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IPC’s D.C. Focus: Chemicals Regulations, Lead-Free, Export Controls

From North America to Europe, Asia, and beyond, the future of the electronics manufacturing industry is shaped in many ways by government policies. That’s why IPC maintains an active, multifaceted government relations program, including leadership and networking opportunities for member company executives. Here’s a snapshot of a few of the issues we’re working on currently, and how you can learn more and get involved.

EPA Proposes Rule on Chemical Data Reporting

The U.S. EPA recently proposed changes to the Toxic Substances Control Act (TSCA) Section 8(a) Chemical Data Reporting (CDR) requirements ^[1] and the description of small manufacturers. The rule would continue to require data collection every four years concerning the processing and use of certain chemicals above threshold production volumes, generally 25,000 pounds per reporting year.

The proposed rule could do more to provide reporting relief for PCB manufacturers who send inorganic byproducts for recycling, which has been a longtime goal of IPC. We will continue to press relevant decision-makers on this issue as well as submit official comments on the rule.

Meanwhile, the EPA also has begun the prioritization process for chemicals to be evaluated under Section 6(b) of TSCA ^[2]. The process begins with a list of 40 candidate chemicals ^[3] and includes a public comment period during which EPA welcomes relevant information, such as scenarios of use and exposure potential. IPC plans on submitting comments to the EPA, and we invite you to bring your questions or concerns on environmental policy issues to KellyScanlon@ipc.org.

IPC Reviving R&D on Lead-free Electronics in High-reliability Sectors

Over the last 15 years, tighter international regulations on the use of lead (Pb) have resulted in a global transition to Pb-free consumer electronics. However, the aerospace, defense, and high-performance electronics sectors have been slower to abandon the use of lead in part because there is not enough data on the performance of Pb-free products. The necessary research has never been completed.

Now, IPC and a consortium of manufacturers and academic institutions are working with more than a dozen members of Congress to secure $15 million in federal funding to put the R&D back on track. Congress is likely to send the President a defense appropriations bill by fall, at which time we will know whether we have been successful. A great deal of advocacy will take place between now and then. Learn more and contribute your expertise to IPC’s Pb-free electronics efforts by emailing me and checking out our Pb-free resources ^{[4 & 5]}.

Export Controls: What You Need to Know Now

U.S. export control rules have changed significantly over the last decade, and more changes are expected over the next few years as policymakers tackle the treatment of emerging and foundational technologies and respond to geopolitical developments. To help electronics manufacturers comply with U.S. export control rules and stay abreast of regulatory developments, IPC recently held three training workshops in California, Illinois, and Virginia sponsored and hosted by TTM Technologies.

Led by Gary Stanley—president of Global Legal Services PC and one of the nation’s top legal experts on export controls—the workshops covered the regulatory framework, compliance, and recent and anticipated reforms under both the Export Administration Regulations and International Traffic in Arms Regulations. Officials from the Commerce Department’s Bureau of Industry and Security were also on hand to discuss enforcement trends and priorities. Experts from the Department of Defense’s Executive Agent for Printed Circuit Board and Interconnect Technology spoke to attendees about initiatives in progress to address business risks in the defense electronics supply chain. 

The U.S. Government has been clear and emphatic. Ignorance is no excuse for violation of export control rules. If you missed the workshops but want to get up-to-speed, please let me know as we are considering additional workshops and webinars in response to member demand.

Join IPC for Our D.C. Advocacy Event, May 21–22

One of the most effective ways to influence change in Washington is for industry leaders like you to come to D.C. and make sure our industry’s voice is heard. IMPACT Washington, D.C. 2019 is an opportunity to interact with fellow business leaders and advocate before top policymakers on the issues that affect our industry’s future. Our issue priorities this year include the skilled workforce, the defense supply chain, and the U.S.-Mexico-Canada trade agreement (USMCA). Special guests will include former Indiana Senator Joe Donnelly, former Virginia Congressman Tom Davis, and top officials in the DoD and Department of Education, U.S. EPA, and other agencies. We’ll also arrange and support meetings with your own members of Congress. Learn more and register for IMPACT Washington, D.C. today ^[6].

We Invite Your Input and Participation!

Our success depends in large part on the guidance and support we receive from IPC members. If you’re a member of IPC and want to be in the loop on our government relations activities, you can opt in to receive advocacy updates. If you are not an IPC member (or you’re not sure), please send a note to friends@ipc.org, and our staff will add you to our email list.

See you here again next month!

Connect With Us

• IPC Governmental Relations Staff
• Chris Mitchell on Twitter
• IPC on Twitter
• Email preferences

References

1. EPA. “TSCA Chemical Data Reporting Revisions and Small Manufacturer Definition Update for Reporting and Recordkeeping Requirements Under TSCA Section 8(a),” Vol. 84, No. 80, April 25, 2019.
2. EPA. “Assessing and Managing Chemicals Under TSCA: Prioritizing Existing Chemicals for Risk Evaluation,” March 20, 2019.
3. EPA. “Assessing and Managing Chemicals Under TSCA: List of Chemicals Undergoing Prioritization,” March 20, 2019.
4. Mitchell, C. “IPC Working to Revive R&D on Lead-free Electronics in High-reliability Sectors.”
5. Pb-free Electronics Risk Management (PERM) Council.
6. IPC. IMPACT Washington, D.C. 2019.

Chris Mitchell is IPC’s VP of global government affairs and can be reached at ChrisMitchell@ipc.org.