Dear IPC Members:

The coronavirus outbreak is being felt by IPC and our members. Last week, IPC released the results of a member survey on the issue, revealing that an overwhelming majority are concerned and are eyeing various strategies for coping. If you haven’t already done so, check out the survey, and let us know how COVID-19 is affecting your business. Also watch for a follow-up survey soon on whether things are getting better or worse.  

Due to concerns with COVID-19, IPC also has decided to cancel IMPACT Washington, D.C. 2020, our annual advocacy event which was scheduled for later this month. However, we are taking the opportunity to try something new and develop an online IMPACT experience. Please watch for fresh details next week and send us your input.

Meanwhile, this week’s newsletter features updates on a bevy of new environmental regulatory actions in the U.S., Europe and Asia; a query to you about changes in the electronics supply chain, and much more.

Please let us know if you have any questions or suggestions for IPC advocacy. We need and welcome your participation!

All the best,

Chris Mitchell
Vice President, Global Government Relations

TOP OF THE WEEK

Coronavirus Epidemic Affecting Electronics Manufacturers: As the stock market continues to feel the effects of the coronavirus epidemic, electronics manufacturers are now anticipating production and shipping delays across the supply chain, an IPC survey says. IPC will continue to perform research on this issue and keep you updated. Read IPC's full press release and the study, starting here. IPC Contact: Chris Mitchell.

Changes to RoHS Regulation will Affect the Electronics Industry: At the Chemicals Management for Electronics conference on March 23-24 in Amsterdam, Kelly Scanlon, IPC director of environment, health and safety policy and research, will provide an overview on the electronics industry’s perspectives on the current RoHS General Review. Kelly’s presentation on March 23 will follow the keynote presentation from the European Commission’s policy officer on RoHS. This is a great opportunity for IPC members to engage with a senior policy maker and to learn the latest on RoHS in the context of the electronics industry’s needs and concerns. Event sponsor Chemical Watch is extending a 15% registration discount to IPC members; simply use the code IPC15 when you register. IPC Contact: Kelly Scanlon.

Electronics Supply Chain in Flux Due to Tariffs, Epidemic, Other Factors: Over the last year, electronics manufacturers have been adjusting their supply chains due to trade tensions, tariffs, and the belief that higher tariffs may become permanent. We’re seeing evidence of a “decoupling” between China and the United States and shifts to other sources of supply such as Mexico, Vietnam, Indonesia, Taiwan and India. Read a short blog on this issue by IPC Chief Economist Shawn Dubravac; and if your company is contemplating, or in the process of, sourcing from new countries, we would be interested in hearing from you as part of IPC’s ongoing research and monitoring efforts. IPC Contact: Shawn DuBravac.

DEFENSE

IPC Pursuing More Funding for Pb-free Electronics Research: Late last year, IPC was successful in securing federal funding in Fiscal 2020 for research into lead-free electronics in high-performance missions. As a result of advocacy by IPC and its partners, the U.S. Congress appropriated $5 million to restart Pb-free research under the auspices of the U.S. Department of Defense. The funding reflects the need to close the knowledge gap concerning the reliability of Pb-free alternatives in aerospace and defense electronics. We believe that a five-year, $40 million investment in a public-private R&D program would yield more than $100 million in U.S. defense savings per year and improve military readiness and overall innovation. If your company would like to join the coalition that is working to secure funding for Pb-free R&D in Fiscal 2021, please contact Ken Schramko.

ENVIRONMENT, HEALTH AND SAFETY

Lead Metal Not Included in ECHA’s Latest Draft Recommendation for REACH Authorization: The European Chemicals Agency (ECHA) recently launched a 90-day public consultation on a new set of seven substances it is considering recommending for Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Authorization. Notably, the latest draft recommendation for REACH Authorization does not include lead metal. The public consultation remains open until June 5, after which the ECHA Member State Committee (MSC) will prepare an opinion on the draft recommendation. Please let us know if you have information on uses of the proposed substances. IPC Contact: Kelly Scanlon.

Does Your Company Face New TSCA Fee Obligations? If you manufacture or import certain “high-priority substances” or items that contain them, you may be obligated to pay fees in 2020 to the U.S. EPA. Many companies may be unaware of these potential fees, so it is critical to perform due diligence. IPC’s advocacy has, in part, led to the EPA’s 30-day extension for the self-reporting timeframe through the end of April 2020. IPC will continue to fight for our members to ensure the EPA actively addresses our concerns about the burdens of these fee obligations. Read IPC’s latest blog post for more information and let us know your questions and concerns. IPC Contact: Kelly Scanlon.

Learn More About ECHA’s SCIP Database: The European Chemicals Agency (ECHA) published a beta version of the Substances of Concern in Products (SCIP) database. Learn more at a free webinar from ECHA on March 17. Companies supplying articles containing certain hazardous materials above a threshold amount will be required to submit information on these articles to ECHA using the SCIP database beginning January 5, 2021. Companies will need to submit information to identify the article, name, concentration range, and location of the substance of concern in the article, and other information on its safe use. Please consider using IPC-175X standards to assist you in the identification of information useful to the SCIP database entry. IPC Contact: Kelly Scanlon.

Do you use PFAS?: On February 20, the U.S. EPA proposed a supplemental Significant New Use Rule to ensure that the EPA is notified before anyone begins or resumes the import of long-chain per- and polyfluoroalkyl substances (PFAS) as part of surface coatings on articles. The EPA and various European Union Member States are also exploring how best to manage a variety of PFAS across their life cycles. Please let us know if you use PFAS in your electronics processes and products. IPC is tracking these developments and will keep you updated. IPC Contact: Kelly Scanlon.

Proposed Clarifications to Prop 65: The California Office of Environmental Health Hazard Assessment (OEHHA) proposed modifying the safe harbor warnings in Proposition 65 to make clarifying changes to specific sections of the law. The proposed action will facilitate compliance by providing clarifying changes to the regulations as they relate to specific consumer product exposure warnings for products sold over the internet or through a catalog. The Public Comment period is open through March 16. IPC Contact: Kelly Scanlon.

Euro Trade Associations Fear Negative Impacts of RoHS Restriction on Plastic Recycling: According to comments submitted by the European Electronics Recyclers Association (EERA) and the Recycling Industries Confederation (EuRIC) to the European Commission’s review of Tetrabromobisphenol A (TBBPA) under the Restriction of Hazardous Substances (RoHS) Directive, a TBBPA restriction would negatively affect the sorting of plastics and potentially lead to the use of substitutes of similar concern. Germany’s Öko-Institut, the research institute overseeing the substance assessments on behalf of the commission, recommended new restrictions for TBBPA and medium-chain paraffins (MCCPs). The commission will wait for the study's conclusions, expected in May, and will consider further steps then. IPC Contact: Alison James.

ECHA Claims REACH Successfully Promotes Safer Alternatives to SVHCs: According to a market survey conducted by the European Chemicals Agency (ECHA), the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) authorization system is achieving its purpose of steering companies towards safer alternatives to 11 substances of very high concern (SVHCs) recently added to REACH Annex XIV. Based on market intelligence from leading actors in the supply chains for the substances, the ECHA concluded it was likely to receive fewer than five authorization applications for the substances, and called it a, "strong and positive indication that the authorization system is driving companies towards safer alternatives." IPC Contact: Alison James.

ECHA Increased Compliance Checks in 2019: The European Chemicals Agency (ECHA) announced last week that it increased the number of checks it performed on companies’ chemical safety dossiers by 50 percent last year. Under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation, companies must prove that a chemical is safe before it can be sold in the European Union's single market, a principle known as “no data, no market.” Non-governmental organizations (NGOs) have been critical of the system, citing studies suggesting that many chemicals approved for sale in the European Union don't comply with the regulation currently in place. IPC Contact: Alison James.

Chinese Agency Approves New Rules on Chemical Substances: On February 17, the Chinese Ministry of Ecology and Environment (MEE) approved amendments affecting the management of new chemical substances. The amendments adjust the registration classification, while simplifying the new chemical registration process. While the official amendments have not been published, and the implementation date has yet to be confirmed, they are expected to come into effect later this year. IPC Contact: Kelly Scanlon.

South Korea MoE Launches Online Platform for K-REACH Registration: On January 31, the South Korean Ministry of Environment launched the online data support platform for K-REACH registration. The platform contains a large amount of information on chemical and physical properties, and human health and environmental hazard data on 1,515 existing chemicals, collected from other countries and international organizations. The data set includes data sources and test methods for each chemical, which can be taken as reference for K-REACH registration. Please see detailed information on the chemical list and platform guide in their latest notice. IPC Contact: Kelly Scanlon.

Malaysia Updates List of Classified Chemicals: On February 11, Malaysia’s Department of Occupational Safety and Health (DOSH) published Part One of the Industry Code of Practice on Chemicals Classification and Hazard Communication (Amendment) 2019 (ICOP). ICOP was first approved on October 11, 2019, and Part One, which updates a list of classified chemicals, adds more than 400 chemicals to the previous 229 classified chemicals. ICOP is a guidance for chemical suppliers to comply with the provisions in Part Two of the Occupational Safety and Health (Classification, Labelling and Safety Data Sheet of Hazardous Chemicals) Regulations 2013, which deals with chemical classification. Chemical suppliers should check if products contain any substances in the 2019 Amendment and, if so, reclassify products and update information accordingly. IPC Contact: Kelly Scanlon.

EUROPEAN UNION

EU Eyes Changes to CSR Reporting Obligation: On February 17, the European Commission launched a public consultation on its upcoming review of the Non-Financial Reporting Directive (NFRD). The NFRD requires certain large companies to include a non-financial statement – for example on environmental or social issues – as part of their annual public reporting obligations. The upcoming review is part of the new “European Green Deal,” which aims to strengthen sustainable investment in Europe, improve corporate transparency, and provide all stakeholders with more comparable and relevant information on sustainable business activities. The review may bring about changes affecting IPC members, such as a widening of the scope of companies captured by the NFRD. The public consultation is open for stakeholder feedback until April 28. IPC Contact: Alison James.
 
Commission to Present New Circular Economy Action Plan: According to a recent communication and a draft of the upcoming Circular Economy Action Plan, which is due on March 10, the Plan will present a vision for a “cleaner” and “more competitive” Europe, including a timeline for numerous legislative initiatives. Electronics and information and communications technology (ICT) are considered to be “high-impact sectors”, and possible measures will include a sustainable product policy framework as well as a formation of a European Circular Dataspace. Additionally, the upcoming European Union chemicals policy should encourage a shift to safe-by-design chemicals and the progressive substitution of substances to protect citizens and the environment against hazardous chemicals. These efforts will be further communicated as part of the upcoming “chemicals strategy for sustainability,” expected later this year. IPC Contact: Alison James.

TRADE

Section 301 Tariff Exemptions for Two- and Four-Layer Printed Boards: Earlier this month, the US Trade Representative (USTR) published a notice in the Federal Register providing for additional exclusions to previously imposed Section 301 tariffs on imports from China. The list of exclusions includes “printed circuit boards, each with a base wholly of plastics impregnated glass, not flexible” with two- or four-layers of copper (HTSUS Codes 8534.00.0020 & 8534.00.0040). Exclusions for these products are retroactive to September 24, 2018 and will run until August 7, 2020. Importers that paid the tariffs are eligible for reimbursement. The USTR is continuing to consider exclusion requests; more notices are expected. IPC Contact: Chris Mitchell.

EU and U.K. Both Set to Discuss Trade Deals with U.S.: European Union trade ministers will discuss bilateral trade negotiations, including a possible ”mini-deal” with the United States, during a closed-door meeting on March 12, according to a provisional agenda. Ministers are also expected to discuss broader relations with China and the U.S. during the meeting. Meanwhile, United Kingdom Prime Minister Boris Johnson said the U.K. would “drive a hard bargain” in trade talks with the U.S., scheduled to begin later this month, while vowing to protect the country’s services including health care. The British government also said it would soon present negotiating objectives for deals with Australia, Japan and New Zealand “with the aim of having 80 percent of total U.K. external trade covered by free trade agreements by 2022.” IPC Contact: Alison James.

EU and U.K. Present Respective Strategies for Brexit Trade Talks: On February 25, European Union ministers adopted the bloc’s negotiating mandate for talks on a future relationship with the United Kingdom, covering areas such as trade, transport, and security. The final text includes tough language on level playing field stipulations, particularly in the areas of state aid, competition, environmental standards, and climate change. Meanwhile, on February 27, the U.K. presented its own negotiating strategy, stating that either party should have the freedom to make its own rules during the trade talks. However, the EU is concerned that this could allow the U.K. to import lower-standard products that don’t align with the EU’s rules. IPC Contact: Alison James.

UPCOMING EVENTS

CANCELLED: IMPACT Washington, D.C.: March 25-26, 2020. IPC’s U.S. advocacy event is canceled due to the coronavirus, but we will still be providing opportunities for members to engage with policy makers on the issues that affect our industry. Stay tuned for fresh details coming soon. IPC Contact: Chris Mitchell.

Chemicals Management for Electronics Europe 2020: March 23-24, 2020, Amsterdam, Netherlands. Kelly Scanlon, IPC director of environment, health and safety policy and research, will provide an overview on the electronics industry’s perspectives on the current RoHS General Review. Use the code IPC15 when you register to receive a 15% discount.  IPC Contact: Kelly Scanlon.

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