PIP (3:1) Implications: IPC Issues Industry Alert on Prohibition of PIP (3:1)

Key Summary

• EPA’s PBT rules took effect February 5, 2021, including restrictions on PIP (3:1)
• Processing and distribution of PIP (3:1) or products containing it is prohibited as of March 8, 2021
• Electronics receive no exemptions, unlike some automotive and aerospace uses
• PIP (3:1) serves multiple functions including plasticizer, flame retardant, and additive in fluids and coatings
• It is found in plastics used for cables, tubes, harnesses, sleeves, gaskets, and covers in electronic products
• IPC seeks industry input on potential supply-chain impacts and product functions involving PIP (3:1)


The U.S. Environmental Protection Agency’s (EPA) final risk management rules to reduce exposure to persistent, bioaccumulative, and toxic chemicals (PBTs) went into effect on February 5, 2021. Some of the five PBTs listed have a history of use in electronics, including phenol, isopropylated, phosphate (3:1) (known as PIP (3:1)).

The final rule for PIP (3:1) prohibits the processing and distribution of this chemical substance or products containing this chemical substance as of March 8, 2021. There are some exceptions to the prohibition, for example, for new and replacement parts for automotive and aerospace industries, however, there are no electronics industry exceptions.

As a chemical that can perform several functions simultaneously, sometimes under extreme conditions, PIP (3:1) has several distinctive applications: It is used as a plasticizer; a flame retardant; an anti-wear additive; or an anti-compressibility additive in hydraulic fluid, lubricating oils, lubricants and greases, various industrial coatings, and in adhesives and sealants. PIP (3:1) is also used in plastic-containing materials that are used to form tubes, harnesses, cables, sleeves, gaskets, and covers of parts – parts that are used in electrical or electronic products.

If the March 8 prohibition will have adverse impacts on your supply chain or if you have information regarding the function of PIP (3:1) in electronics and the types and quantity of products affected, please contact Kelly Scanlon, IPC’s director of environmental policy and research as soon as possible.

Q:
What does the EPA’s PIP (3:1) rule prohibit?
A:

It bans processing and distributing PIP (3:1) and any products containing it starting March 8, 202
 

Q:
Does the electronics industry receive any exemptions?
A:

No. The rule provides limited exceptions for automotive and aerospace parts, but none for electronics.
 

Q:
Where is PIP (3:1) typically used in electronics?
A:

In plastics for tubes, cables, harnesses, sleeves, gaskets, covers, and in coatings, lubricants, adhesives, and sealants.
 

Q:
Why is this prohibition significant for electronics manufacturers?
A:

Because many electronic components rely on materials containing PIP (3:1), and losing access could disrupt production and supply chains.
 

Q:
What should companies do if they expect supply-chain disruptions from this rule?
A:

They should contact Kelly Scanlon to provide details on how PIP (3:1) is used and what products could be affected.