By Aidan Turnbull, managing director, BOMcheck; Kelly Scanlon, director, EHS policy and research, IPC 

Key Summary

• ECHA clarified SCIP database reporting requirements for articles containing REACH Candidate List substances above 0.1 percent starting January 2021.
• Database prototypes and production versions will launch in 2020 to help companies prepare for SCIP reporting.
• IPC standards IPC 1752B and IPC 1754 are being used to test needed data fields and support supplier declarations.
• ECHA adopted several IPC Task Group recommendations, including options to protect confidential business information using company part numbers.
• Updated Materials Categories, TARIC and CN Codes, and Candidate List structures will guide accurate reporting.
• ECHA plans future safe use text lists developed with IPC and other stakeholders.

At a recent stakeholder workshop in Helsinki, Finland, the European Chemicals Agency (ECHA) shed more light on its upcoming Substances of Concern in Products (SCIP) Database and how IPC standards factor into it. Starting January 5, 2021, all manufacturers will be required to report information into the new ECHA SCIP Database if their products include articles that contain REACH Candidate List substances above 0.1%. At the recent workshop, ECHA confirmed that a prototype database will be available in Q1 2020, which will enable companies to start getting used to it, and a production version, coming in October 2020, will enable companies to begin entering data. Together with other leading industry groups, IPC has been using its development of the new IPC-1752B Materials Declaration Management standard and the IPC-1754 Materials and Substances Declaration for Aerospace and Defense and Other Industries to road-test the data fields needed in supplier materials declarations. Various members of IPC’s Materials Declaration Task Groups, which, for example, are responsible for development of the IPC-1752B and IPC-1754 standards, have made recommendations to ECHA. 

At the workshop, ECHA confirmed that some of the recommendations are already being implemented for the prototype release in early 2020, and others need further discussion. For example, companies can protect confidential business information about their supply chains by using their own part numbers for articles they are notifying, instead of using their suppliers’ identifiers. The company part number can be multi-sourced from several alternate suppliers, provided that the supplier part numbers are not materially different as regards REACH Candidate List substances. Materials Categories and Articles Categories (TARIC/CN Codes) are now provided with unique Pick List IDs by ECHA in IUCLID, and they will be updated annually in October. The Materials Categories and the TARIC/CN Codes are managed by ECHA and the European Commission, respectively. The TARIC/CN Codes update will be based on the TARIC list published by the European Commission in July each year. If Materials Categories are provided, then Mixture Codes are optional. Additional Material Characteristics is now a separate optional list, which users can use to declare further details about the materials an article is made of. The objective is to describe the materials as accurately as possible and/or to describe the applied mixture in which the Candidate List substance resides. Also, the Candidate List entries will be provided as reference substance data sets rather than as Pick Lists because the REACH Candidate List is updated at least twice per year, which is more frequent than the IUCLID annual update. 

Each version of the Candidate List is identified as a Pick List in IUCLID. In future updates to the SCIP database, ECHA is planning to provide an enumerated list of Safe Use Information text strings, with an ID for the list and an ID and description for each entry in the list. ECHA is looking forward to developing such a list together with IPC and other leading stakeholders. The new IPC-1752B standard will help companies collect the necessary information from their supply chains so that they can start reporting into the ECHA SCIP database any products that include articles that contain REACH Candidate List substances above 0.1%. To help you learn more, IPC and Chemical Watch are partnering on a free webinar, “Update on New IPC-1752B Supply Chain Standard,” which will take place on December 5 at 10:00 am EST. Speakers Aidan Turnbull and Patrick Crawford will provide an update on the reporting requirements for the ECHA SCIP database and explain how your company can contribute to standards development. Click here to learn more and register today. Thank you to Materials Declaration Task Groups for their involvement with standards development, ECHA’s development of the SCIP database, and their contributions to this blog post. And special thanks to Walter Jager, ECD Compliance, for his input on this blog post.

By Sharon Starr, director, market research 

Key Summary

• IPC’s wage and salary survey provides compensation benchmarks for North American electronics assembly companies.
• The survey includes data for 40 technical, manufacturing and sales positions across OEMs and EMS companies.
• Results offer averages, percentiles and segmentation by company type, size and region for competitive analysis.
• The study also benchmarks employee benefits and HR policies to support workforce strategy updates.

IPC's biennial Wage Rate and Salary Survey for the North American Electronics Assembly Industry is much more than its name implies. It collects data on compensation for 40 hourly and salaried technical, manufacturing and sales positions at original equipment manufacturers (OEMs) and contract electronics manufacturing services (EMS) companies in North America. In addition, it covers salary budget growth, planned increases for 2020, and employee benefits and policies. Companies can use this study to assess their competitiveness in today’s labor market. The survey covers 25 hourly, 11 salaried and four sales positions, including commission rates for both internal sales and customer service staff as well as independent manufacturers’ representatives. The report on the results will show the data in averages and percentiles. It will be segmented by company type, size and region, enabling companies to assess their competitive position as employers within their region and company-size tier. Job descriptions are also included in the report. The study will enable companies to benchmark their employee benefits and HR policies against industry norms. The survey covers the use of various types of insurance and retirement plans, flexible hours, paid leave, performance appraisal methods, tuition reimbursement and many other policies, making the results a valuable resource for companies wishing to update their human resource management strategies. The study is unique in in its focus on the North American electronics assembly industry. Survey participants will receive the report on the findings at no cost. The survey is intended for HR professionals and executives who can provide data on a range of positions and policies. The survey is open now with an extended response deadline of November 8. The survey can be accessed at www.ipc.org/WageSurvey2019. Participants are asked for their IPC company code to start the survey. They can obtain their codes by contacting IPC’s market research team at marketresearch@ipc.org or calling +1 847-597-2868. The company code is used to protect the confidentiality of participants’ data. IPC publishes only aggregate numbers and maintains strict confidentiality. The report will not identify participating companies.  

By Kelly Scanlon, director, EHS policy and research 

Key Summary

• The EU’s Restriction of Hazardous Substances (RoHS) Directive is under review, creating multiple opportunities for stakeholders to provide feedback to the European Commission.
• Ongoing evaluations will assess the directive’s effectiveness, its exemption methodology, and whether the list of restricted substances should be updated.
• IPC (Now Global Electronics Association) is coordinating industry input to help shape future RoHS rules in a way that safeguards health and the environment while supporting industry competitiveness.
• Companies using RoHS-listed substances are encouraged to share experiences and participate in IPC’s activities to inform upcoming decisions.
• Additional learning opportunities are available through an IPC EHS Tech Ed webinar scheduled for 14 November 2019.

The European Union’s Restriction of Hazardous Substances Directive, known as RoHS, aims to protect human health and the environment and maximize recovery of certain hazardous substances after their use. How well is the RoHS Directive working? We’re about to find out. Specifically, there are several opportunities between now and December to express feedback to the European Commission regarding the existing directive, the methodology for exemptions, and whether the list of restricted substances should be altered. IPC is coordinating input from the electronics manufacturing industry, aiming to influence future rules in a way that protects human health, the environment, and industry competitiveness. If your company uses substances that are on the RoHS list, we want to hear from you. Please check out this IPC document, which summarizes four activities that IPC is leading to collect and submit the industry’s input. This is an exciting time to rethink how chemical and product policies can help us to make electronics – and the world – better. Reach out to me if you have experiences with the EU RoHS Directive that you would like to share. By the way, we invite you to learn more about these opportunities in an upcoming IPC EHS Tech Ed webinar on 14 November 2019.

By Chris Mitchell, vice president, global government relations and Ken Schramko, senior director, North American government relations 

Key Summary

• IPC joined the European Partnership for Responsible Minerals (EPRM) to support responsible sourcing of 3TG minerals
• EPRM focuses on breaking links between mineral extraction, conflict, and human-rights abuses in high-risk regions
• Initiative supports SMEs through “Due Diligence Ready,” launching in 2021 for new EU rules
• IPC participates to avoid undue regulation and help members meet due-diligence expectations
• IPC-1755 standard facilitates conflict-minerals data exchange and is being revised to align with OECD guidance
• EPRM goals include knowledge sharing, SME education, upstream–downstream collaboration, and support for artisanal mines
 

On an issue of long-running concern to the electronics industry, IPC has joined the European Partnership for Responsible Minerals (EPRM) as part of its continuing efforts to help IPC members avoid undue regulation and navigate the challenge of responsible minerals sourcing. The EPRM is a multi-stakeholder partnership aiming to break the links between minerals extraction, conflict, and human rights violations and to increase the proportion of responsibly produced minerals in in conflict and high-risk areas (CAHRAs), especially the Democratic Republic of Congo (DRC). For years, the United Nations has reported that serious violations of human rights are widespread in the DRC, including acts of violence by government forces, criminal networks, and other armed groups that derive illegal revenues from smuggling and taxation of minerals from DRC mines. In response, the EPRM is building partnerships and sharing knowledge about due diligence related to four minerals – tin, tantalum, tungsten and gold (3TG) – which are used in many electronic components in key sectors such as automobiles, health care, ICT, aerospace and defense. The group is especially focused on assisting small and medium-sized enterprises with their due diligence requirements. Specifically, the EPRM is preparing to launch an initiative in November called “Due Diligence Ready,” through which companies will be able to access information, tools, and training materials to prepare for new EU rules coming into effect in 2021. IPC decided to join the EPRM at the urging of members of our European Government Relations Committee. The choice was clear: The electronics industry could put its head in the sand and ignore the issue; or it could work voluntarily with peers and stakeholders to encourage the responsible sourcing of minerals. The committee chose the latter course for two reasons. First, electronics companies, as consumers of these minerals, want to avoid any association with these conflicts and human rights abuses. Second, by engaging with policy makers and influencers, the industry hopes to avert and minimize undue regulatory burdens on industry. 

Our members’ actions, however strenuous, cannot fix the root causes of conflict in these regions. IPC has been involved in the conflict minerals dialogue for years, representing our members in proceedings and negotiations with policymakers; developing standards and guidance to promote industry compliance; and participating in the Organization for Economic Cooperation and Development (OECD) as it developed international guidance. For example, after the Dodd-Frank legislation was signed into law in the United States, and the U.S. Securities and Exchange Commission (SEC) finalized its conflict minerals regulation, IPC and its partners developed and released IPC-1755, a standard that helps industry suppliers and customers share conflict-minerals data along the entire global supply chain. Currently, this standard is undergoing revision to be better aligned with the OECD guidance, with a new version expected in early 2020. The IPC E-31H Conflict Minerals Data Exchange Task Group is conducting the revision process, and one of its co-chairs, Environmental Compliance Manager Nikki Johnson of Total Parts Plus (TPP), is serving as IPC’s representative to EPRM. Going forward, IPC will be working closely with EPRM members including Intel, Apple, Samsung and HP to implement supply chain practices that promote support responsible sourcing channels for minerals. EPRM is working to achieve this goal through four main objectives: • Develop and operate a knowledge platform to inform stakeholders on due diligence; • Educate SMEs in Europe about the importance of responsible mineral sourcing; • Facilitate connections between upstream, midstream, and downstream actors; and • Align “mining intervention strategies” and expand resources to support artisanal and small-scale mines to improve their practices and access global markets. Our focus is on making sure that our industry demonstrates its commitment to meaningful voluntary approaches because we have heard directly from European Commission officials and Members of the European Parliament that mandatory reporting requirements are being contemplated. U.S. Policy Direction in Suspense Meanwhile, in the United States, IPC continues to believe that collaborative, industry-driven approaches like those favored in Europe would be more effective than the current U.S. regulations, which were issued in 2012 under Section 1502 of the Dodd-Frank financial regulation law. In 2014, a federal court ruled that a portion of the SEC rule violated the First Amendment. In April 2017, the SEC’s Division of Corporation Finance issued new guidance indicating a lighter approach to enforcement. That said, the rule remains on the books, and the SEC could still initiate enforcement action if companies did not report on their due diligence as required. Earlier this month, the U.S. Government Accountability Office issued a mandatory annual report on the issue, concluding that little has changed since 2017: • In 2018, 1,117 companies filed conflict minerals disclosures—roughly the same number as in 2017 and 2016. • An estimated 56% of companies were able to report whether the minerals in their products came from the DRC or neighboring countries. That number rose significantly between 2014 and 2015 and has since leveled off. • Of the 56% who were able to report, 38% of companies reported their minerals came from a covered country, and 61% reported they could not definitively confirm the source of the minerals in their products, with both figures about the same as in prior years. • Approximately 94% of companies required to conduct due diligence reported conducting it, and of those, 89% reported using the OECD’s due diligence framework. • Violence continues to be prevalent in the regions of concern. The GAO notes that as of June 2019, a revision of the SEC rule was on the agency’s long-term regulatory agenda, “which means— according to SEC staff—that any action would likely not take place until after March 2020.” Please contact Ken Schramko if you have questions about responsible sourcing of minerals, IPC’s advocacy programs on this issue, or our membership in EPRM.