Dear IPC Members:

Have you ever struggled to explain to someone what your company does or why it matters? Now you can show them this new 90-second video from IPC, which illustrates the many ways that electronics are making people’s lives safer, healthier, more connected, secure, and fun. We designed the video to help us explain the basic technology and the importance of electronics to non-technical audiences such as policymakers and educators. Please help us promote the video by sharing it on social media with the hashtag #OurLivesDependonElectronics, or send a link by email to your workforce, business partners, elected officials, families, and friends.

Meanwhile, on the front burner in our office this week, nearly 100 IPC members and friends participated in our online seminar, Critical Environmental Requirements for Electronics, which covered the full array of pending issues in the Americas, Europe and Asia. Next week we will have a full writeup from the event as well as next steps you may want to take. And don’t miss the news items below on the most recent EHS policy developments.

Chris Mitchell
Vice President, Global Government Relations

TOP OF THE WEEK

COVID-19 Recovery Bills On Hold: “Buoyed by a surprisingly strong jobs report last week and the knowledge that some of Congress’s $2 trillion March spending package still hasn’t been spent,” U.S. Senate Republican leaders are “noncommittal” on the timing and substance of another COVID-19 recovery bill, Politico reports. Bipartisan talks are not even expected to start until July. The U.S. House has already approved a $3 trillion “Phase 4” package. In the context of this possible legislative vehicle, IPC recently joined a broad-based business coalition in calling on Congress to enact “temporary and targeted liability relief legislation.” Keep an eye out for a future IPC action alert. IPC Contact: Ken Schramko.

Did You Know? The U.S. electronics manufacturing sector is an important supplier of intermediary goods and capital equipment for critical industries including automotive, aerospace, and medical equipment. For example, the aerospace industry sources nearly $26 billion in intermediate goods from the electronics manufacturing sector — roughly 11.3 percent of all aerospace sector intermediate expenditures. For more facts on our industry’s economic impacts, please review our recent landmark economic impacts report; and please take a minute to share the report with your elected officials! IPC Contact: Chris Mitchell.

DEFENSE AND SECURITY

Industry Groups Object to New U.S. Export Controls: Nineteen industry groups including IPC and the National Association of Manufacturers recently sent a letter to the U.S. Department of Commerce’s Bureau of Industry and Security, objecting to two new export control rules affecting U.S. dealings with “countries of national security concern,” including China, Russia and Venezuela. The groups said, “We share the Administration’s goal of controlling technology exports to military end users and military end uses” in these countries. But the bureau defined these terms “with such breadth and ambiguity that they appear to extend beyond the intended goal and into commercial, mass market products and sales to end-users with indirect or limited connection to the military,” the groups said. The new rules – EAR § 744.21 and EAR § 740.5 – will go into effect on June 29. Please let us know if these rules might affect your company. IPC contact: Chris Mitchell.

ENVIRONMENT, HEALTH AND SAFETY

U.S. Chemical Data Reporting – Now Open! June 1 marked the opening of the U.S. Environmental Protection Agency’s Chemical Data Reporting (CDR) submission period. The CDR rule requires manufacturers and importers of certain chemical substances listed under the Toxic Substances Control Act (TSCA) Chemical Substance Inventory to report data to the EPA every four years. There are several new reporting requirements you should be aware of, including requirements for making confidentiality claims (CBI); reporting refinements related to byproducts, including exemptions; phasing out certain processing and use of data codes; and an improved process for reporting co-manufacturing. Meanwhile, in a separate rulemaking, the EPA also updated definitions for small manufacturers that are exempt from reporting. Also, to report using e-CDRweb, you must first register with the Chemical Data Exchange (CDX) system. The deadline for reporting has been extended to November 30. Let us know if you have any questions as your company goes through the reporting process. IPC Contact: Kelly Scanlon.

New Reporting Deadline for TSCA Self-Reporting: The U.S. Environmental Protection Agency (EPA) extended the comment and reporting period on the preliminary lists of manufacturers and importers subject to the Toxic Substances Control Act (TSCA) Fees Rule from May 27 to June 15. The new deadline will allow companies additional time to self-identify as a manufacturer potentially subject to the fees rule. The extension also will allow those who are incorrectly listed on the preliminary lists to use the Chemical Data Exchange (CDX) system to remove their company’s listing. Learn more about your company’s potential obligations under the fees rule here. IPC Contact: Kelly Scanlon.

Does Your Company Use PFAS to Make Electronics? Regulators in the United States and Europe are eyeing chemicals in the per- and polyfluoroalkyl substances (PFAS) class. The U.S. Environmental Protection Agency (EPA) has codified a list of 172 PFAS that are subject to reporting through the Toxics Release Inventory (TRI) program, and in June, the EPA is expected to issue a significant new use rule (SNUR) for long-chain perfluoroalkyl carboxylate (LCPFAC). Meanwhile, five European countries are calling for evidence and information on PFAS usage as they prepare a joint proposal under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program. A top official of the European Commission’s DG Environment said recently that his office is aiming to strengthen the legal framework surrounding PFAS. And the European Commission is already asking for feedback on limit values for 10 different substances under the Persistent Organic Pollutants (POPs) Regulation, including some PFAS. The POPs impact assessment will be open for feedback until August 7.  Please let us know if you use PFAS in your electronics processes and products. IPC U.S. Contact: Kelly Scanlon. IPC Europe Contact: Alison James.

Traceability of Substances Study Published: A new study on substances of concern (SoCs) in products from supply chains to waste operators, mandated by the European’s Commission Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW), supported efforts to improve the interface between chemicals, products, and waste legislation. The study concluded that “improved sorting early in the waste chain may create considerable benefits at low cost,” and “more sophisticated approaches using databases allow information update after placing on the market...but are more costly.” Meanwhile, “a combination of material-based and product sector approaches to communicate on SoCs in products seems necessary to achieve a safe, more circular economy.” What are some of the ways your company can improve waste sorting? IPC contact: Alison James.
 
Delaying of SCIP Deadline Unlikely, According to Commission: Following calls from several European trade associations, the European Commission confirmed that companies should continue their preparations to comply with the January 2021 deadline to submit notifications to the Substances of Concern in Products (SCIP) database. The commission also reminded companies that the obligation to submit information is set in the revised Waste Framework Directive, and the date can’t be modified by them. The SCIP database will be further discussed at the Competent Authorities for REACH and CLP (CARACAL) meeting on July 9. IPC will attend the meeting to follow up on previous advocacy regarding the possible impact of new reporting obligations. IPC Contact: Alison James.

Commission Asks for Feedback on Impact of REACH Registration Deadline: The European Commission launched a survey to gain a better understanding of the impact of the final Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) registration deadline on businesses. The survey seeks feedback on the costs and benefits of the registration exercise, which began in 2018. The questions are intended for businesses who registered chemical substances and stakeholders with experience in the process. The survey will close on August 10. IPC Contact: Alison James.

Commission Seeks Feedback on EU Chemicals Strategy: The European Commission has opened the feedback period for their roadmap on the upcoming chemicals strategy for sustainability, which is expected later this year. The strategy will aim to reduce risks associated with producing and using chemicals; simplify and strengthen European Union rules on chemicals; and “review how EU agencies and scientific bodies can work together towards a process where substances are only reviewed by one agency.” The feedback period runs until June 20. IPC Contact: Alison James.

EUROPEAN UNION

EU Justice Commissioner Confirms Due Diligence Proposal in Progress: During a June 8 webinar, European Union Justice Commissioner Didier Reynders reconfirmed his plan to introduce a mandatory due diligence legislative proposal in the EU by the end of this year. The legislation will seek to require “businesses to carry out due diligence in relation to the potential human rights and environmental impacts of their operations and supply chains.” The proposal is expected to include sanctions for businesses that do not comply. The European Council and European Parliament are expected to follow up on Reynders’s proposal, and they may seek to include businesses operating outside the EU in the legislation’s scope. IPC contact: Alison James.

TRADE AND SUPPLY CHAIN

Why Free Trade Needs a Comeback: The coronavirus pandemic has helped us realize the importance of freer, fairer, and more resilient trade among nations; our response to it must protect these values in a way that braces them for similar shocks in the future. IPC firmly believes all nations should do more to develop their industrial bases and supply chains to ensure their security and resiliency. For further insight on how COVID-19 is impacting our supply chains, check out this new article in Industry Week from our Chief Economist Shawn DuBravac. IPC Contact: Shawn DuBravac.

EU Trade Ministers Discuss Candidates for Next WTO Director-General: During a video conference on June 9, European Union trade ministers discussed unifying around a single European candidate for the post of Director-General of the World Trade Organization (WTO), following the decision by Roberto Azevedo, current director-general, to step down as of August 31. Candidates discussed included European Trade Commissioner Phil Hogan, who has made public his willingness to run for the job. Trade ministers stressed the “importance of expediting the process so that the new director-general can take office on September 1,” while also calling for the “future director-general to be a strong supporter of multilateralism, with the necessary experience and ability to push an ambitious agenda for the WTO.” Member states will try to reach an agreement on a candidate over the next two weeks. IPC contact: Alison James.

Vietnam Ratifies Trade Deal With EU: On June 8, Vietnam officially ratified a free-trade agreement with the European Union “that is expected to energize the country’s manufacturing sector and exports, as it recovers from the impact of the coronavirus pandemic.” Under the deal, the EU will lift 85 percent of its tariffs on Vietnamese goods, gradually cutting the rest over the next seven years, while Vietnam will lift 49 percent of its import duties on EU exports and phase out the rest over the next 10 years. IPC contact: Alison James.

U.K. Releases Global Tariff Plan: As the United Kingdom continues to plan its exit from the European Union, the government recently released its U.K. Global Tariff (UKGT) plan, detailing tariffs that will now be levied on products coming into the U.K. The UKGT will replace the European Union's external tariff on January 1, and tariffs will be eliminated on £62 billion ($76 billion) of imports. The publication of this tool is intended to allow for businesses to plan for tariff rates in the new year, although the United States and U.K. are conducting negotiations for a separate trade agreement, and tariffs are subject to change. IPC contact: Alison James.

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