—none matching the required structure. One incorrect CAS number invalidates the entire submission.

### The Midori-kai Escalation Trap

Komatsu evaluates Midori-kai members on SLQDC performance—Safety, Lead time, Quality, Delivery, and Cost—alongside ESG compliance. A missed substance declaration does not just create a regulatory gap. It triggers an escalation that impacts your supplier tier status, access to global opportunities, and contract continuity. The commercial consequence of non-compliance extends far beyond a failed audit.

### The Sub-Tier Visibility Gap

Komatsu's conflict minerals and substance management obligations flow down to sub-tier suppliers. But most Tier 1 suppliers lack visibility into raw material origins and substance composition beyond their direct suppliers. Collecting 3TG origin data, refiner information, and substance declarations from Tier 2 and Tier 3 suppliers requires multi-tier supply chain transparency that spreadsheet-based tracking cannot deliver.

## Certivo In Action

### Certivo in Action—Komatsu Compliance Workflow

#### GET EVIDENCE IN

Collect Substance Declarations from Every Supplier—Without the Chasing

CORA launches targeted campaigns to collect material composition data, substance declarations, and conflict minerals disclosures from suppliers at every tier, following up automatically and accepting responses in any format.

- Launch substance data campaigns to hundreds of suppliers with one click
- CORA-powered outreach in suppliers' native languages, including Japanese
- Accept any format: PDFs, Excel, JAPIA sheets, IMDS exports, freeform responses
- Track response rates and escalate non-responders through automated supplier data collection workflows

#### MAKE SENSE OF IT

Know Instantly Which Products Exceed Komatsu's Restricted Substance Thresholds

CORA extracts every substance to CAS number level, validates against Komatsu's KES 07.000.1 banned and limited-use substance list, and flags threshold exceedances through AI document parsing and certificate validation.

- CORA parses declarations to extract CAS numbers, concentrations, and full material composition
- Automatic validation against KES 07.000.1 restricted substances and REACH SVHCs
- Real-time alerts when regulatory list updates affect your product portfolio
- BOM-level compliance intelligence mapping substances to individual articles and components

#### PROVE COMPLIANCE OUT

Generate GDMS-Ready Documentation and OEM Packages in Hours, Not Weeks

Produce JAPIA-formatted substance data, conflict minerals reports, and audit-ready compliance packages from validated supplier data with complete traceability.

- Pre-formatted exports compatible with JAPIA datasheet and IMDS registration requirements
- One-click conflict minerals reporting with refiner-level traceability
- Customer-specific OEM compliance packages with full audit trail
- Continuous compliance monitoring and audit readiness across Komatsu's evaluation cycles

## One Supplier Submission. Validation Against KES 07.000.1, REACH SVHCs, and RoHS Restrictions. Audit-Ready in Hours.

Certivo reads supplier documents, extracts substance data to CAS number precision, validates against Komatsu's restricted substance list and global regulatory frameworks, and generates OEM-ready evidence automatically. When Komatsu updates requirements or ECHA adds new SVHCs, Certivo reassesses your portfolio through regulatory intelligence and horizon scanning—before your next Midori-kai review.

- **CAS-Level Extraction**
- **KES 07.000.1 Validation**
- **JAPIA/IMDS Formatting**
- **Conflict Minerals Tracing**
- **Regulatory List Alerts**

## Features Tabs

### Declaration Collection

Certivo's automated campaigns achieve 95% response rates vs. 20–30% with manual outreach through centralized supplier self-service portals.

- Targeted campaigns by product line, supplier tier, or substance category
- Multi-language outreach in suppliers' native languages, including Japanese, Chinese, Thai, and German
- Intelligent follow-up sequences adapting to supplier behavior
- Format-agnostic: PDFs, Excel, JAPIA sheets, IMDS exports, freeform responses

**95% Supplier Response Rate**

### Substance Extraction

Every declaration parsed to CAS number level automatically—no manual data entry required for specialized substance reporting solutions.

- Deep extraction of substance names, CAS numbers, EC numbers, concentrations
- Parses JAPIA datasheets, IMDS exports, and proprietary OEM templates
- Multi-language document processing across Japanese, English, Chinese, and European languages
- Anomaly detection for inconsistent or suspicious declarations

**99.2% Extraction Accuracy**

### Regulatory Monitoring

Always validated against the current KES 07.000.1 list, REACH Candidate List, and RoHS restrictions—not your last audit cycle.

- Automatic sync with ECHA updates, RoHS amendments, and Komatsu-specific standard revisions
- Threshold calculations per Komatsu's article-level guidance aligned with REACH methodology
- Proactive alerts when new restricted substances affect your portfolio
- Historical tracking of substance status changes across frameworks through regulatory intelligence and horizon scanning

**Real-Time Multi-Framework Sync**

### OEM Response

Generate Komatsu compliance packages in hours instead of 4–6 weeks through a centralized compliance data backbone.

- One-click JAPIA-formatted substance data exports for GDMS registration
- Conflict minerals reporting with CMRT and refiner-level data
- Supplier declaration chain with complete traceability for Midori-kai evaluations
- Continuous compliance monitoring ensuring audit readiness across review cycles

**4 hours To OEM-Ready Package**

### Supply Chain Transparency

Pre-validated substance data and conflict minerals tracing across the entire supply chain through digital passport and traceability systems.

- Multi-tier supplier campaigns reaching Tier 2 and Tier 3 suppliers
- Conflict minerals origin mapping with refiner identification
- Substance flow tracking from raw material to finished component
- Supplier risk scoring and due diligence dashboards for procurement teams

**Multi-Tier End-to-End Visibility**

## Related Regulations

- **EU REACH:** KES 07.000.1 references REACH SVHCs; Komatsu tracks 247 SVHCs across production
  - **Combined Value:** Single declaration collection satisfies both Komatsu and REACH obligations
- **EU RoHS:** RoHS restricted substances overlap with Komatsu's banned substance categories
  - **Combined Value:** Multi-framework validation from one supplier submission
- **TSCA (US):** US chemical regulation with overlapping substance concerns for North American operations
  - **Combined Value:** Unified substance database flags TSCA chemicals alongside Komatsu restrictions
- **Conflict Minerals (Dodd-Frank / EU):** Komatsu requires 3TG due diligence aligned with US and EU conflict minerals regulations
  - **Combined Value:** Integrated conflict minerals tracing within the same compliance workflow
- **PFAS Regulations:** Emerging PFAS restrictions intersect with Komatsu's chemical substance management scope
  - **Combined Value:** Tracks PFAS across Komatsu requirements and emerging global frameworks
- **California Prop 65:** State-level warning requirements; some overlap with Komatsu's restricted substance categories
  - **Combined Value:** Unified database flags Prop 65 chemicals alongside KES 07.000.1 substances

## Managing Komatsu Green Procurement Standards compliance alongside related regulations eliminates duplicate supplier requests. Certivo validates one submission against multiple frameworks through an integrated PLM/ERP compliance thread.

## Industries Most Impacted

- **Industrial Machinery & Heavy Equipment**  
  Your Pain Point: Core Komatsu supply base; KES 07.000.1 and GDMS registration across complex BOMs
- **Automotive Manufacturing**  
  Your Pain Point: IMDS requirements overlap; shared supply chains with automotive-grade substance standards
- **Electronics Manufacturing**  
  Your Pain Point: Electronic components in operator systems, sensors, and control modules require RoHS + Komatsu alignment
- **Chemical Manufacturing**  
  Your Pain Point: Raw material and sub-material suppliers must provide full substance composition data
- **Building Materials & Construction**  
  Your Pain Point: Hydraulic fluids, coatings, sealants, and structural materials subject to Komatsu substance restrictions
- **Energy & Infrastructure**  
  Your Pain Point: Mining equipment components face dual Komatsu + regional environmental compliance requirements

## Return on Investment

- **80% Reduction in Compliance Labor**  
  From Manual Data Entry to Exception Management
- **2 Days to OEM-Ready Package**  
  Komatsu Compliance Response Acceleration
- **Continuous Compliance Monitoring**  
  Proactive Komatsu Green Procurement Standards Compliance

## Key Statistics

- **247+** Restricted substances tracked with automatic regulatory list sync
- **99.2%** Substance extraction accuracy from supplier declarations in any format
- **95%** Supplier response rate with CORA-powered multilingual campaigns

## Frequently Asked Questions

**What products and companies are subject to Komatsu Green Procurement Standards?**  
Any company supplying products, parts, raw materials, or sub-materials to Komatsu's global construction and mining equipment operations must comply. This includes all Midori-kai member companies across five regions, Tier 1 direct suppliers, facility and logistics service providers, and sub-tier suppliers receiving flowdown requirements.

**What are the consequences of non-compliance with Komatsu Green Procurement Standards?**  
Komatsu incorporates compliance with its CSR Procurement Guidelines and Green Procurement Guidelines into business contracts. If a clear violation is identified and corrective actions are not taken within a specified period, Komatsu may suspend or terminate the business relationship.

**How does Certivo handle Komatsu's JAPIA and IMDS reporting requirements?**  
Certivo accepts supplier declarations in any format—PDFs, Excel, JAPIA sheets, IMDS exports, or freeform responses—and extracts substance data to CAS number precision.

**Does Certivo validate against Komatsu's KES 07.000.1 alongside global regulations?**  
Yes. Certivo validates every supplier submission against Komatsu's KES 07.000.1 banned and limited-use substance list simultaneously with EU REACH SVHCs, EU RoHS restrictions, TSCA requirements, California Prop 65, and emerging PFAS regulations.

**How does Certivo support conflict minerals compliance for Komatsu suppliers?**  
Komatsu requires suppliers to investigate and report on 3TG content and country of origin per the US Dodd-Frank Act and EU conflict minerals regulation. Certivo automates conflict minerals survey distribution, collects CMRT responses from multi-tier supply chains, and traces mineral origins to refiner level.

## Ready to Automate Komatsu Green Procurement Standards Compliance?

See how Certivo's AI-native compliance automation transforms Komatsu substance tracking from reactive firefighting to proactive confidence—across KES 07.000.1, REACH, RoHS, and conflict minerals obligations simultaneously.