EPA Extends PIP (3:1) Compliance Date, IPC Member Feedback Needed
By Kelly Scanlon, director of environmental policy and research
Key Summary
• EPA proposes extending the PIP (3:1) compliance deadline for articles to October 31, 2024
• Electronics components such as wiring, cables, cords, and casings are specifically highlighted as affected
• IPC, CTA, and ITI will submit industry feedback but will not oppose the extension
• IPC urges a “manufactured by” compliance date, de minimis thresholds, and exemptions for spare parts
• Industry input is needed, especially new supply-chain data and economic impact information
• Feedback in response to IPC’s Request for Information is due by December 1, 2021
EPA published a new Proposed Rule to further extend the risk management compliance date for PIP (3:1)-containing articles to October 31, 2024. The prohibition on processing and distribution of PIP (3:1) and PIP (3:1)-containing articles will be effective on that date unless we can make a strong case otherwise.
Because the proposed rule highlights electronics, including wiring harnesses, cables, wiring sleeves, casings, and cords, we want to make sure that the electronics manufacturing industry is aware of the likely relevance of the 2024 prohibition.
We encourage you to review our Request for Information for a detailed list of data and documentation needed to prepare a response to EPA. IPC will continue to collaborate with CTA and ITI to gather the electronics industry’s feedback. We do not plan to oppose the newly proposed extension, but we will request to EPA that it be based on a “manufactured by” compliance date. Also, we will reiterate to EPA our earlier requests to establish an adequate de minimis concentration and to provide specific exemptions including for spare and replacement parts.
We anticipate that the electronics industry will have new or additional data and information based on its efforts to identify PIP (3:1) in its supply chain since the January 2021 final risk management rulemaking. Also, we anticipate industry members will have more economic impact information to support a request for an exemption for spare and replacement parts. We welcome your feedback in response to the Request for Information by December 1, 2021.
Please see our earlier blog posts regarding PIP (3:1). I welcome your questions about this proposed rule and the recent history of PIP (3:1)-related policy actions. KellyScanlon@ipc.org
IPC Issues Industry Alert on Prohibition of PIP (3:1), March 1, 2021
USEPA Announces Request for Public Input on PIP (3:1) Final Risk Management Rule, March 12, 2021
Electronics Industry Submits Comments on EPA’s PIP (3:1) Request for Public Input, May 17, 2021
PIP (3:1) Compliance Deadline Extended…At Least Two More Rules Expected, September 8, 2021
PIP (3:1) is a flame retardant/plasticizer regulated under TSCA. EPA is proposing to extend the compliance date for articles to October 31, 2024 due to industry challenges identifying and removing PIP (3:1) from complex supply chains.
The proposed rule specifically calls out electronics components like wiring harnesses, cables, cords, sleeves, and casings. These complex assemblies often contain materials from many suppliers, making PIP (3:1) identification and substitution difficult.
Updated supply-chain data, documentation on PIP (3:1) findings, and detailed economic impact insights—especially regarding spare parts, replacement components, and the challenges of compliance.
No. IPC supports the extension but will request modifications, including using a “manufactured by” date, setting an appropriate de minimis concentration, and establishing exemptions for spare and replacement parts.