IPC Global Advocacy Report
3/13/2020

Dear IPC Members:

The coronavirus outbreak continues to dominate the headlines and the work being done by the IPC Government Relations team. Two weeks ago, IPC released the results of a member survey on the issue, revealing that many members are concerned about the outbreak’s effect on business and are eyeing various strategies for coping. The results of a second-round IPC survey are being released today (Friday), and they reveal growing concern in some quarters. Please let us know how the pandemic is affecting your operations, and whether you’d be willing to share your story with policy makers.

In case you missed it, IPC decided to cancel IMPACT Washington, D.C. 2020, our annual advocacy event, which was scheduled for later this month, due to the coronavirus. However, we are taking the opportunity to develop an online IMPACT experience, and some initial details are provided below.

This week’s newsletter also features updates from the EU, including a just-released Circular Economy Action Plan and an Industrial Strategy. There are also new environmental regulatory actions which may affect IPC members, including toxic substances fees that may be due to the U.S. EPA.

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

All the best,

Chris Mitchell
Vice President, Global Government Relations


TOP OF THE WEEK

Coronavirus Epidemic Continues to Affect Electronics Manufacturers: As the coronavirus continues to take a toll on the stock market and multiple industries, electronics manufacturers are now experiencing delays in design, production and shipping across the supply chain. In a second-round survey on the issue, IPC members tell us they expect five-week delays in receiving inputs from overseas suppliers, but a majority expect business to return to normal between July and October. Please let us know how the pandemic is affecting your operations, and whether you’d be willing to share it publicly. IPC Contact: Chris Mitchell.
 
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.

IMPACT Washington, D.C. Becoming an Online Month of Impact: IPC’s signature U.S. advocacy event – IMPACT Washington, D.C., previously scheduled for March 25-26 – is canceled due to the coronavirus, but we are viewing this as an opportunity to try something new and provide online opportunities for members to engage with policy makers on the issues that affect our industry. During the week of March 23, IPC will host two online webinars open to all IPC members: one to share new research on our industry’s economic impact in the United States; and another on the U.S. political outlook for 2020. Over the coming month, we will offer more online educational sessions and opportunities to engage with policymakers. Stay tuned for more details coming soon. IPC Contact: Chris Mitchell.

 

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

Changes in RoHS Regulation Will Affect the Electronics Industry: Kelly Scanlon, IPC director of environment, health and safety policy and research, has prepared an article and presentation for Chemical Watch on how evolving changes to the Restriction of Hazardous Substances Directive (RoHS) may affect the electronics value chain. Alison James, IPC senior director for government relations in Europe, is engaging in stakeholder meetings during March that are sponsored by the European Commission. IPC is communicating with the commission about our members’ experiences that are relevant to the RoHS General Review. If you have information to share about your experience with RoHS, please let us know. IPC Contact: Kelly Scanlon.

ECHA Considers Seven New Hazardous Substances for REACH Authorization: The European Chemicals Agency (ECHA) recently launched a 90-day public consultation on seven substances it is considering regulating under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program. Most notably, the latest draft recommendation does not include lead metal, although due to the high volumes of lead traded on the European Union market, it may be considered again next year. The public consultation remains open until June 5, after which the ECHA Member State Committee (MSC) will prepare an opinion on the draft recommendation. Based on that feedback, the European Commission will decide in early 2021 which substances should be included in the Authorization List (REACH Annex XIV). Please let us know if you have information on uses of the proposed substances. IPC Contact: Alison James.

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.

Does Your Company Face New TSCA Fee Obligations? If you manufacture or import chemical substances designated as High-Priority Substances under the U.S. Toxic Substances Control Act (TSCA), you may be subject to new fee obligations to the U.S. EPA. Many companies may be unaware of these potential fees, so it is critical to perform due diligence. This week, the EPA announced a 60-day extension for self-reporting, ending on May 27. 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 recent blog post for more information, and let us know your questions and concerns. IPC Contact: Kelly Scanlon.

Do you use PFAS? The U.S. EPA and various European Union Member States are exploring how best to manage a variety of per- and polyfluoroalkyl substances (PFAS) across their life cycles. Please let us know how you use PFAS in your electronics processes and products. IPC is tracking policy 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.

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

New EU Industrial Strategy Focuses on Competitiveness, Green and Digital Transitions: The European Commission unveiled its long-awaited Industrial Strategy on March 10, laying out new policy directions to boost Europe's global competitiveness while addressing the European Union's dual objectives of green transition and digital transformation. The new strategy aims to help deliver on priorities such as “making Europe climate-neutral by 2050,” “shaping Europe's digital future,” improving the scrutiny of supply chains, and reviewing EU competition rules. On the same day, the commission also presented a strategy for helping small and medium-sized enterprises (SMEs), which includes measures to help SMEs benefit from opportunities created by the green and digital transitions and improve access to financing. IPC will engage the commission throughout the process to highlight the importance of electronics manufacturing and provide analysis of what is required to support our industry. IPC Contact: Alison James.

EU Presents New Circular Economy Action Plan: On March 11, the European Commission officially released its new Circular Economy Action Plan, which includes initiatives to promote efficient use of materials; encourage sustainable production and consumption; and cut waste. Notably, the action plan features a Sustainable Product Policy Framework initiative that focuses on designing greener products, particularly in electronics and information and communications technology (ICT). In addition, the action plan will encourage a shift to safe-by-design chemicals through a progressive substitution of hazardous substances in supply chains. The action plan remains in line with the EU Industrial Strategy, presented on March 10, and aims to complement the commission’s goal to achieve carbon neutrality by 2050. IPC Contact: Alison James.

Commission Publishes its First EU Climate Law: In another far-reaching initiative, the European Commission last week released their European Climate Law proposed regulation, which seeks to enshrine the European Union’s 2050 net-zero emissions target into legislation. The regulation would allow for the commission to review the “collective progress” of Member States toward the EU’s climate neutrality goal by September 30, 2023, and every five years thereafter. However, the proposal avoids tackling the issue of the EU’s 2030 emissions reduction target, which is tabled until September. The proposal needs to be adopted by the European Parliament and European Council, with backers hoping this will happen early this summer. IPC Contact: Alison James.

EU Eyes Changes to CSR Reporting Obligation: The European Commission launched a public consultation on its upcoming review of the Non-Financial Reporting Directive (NFRD) on February 17. 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.
 


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.

Trade Ministers to Discuss EU-US Trade Relations and COVID-19: European Union trade ministers discussed ongoing negotiations with China regarding an investment protection agreement, as well as the impact of the COVID-19 outbreak on supply chains and trade flows, during a closed-door meeting on March 12, according to a released agenda. Ministers were also expected to sign off on a trade agreement with Vietnam during the meeting. Meanwhile, EU Trade Commissioner Phil Hogan said last week that the EU remains hopeful of reaching a "mini-deal" with the United States in the coming weeks, though it may prove difficult given disagreements on food safety regulations, energy, and trade. IPC Contact: Alison James.

 

UPCOMING EVENTS

CANCELLED: Chemicals Management for Electronics Europe 2020: IPC has confirmed that the Chemical Watch conference scheduled for March 23-24 in Amsterdam, Netherlands has been postponed due to the coronavirus until the fall. We will update our members as more details arise. IPC Contact: Kelly Scanlon.

 

KEEP IN TOUCH WITH US

Subscribe to IPC Global Advocacy Report: If you’re a member of IPC, manage your e-mail preferences and opt in to receive “Advocacy” updates. If you are not an IPC member – or you’re not sure – please send a note to friends@ipc.org, and our staff will add you to the list.

Follow us on Twitter.

Contact one of us if you have any questions or insights to contribute.

Tell us how government policies affect your business.

See prior editions of Global Advocacy Report.

Explore our IPC Government Relations information online.