Stakeholder Consultation on EU RoHS Exemption Applications Launched

On April 24, 2015, the Öko Institut, consultants to the European Union (EU), announced the launch of an online stakeholder consultation. The stakeholder consultation will run for eight weeks from April 24 to June 19, 2015.  

The consultation covers three requests for renewal of exemptions listed in Annex III of the Directive:

Exemption renewal request 9b: “Lead in bearing shells and bushes for refrigerant-containing compressors, with a stated electrical power input of only 9 kW or lower for the HVACR industry” with requested expiry date three years after the publication of the amended RoHS Annex

Exemption renewal request 13a: “Lead in white glasses used for optical applications”

Exemption renewal request 13b: “Cadmium and Lead in filter glasses and glasses used for reflectance standards”

And three new exemption requests:

Exemption request 2015-1: “Lead in thin film electronic sensor elements such as pyroelectric sensors or piezoelectric sensors”

Exemption request 2015-2: “Lead in high voltage cables and cable assemblies for a rated voltage higher than 250kV DC, containing up to 4% lead by weight” (for industrial monitoring and control instruments, Annex IV)

Exemption request 2015-3: “Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps when used as phototherapy lamps containing phosphors such as BSP (BaSi2O5:Pb) (Annex IV)

IPC, in conjunction with an international industry stakeholder group, applied for more than a dozen exemption extension requests under the EU RoHS Directive. The RoHS2 Directive dictates expiration dates for all exemptions granted and several critical to the electronics manufacturing industry are set to expire in 2016.

EU Parliament International Trade Committee Votes for Mandatory Conflict Minerals Regulation

Last week, on April 14, the International Trade Committee of the European Parliament (INTA) voted on amendments to the EU’s conflict minerals regulation that were proposed by its members. The INTA voted to make mandatory the proposed voluntary system of certification for EU smelters and refiners. By a close vote (22-16) they rejected amendments seeking to extend this mandatory scheme to those who purchase minerals for the production of goods such as mobile phones and other electronics.

The draft regulation covers tin, tantalum and tungsten, their ores, and gold originating in conflict-affected and high-risk areas. Amendments proposing the extension of the scope of the legislation to other minerals and metals were rejected by the INTA committee.

On March 30, 2015, IPC, and a number of other associations issued a statement emphasizing the need for EU legislation to adhere to the Organisation for Economic Co-operation and Development (OECD) framework and those concepts that have been assessed in the regulatory impact assessment performed by the EU Commission.

The Members of European Parliament (MEPs) on the INTA committee also approved the establishment of a “European certification of responsibility” for “downstream operators,” such as electronics manufacturers.

The draft regulation adopted by the INTA committee will be voted on by the full European Parliament during their May 18 – 19 plenary session. During the plenary session, any member of the EU Parliament can offer an amendment, even those that were rejected by the INTA committee. IPC members with facilities in the EU are encouraged to contact their MEPs and urgethem to support the European Commission proposal for a voluntary program.

Tulane University Conducts Conflict Minerals Market Impact Survey of Entire Supply Chain

IPC members and many other companies are continuing to be burdened by compliance with U.S. conflict minerals regulations, while Europe contemplates its own conflict minerals regulations. In a continuing effort to quantify the burdens experienced by companies, especially those in the supply chain, Tulane University is conducting a Conflict Minerals Market Survey. The survey results will also assist IPC and other industry associations in lobbying for less burdensome regulations in other parts of the world, such as those currently being considered in the European Union.

All companies impacted by conflict minerals legislation or produce, procure or consume tin, tungsten, tantalum and/or gold (3TG) are invited to participate. This survey will focus on the upstream and downstream 3TG supply chain. The survey can be found at http://payson.tulane.edu/3tg15. The deadline to complete the survey is June 15, 2015. The survey is expected to take survey respondents between 10 and 30 minutes to complete and is available in English, French and Mandarin.

 

California DTSC Releases Safer Consumer Product Regulation Three-year Work Plan

On April 16, 2015, the California Department of Toxic Substances Control (DTSC) released its three-year work plan for the Safer Consumer Products regulation. Even though electronics are often a target for substance restriction regulations, DTSC chose to focus on product categories that have a direct impact on consumers. The work plan outlines DTSC’s policy priorities and product categories that may be evaluated over the next three years:

  • Beauty, Personal Care and Hygiene Products
  • Building Products and Household, Office Furniture and Furnishings
    • Building Products: Painting Products, Adhesives, Sealants, and Flooring
    • Household, Office Furniture and Furnishings
  • Cleaning Products
  • Clothing
  • Fishing and Angling Equipment
  • Office Machinery

DTSC will use screening approaches, prioritization criteria and stakeholder consultations to identify specific products within these categories that will be investigated as potential Priority Products.

The work plan can be found on DTSC’s website at http://www.dtsc.ca.gov/SCP/PPWP.cfm. IPC will continue to monitor DTSC activities surrounding the Safer Consumer Products regulation.

Withdrawal of Application to Renew Exemption 7(b) of Annex III of the RoHS Directive

Quintech Electronics & Communications, Inc. has withdrawn its application to renew exemption 7(b) of Annex III of the RoHS Directive.  Exemption 7(b) was for lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signalling, transmission, and network management for telecommunications.

RoHS exemption renewal requests are reviewed by the European Union (EU) Commission prior to requesting consultant evaluation. This pre-review process may involve a series of questions and answers with the submitting company. As a result of this process, the lone applicant for extension of RoHS exemption 7(b) [related to Pb plating, solders and solder balls in telecom server array systems] has withdrawn their application for renewal. 

This withdrawal means that exemption 7(b) will expire on 7/21/2016 as scheduled in RoHS-2, Annex III. Exemption 7(b) will not receive the additional 6-18 month transition time that would have been allowed if an exemption renewal had been sent to the Okö-Institut for evaluation.

 

IMPACT 2015: IPC on Capitol Hill

John Mitchell, IPC president and CEO, extends a special invitation to IPC-member company executives to attend IMPACT 2015: IPC on Capitol Hill, April 29–30 in Washington, D.C.

 

 

 

 

IPC and Other Associations Issue Joint Statement on EU Conflict Minerals Legislation

On March 30, 2015, in anticipation of the upcoming European Union Parliament Committee on International Trade vote on proposed conflict minerals legislation, IPC, along with AmCham EU, the European Committee of Domestic Equipment Manufacturers (CECED), DIGITALEUROPE, the Japan Business Council in Europe (JBCE), the Japan Electronics and Information Technology Industries Association (JEITA), the Korea Electronics Association (KEA), Semiconductor Equipment and Materials International (SEMI), the Trans-Atlantic Business Council (TABC), and TechAmerica Europe issued Joint Recommendations on the EU Draft Regulation on Responsible Sourcing of Minerals.

The recommendations support the March 2, 2015 report, “Union system for the supply chain due diligence of responsible importers of 3TG originating in conflict-affected and high-risk areas,” issued by MEP Winkler, the rapporteur for conflict minerals. The statement emphasizes the need to adhere to the OECD framework and those concepts that have been assessed in the regulatory impact assessment performed by the EU Commission.  Particular issues addressed by the statement include:

  • Acknowledgement and support of existing industry schemes identifying compliant smelters and refiners
  • A white list of smelters and refiners to be produced by the Commission
  • Maintaining the product focus on 3TG and the exclusion of recycled materials
  • Focusing on upstream portions of the supply chain (smelters and importers)
  • Flexibility for downstream companies in way they provide information on supply chain due diligence to their supply chains and customers
  • Companies should not be required to define conflict zones and high-risk areas.

The Committee on International Trade is scheduled to vote on the conflict minerals proposal during an April 13-14, 2015 meeting and plenary session. Consideration by the full European Parliament is tentatively scheduled for May 19, 2015.

Your Participation Needed in IPC Military Lead-free Survey

There is growing concern among military/aerospace suppliers about the availability and cost of leaded materials and components. IPC is conducting a confidential survey to assess the current state of the supply chain and the issues facing electronics manufacturers.

If you manufacture PCBs or electronic assemblies for military/aerospace applications, IPC requests your participation in this survey. As a “fast-facts” survey, the turnaround will be quick. It is open only through Friday, March 27. If you complete the survey, you will receive a report on the results at no charge by the end of April.

Please use this link to access the survey: https://www.surveymonkey.com/s/IPCLeadFree. Your response will be kept confidential and only aggregate data will be published in the report.

 

Four IPC Global Statistical Programs Now Open

IPC’s global statistical programs for the laminate, solder, process consumables and assembly equipment industries are now open to new participants for 2015. The deadline for IPC members to sign up is April 15. Participation is free to IPC member companies as a benefit of membership.

The statistical programs give participating IPC members access to global quarterly market data that would be impossible for them to collect themselves and prohibitively expensive for individual companies to obtain from research firms. As a neutral and trusted third party, IPC collects sales and other business and technical data from the participating companies using a secure and confidential online survey system. In exchange, these companies receive quarterly market reports showing aggregate sales and growth rates for the industry, segmented by detailed product categories and by region.

Participating companies use this quarterly data in their marketing, sales, planning and budgeting activities. The data helps them to track changes in their market shares, compare their performance against industry averages in their regions and product segments, and identify growing and declining markets. Current participants in these programs include most of the world’s leading producers.

The laminate and solder statistical programs are conducted in English and Mandarin Chinese. In addition to shipment data, the solder program also tracks worldwide consumption of lead-free versus tin/lead solder, and the use of SAC alloys. The process consumables program is conducted in English and Japanese. It covers dozens of product categories in plating materials, final finishes, solder mask and other imaging processes, developers and strippers. The assembly equipment statistical program tracks sales in units and value. It covers specific product categories under the headings of pick-and-place, inspection, test, soldering and dispensing equipment, as well screen printers, ovens, stencils and software.

The first-quarter 2015 surveys will go out on April 1. To ensure consistent survey samples for the year, participants must commit to completing all four quarterly surveys for 2015. IPC members interested in participating in the statistical programs for their industries may contact IPC at marketresearch@ipc.org or by phone at +1 847-597-2868.

 

 

EU Court Advisor Releases Opinion on the REACH Article Debate

Last week, the European Union Advocate-General to the Court of Justice issued an opinion on the debate regarding the concept of an “article” under the Registration, Evaluation and Authorization of Chemicals (REACH) regulation. The Advocate-General’s opinion stated that the threshold for registration requirements applies to the whole article, not at the level of each individual component (part). However, for SVHC (substances of very high concern) notification requirements, the Advocate-General’s opinion stated that the SVHC notification requirements apply to individual components. If any component within a larger article contains an SVHC above the 0.1% threshold, a company must comply with the notification requirements.

According to the Advocate-General, a component is an article if, once integrated, it retains a shape, surface or design of its own. REACH defines an article as “an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.” The Advocate-General reasoned that this definition does not distinguish between stand-alone articles and articles integrated in a bigger article and an article does not lose its function once it is integrated in a bigger one, though that function might change. The only criteria to be taken into account is whether the product has a shape, surface or design which is more relevant than its chemical composition.

Member States have had differing interpretations of an article, in particular how reporting threshold requirements apply to complex articles, such as a computer. The European Commission and most Member State authorities concluded that the threshold applies at the level of the whole article, but seven Member States, including France and Germany, had decided to apply the threshold at the level of each individual component, in the case of a laptop, the screen, plastic case, capacitor, integrated circuit, etc.

The EU Court of Justice is expected to release its judgment in the coming months, which will be the final ruling on the issue. 

IPC will keep you informed of any updates on the final ruling.

 

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