Design Chain Associates December 2020 Newsletter

December 21, 2020

Welcome to the December 2020 Design Chain Associates E-mail Newsletter! Happy Holidays from DCA!

In addition to DCA's newsletters, keep an eye on DCA's bi-monthly regulatory-focused column in TTI's MarketEYE Resource Center and our new monthly product development-focused column in EE Times!

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Six months have passed since my last quarterly/periodic/occasional newsletter and I hope to return to a more frequent cadence, but can't promise that! I hope you have been well and have been staying safe and healthy.

Some Notes to SCIP To

As if 2020 were not already memorable enough, like everything else we as a civilization have been through this year SCIP will make 2021 and beyond seem less daunting since we will already have been through it. But until then, remember these important notes:

SCIP only applies for articles/complex objects placed on the market from January 5, 2021. You do not have to enter ANY DATA for items placed on the market before that date: it follows the REACH Article 33 notification requirements. If you are not familiar with the term placed on the market, it has a very specific meaning in the European Union; read all about it in the Blue Guide.
You can skip SCIP for shipments to the UK (including Northern Ireland) - as part of BREXIT the UK has not yet decided to implement a similar system. SVHCs are still disclosable, however.
According to ECHA, only the producer may register on SCIP. To be a producer, you must have a legal entity based in the EU and must be placing products on the market; if that's not you, it's someone downstream of you who should be asking you for the information they need to enter into the SCIP database. ECHA Q&A 1610 describes this and one way that a "foreign user" can support them.

Live Long and Prosper.

Mea Culpa: Lead in Glass or Ceramic is USUALLY NOT an SVHC

In October I published an article on TTI MarketEYE (since withdrawn) which stated that lead (Pb) in glass or ceramic is an SVHC. This is, in fact, rarely the case. Once that fact was firmly embedded in my brain I took the article down (replacing it with an update on the newly-released EU Chemicals Strategy.

Glasses and ceramics have their own chemical composition, just like any compound. Until and unless ECHA adds these specific chemical compounds to the candidate list of SVHCs, only the listed elements, like lead, and compounds, like lead monoxide, are reportable.

Pack 22 and Everyone's Favorite RoHS Exemptions

Last week, Öko-Institut e.V. announced that "A new RoHS project (Pack 22) for the assessment of sixteen requests for nine exemptions listed in Annex III of Directive 2011/65/EU has started. The study shall cover exemptions 6(a)/6(a)-I, 6(b)/6(b)-I, 6(b)-II, 6(c), 7(a), 7(c)-I and 7(c)-II of Annex III." Pack 18 had originally been intended to assess the requests for renewal of exemptions 6(a), 6(b), 6(c), 7(a) and 7(c)-I of Annex III but was suspended when "the applicant ... could not provide despite several clarifying consultations sufficient information to proceed with the assessment. Due to time constraints linked to the duration of the contract, it was decided consensually not to continue the assessment of the five above mentioned exemptions under this contract."

Fortunately that impass appears to have been resolved.

As nearly every product in nearly every RoHS Annex I Category takes one or more of these exemptions, I expect that this new Pack will get plenty of attention. Öko-Institut says "A stakeholder consultation is planned and is expected to be launched before the end of the year. For more details, please see the Technical specifications and the Project Description."

Chemical Watch Courses by DCA

I recently completed development of two "eLearning" courses for Chemical Watch that you or people you know may be interested in:

Short Course: The EU and New Legislative Framework for Product Manufacturers. This is a one-hour-long introduction for manufacturers to the European Union and how it differs from other markets and key aspects of the New Legislative Framework.
An Introduction to EU RoHS This four-hour-long course is a relatively "deep dive" into EU RoHS. Yes, there's that much to RoHS... this is really intended as an introduction for people who have responsibility to ensure that their company's products comply with RoHS requirements.

Comments and input are, of course, welcome!

Save the date: 2021 Green Chemistry & Engineering Conference

Scheduled for June 14-18 as a virtual conference, the 25th Annual Green Chemistry & Engineering Conference should be very exciting! With a focus on "Sustainable Production to Advance the Circular Economy" I expect to see lots of insightful presentations. If you have an idea for a presentation please let me know regardless of whether it's in the semiconductor/electronics space; the call for abstracts will open on January 4.

DCA Articles & DCA In The News

Catch-up on past DCA newsletters on our DCA In The News web page!

December 18, 2020 TTI MarketEYE: Another Look at Lead as SVHC and a Saudi Arabia RoHS Draft An explanation of why lead in glass is generally not an SVHC and a review of Saudi Arabia's draft RoHS regulation.

December 18, 2020 EE Times: Opportunities to Improve Electronics Environmental Safety Get involved in industry-wide efforts at the Clean Electronics Production Network (CEPN) and The International Electronics Manufacturing Initiative (iNEMI).

November 17, 2020 EE Times: Environmental/Human Health Safety: Optional or Not? Product safety isn't optional; why is environmental and human health safety?

October 20, 2020 DCA Newsletter: October 2020. SCIP, Conferences and Columns

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