IPC Concerned By EPA Fact Sheet on TSCA CDR Reporting

Under U.S. Environmental Protection Agency (EPA) regulations, printed circuit board manufacturers who send byproducs, such as wastewater treatment sludge, spent etchant or spent baths, for recycling may be required to report under the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule.

EPA recently published a fact sheet on reporting requirements for the printed circuit board industry.  Members are advised to read the fact sheet very carefully.  Prior to publication of the fact sheet, IPC submitted informal comments to the EPA and asked for a meeting to discuss how the fact sheet could be improved to provide clearer advice to the industry particularly as regards reporting of Chemical Substances of Unknown or Variable Composition, Complex Reaction Products and Biological Materials (UVCBs).

IPC and EPA were unable to schedule a meeting to discuss IPC’s concerns with the guidance, prior to the release of the fact sheet. IPC’s letter to EPA outlines our concerns.

PCB manufacturers are advised to review our CDR guidance and TSCA CDR website in addition to the new fact sheet.

For more information, please contact Fern Abrams, director of regulatory affairs and government relations, at fabrams@ipc.org or +1 (202) 661-8092.

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