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The Government Circuit: Green Regulations, the Economy, COVID-19, and ‘Decoupling’ in Focus for IPC This Fall

Summer may be winding down, but autumn is shaping up to be a busy advocacy season for IPC. With the U.S. Congress and European Commission back at work after August breaks, the U.S. presidential election looming in November, and the continuing spread of coronavirus, the next several months will have long-term impacts for the electronics manufacturing industry.

This month’s column provides you with an overview of the latest worldwide regulations you should be attuned to, the global economic landscape, and opportunities to make your voice heard with policymakers. If you have any questions or would like to learn more, please contact a member of our government relations staff ^[1], visit our government policy web pages ^[2], and/or subscribe to our weekly e-newsletter ^[3].

U.S. EPA Having an Active Start to September
On September 4, the U.S. Environmental Protection Agency (EPA) made two major announcements of interest to our industry.

First, the EPA released the final list ^[4] of businesses subject to fees for the 20 high-priority substances ^[5] listed under the Toxic Substances Control Act (TSCA) Fees Rule ^[6]. Changes have been made since the preliminary list was released on January 27, which IPC wrote about in February ^[7]. Businesses identified on the final list must notify the EPA regarding their intention to form or join consortia to pay fees that defray the costs of risk evaluations. Fee payments are required 120 days after the final list is released, although the EPA may incorporate flexibility into the payment schedule.

Meanwhile, the EPA also released the final scope documents ^[8] for the risk evaluations of 20 high-priority substances ^[5] under TSCA. These documents will outline a three-year process for determining unreasonable risk for various conditions of use of high-priority substances. IPC has already engaged with the EPA during the review period for the draft scope documents on Tetrabromobisphenol A and formaldehyde, and we will be reviewing all of the final scope documents to determine their applicability to the electronics sector.

Please let us know your questions, concerns, and suggestions about the TSCA fee obligations. We welcome your review and insights on the use of these chemicals and on the recent EPA action generally.

Does Your Company Use PFAS to Make Electronics?
Regulators in the United States and the European Union are still eyeing potential regulation on chemicals in the per- and polyfluoroalkyl substances (PFAS) class, and your input can sway their decision-making. In July, IPC completed a screening study ^[9] to gain a better understanding of the evolving policies shaping the production and use of PFAS. IPC needs you to review the preliminary findings from our screening study to confirm whether we accurately captured the uses of PFAS in electronics products and processes. Please send your feedback to Kelly Scanlon. For more information, check out IPC’s recent blog post on PFAS regulation ^[10].

Interested in Chemical and Product Regulations in Asia?
The Asia-Pacific region is home to several of the world’s largest nations and most dynamic economies, and many governments in the region have established comprehensive environmental, health, and safety (EHS) policy frameworks. Please check out these new white papers from IPC on the evolving chemicals regulations in China, Japan, Singapore, South Korea, Taiwan, and Thailand ^[11]. These papers provide a detailed look at the history of the policies, recent regulatory updates, and the regulatory trends in the respective countries.

How Is COVID-19 Affecting the U.S. and European Electronics Industry?
Since I last penned a column for I-Connect007, IPC Chief Economist Shawn DuBravac released the first two IPC Monthly Economic Reports, covering one of the most volatile periods in our economic history and providing industry intelligence on the economy, industrial production, PCB demand, and more. The July report ^[12] forecasts an uneven recovery over the next six months, and the August report ^[13] includes new data on the EU market, forecasts for the major European economies, and updates on the U.S. economy amid the ongoing COVID-19 pandemic.

Relatively speaking, the electronics industry in the U.S., Europe, and Asia has been holding up and performing well, and we hope this trend continues. While manufacturing production in the U.S. and Europe is down over the past year, electronics production has actually increased.

As the pandemic persists, IPC remains alert to the evolving science and policies, and we recently released new information ^[14] aimed at helping our members assess and manage risks in the workplace. Please check out an updated IPC report ^[15] that answers questions we have received related to cleaning, disinfecting, and contact tracing.

IPC Calls for COVID-19 Recovery Bill With Pro-Industrial-Base Provisions
As of this writing, the U.S. Congress is still struggling to reach a deal on another COVID-19 recovery bill, and IPC is calling on them to include provisions of importance to the electronics manufacturing industry. In a recent letter ^[16] sent to the top four leaders in Congress, IPC urged Congress to support the following measures:

• Modified unemployment insurance benefit to continue essential support for laid-off workers, helping to maintain consumer demand while reducing disincentives to return to work
• Common-sense liability protections shielding businesses that have taken “reasonable steps” to comply with government workplace safety guidelines
• Paycheck Protection Program extension and the Safe and Healthy Workplace tax credit
• Supplementary funding to sustain and rebuild the defense industrial base
• Aid to state and local governments to ensure essential services are maintained

More information about our industry’s role in the U.S. economy can be found in this report ^[17], and our Roadmap to Economic Recovery ^[18] summarizes our policy agenda. With election season rapidly approaching, Congress may be spurred to act, and when they do, we will do our best to ensure the industry’s needs are accounted for.

Should Manufacturers Pull Away From Global Markets and Standards?
Relocating manufacturing facilities is not easy, fast, or in some cases, even desirable, but due to recent events like COVID-19 and trade wars, it is a conversation that is increasingly taking place.

On September 1, I, along with other industry experts, discussed strategies for mitigating reshoring risks and other challenges faced by the electronics industry at an Electronics Town Hall. I opined that the West’s wariness of doing business with China is a long-term trend and that the ongoing “decoupling” between the two economies is likely to continue no matter who is elected U.S. president in November.

Meanwhile, IPC President and CEO John Mitchell had two powerful opinion pieces published recently: one on the need for U.S. policymakers to do more for the electronics manufacturing industry ^[19], and the other calling for increased U.S. participation in international standards organizations ^[20]. I urge you to read both these pieces if you have not done so already.

Make Your Voice Heard!
Please note that the IPC Advocacy Team page ^[21] makes it easy to communicate with your elected officials about our industry’s priority issues, or you can reach out and let us know what you think so that we can advocate for you. We are here to amplify your voice and that of the entire electronics manufacturing industry.

As always, please let us know if you have any questions or suggestions for IPC advocacy in the coming months. We are here to support you as we all navigate these challenging times.

References

1. IPC Government Relations Staff.
2. IPC Government Relations.
3. IPC, “Global Advocacy Report.”
4. EPA, “Final Lists Identifying Manufacturers Subject to Fee Obligations for EPA-Initiated Risk Evaluations Under Section 6 of the Toxic Substances Control Act (TSCA); Notice of Availability,” Federal Registry, September 4, 2020.
5. EPA, “Chemical Substances Undergoing Prioritization: High-Priority.”
6. EPA, “Toxic Substances Control Act (TSCA) Administration Fees.”
7. Kelly Scanlon, “U.S. EPA Fees for Toxic Substances May Apply to Your Company This Year,” IPC.
8. EPA, “Final Scopes of the Risk Evaluations To Be Conducted for Twenty Chemical Substances Under the Toxic Substances Control Act; Notice of Availability,” Federal Registry, September 4, 2020.
9. IPC, “Preliminary Findings: PFAS Use in the Electronics Industry,” July 31, 2020.
10. Matthew Chalkley and Kelly Scanlon, “PFAS Regulation in the Electronics Industry: Should We Be Concerned?” IPC.
11. Kelly Scanlon, “Interested in Chemical and Electronics Product Regulations in Asia-Pacific Countries?” IPC.
12. Shawn Dubravac, “Economic Outlook: July 2020,” IPC.
13. Shawn Dubravac, “Economic Outlook: August 2020,” IPC.
14. David Krause and Kelly Scanlon, “IPC, Helping You Assess and Manage COVID-19 Risks at Your Workplace,” IPC.
15. IPC, “IPC Special Report: Workplace Measures To Manage COVID-19 Risk—Dispelling Myths With Effective Methods,” August 2020.
16. Chris Mitchell, “Letter to the Top Four Leaders in Congress,” August 4, 2020.
17. IPC, “Interconnecting America’ Economy: The Economic Impacts of the U.S. Electronics Manufacturing Sector,” 2020.
18. IPC, “An IPC Roadmap to Economic Recovery.”
19. John Mitchell, “We are to blame for the US manufacturing decline,” The Hill, September 1, 2020.
20. John Mitchell, “The World Needs American Leadership in Setting the Technological Standards of the Future,” Nextgov, August 31, 2020.
21. IPC Advocacy Team.

Chris Mitchell is IPC’s VP of global government affairs. Contact him at ChrisMitchell@ipc.org.