IPC Global Advocacy Report
3/272020

Dear IPC Members:

The coronavirus continues to change our world every day, and IPC is doing everything we can to represent and advocate for you.

Thank you to those who joined us for Monday’s webinar on the coronavirus’s economic impact on the electronics manufacturing industry. As a follow up, here is a recording of the webinar as well as the presentation slides. If you were unable to participate, please let us know how the pandemic is affecting your operations, and if you have any questions or suggestions.

Meanwhile, the U.S. Congress and the Trump administration reached an agreement on a massive U.S. economic stabilization package, and several provisions will provide relief to the electronics manufacturing industry. Our press release with initial details is here, and our next-steps Roadmap for Economic Recovery is described below.

Be sure to monitor IPC’s COVID-19 Update web page, which will be updated regularly with new information as it becomes available. And as always, please let us know if you have any questions or suggestions for IPC advocacy.

All the best,

Chris Mitchell
Vice President, Global Government Relations


TOP OF THE WEEK

IPC Proposes Roadmap for Economic Recovery: In addition to the unprecedented actions already being taken by governments and central banks in response to COVID-19, IPC believes the electronics manufacturing industry is so important to the economy that we developed a Roadmap for Economic Recovery – a package of measures designed to help the industry weather the storm and drive the economic recovery. The roadmap includes provisions related to supply chain resiliency, tariffs, regulatory action, shipping, workforce health, and workforce financial security. Please check it out and let us know your thoughts and experience. This document will form the core of our advocacy work for the foreseeable future. IPC Contact: Chris Mitchell.

 

ENVIRONMENT, HEALTH AND SAFETY

U.S. EPA to Ease TSCA Fees: As advocated for by IPC, on March 25, the U.S. EPA confirmed it is exploring potential exemptions to the Toxic Substances Control Act (TSCA) Fees Rule to ease the implementation burden. The agency plans to consider exemptions for manufacturers that import articles containing high-priority substances or those who produce them as impurities or byproducts. The EPA is also providing a “no action assurance” for such manufacturers, meaning it will not pursue enforcement action regarding violations of the self-identification obligations. This action will reduce long-term administrative and financial burdens for affected manufacturers. However, companies that were already identified by the EPA on their preliminary list of fee payers should still plan to certify in the EPA’s Chemical Data Exchange (CDX) system. The EPA has modified the CDX to facilitate new responses; you can read the instructions for reporting here. The deadline to certify is May 27. IPC Contact: Kelly Scanlon.

EPA Implements Temporary Enforcement Discretion Due to COVID-19: On March 26, the U.S. EPA announced a new temporary enforcement discretion policy regarding civil violations during the coronavirus pandemic. While the EPA does not expect to seek penalties for noncompliance with routine monitoring and reporting obligations, it does expect regulated facilities to comply with regulatory requirements where reasonably practicable, and if not, to return to compliance as quickly as possible. Do not change your normal routine of meeting or exceeding regulatory requirements and using best practices. To be eligible for enforcement discretion, the policy requires facilities to document decisions made to prevent or mitigate noncompliance and demonstrate how the noncompliance was caused by the COVID-19 pandemic. IPC Contact: Kelly Scanlon.

 

EUROPEAN UNION

Coronavirus Triggers EU Action on Border Management: On March 17, the European Commission published guidelines for European Union Member States to ensure economic continuity during the coronavirus pandemic. Beyond a restriction on non-essential travel to the EU for 30 days, member states are encouraged to allow the unobstructed transport of goods. On March 23, the commission published further guidance for border management, including an overview of national measures taken by member states. Under the guidance, the commission asks all member states to designate specific freight channels (green lanes) in key locations to keep freight moving and supply chains open. While earlier debate focused on priority for "essential" goods, the guidance covers all freight transport. In anticipation of potential measures to restrict the flow of goods and business operations, IPC sent a letter to government officials in key member states to regard our industry and supply chain as “essential” in connection with medical, defense and infrastructure purposes. IPC Contact: Alison James.


TRADE AND SUPPLY CHAIN

COVID-19 Delays Brexit Negotiations: Brexit negotiations have been put on hold due to the coronavirus pandemic, with the European Union’s chief negotiator, Michel Barnier, having tested positive for COVID-19. While the pandemic will likely delay the first meeting of the joint committee set up to implement the withdrawal agreement, which was due to meet on March 30, the United Kingdom has insisted that the delay will not affect the Brexit transition period which ends on December 31. IPC Contact: Alison James.

Is Your Company Looking to Source Inputs from New Countries? 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 thinking about sourcing from new countries, we would be interested in hearing from you as part of our research and monitoring efforts. IPC Contact: Shawn DuBravac.

 

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