IPC International Community magazine an association member publication
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IPC COMMUNITY 45 SPRING 2023 solvents, phthalates, flame retardants, and others, that a one-off approach to regulating chemicals often leads to substitution regret for alternatives that aren't much better than the original chemical. Yet, regulating the entire class of chemicals poses difficulties for the electronics industry because they are used across the supply chain and viable alternatives are often not available. If regulators univer- sally restricted or banned all PFAS, it would not address the challenges of remediating legacy sites. It also doesn't address how to replace so many chemicals at one time—so many chemi- cals that have provided critical utility without which there may be negative consequences to health and well-being. What Regulations Are on the Horizon? At IPC, we are focused on tracking two major policies: REACH Annex XV Restriction Dossier on PFAS A REACH restriction is an EU policy mech- anism implemented by the European Chemi- cals Agency (ECHA) to protect human health and the environment from risks posed by chemicals. Restrictions generally limit or ban the manufacture, placement on the market, or use of a substance. An EU member state, or ECHA, at the request of the European Com- mission, can initiate the restriction procedure if they are concerned that a certain substance poses a risk. Recently, the national authorities of Den- mark, Germany, the Netherlands, Norway, and Sweden submitted a proposal to ECHA to restrict PFAS under REACH. These nations first announced their intention to create the restriction, which will be one of the broad- est in the EU's history, in December 2019 and began collecting evidence in May 2020. On Feb. 7, 2023, the pre-publication for the restriction proposal was released and, in turn, many stakeholders are getting to work trying to address the broadest universal ban on PFAS. A future restriction on PFAS in the EU can have significant ripple effects across the globe and on the electronics supply chain. Once again, the big question is where and how PFAS are used and whether viable alternatives exist. TSCA Section 8(a)(7) Reporting and Record- keeping Requirements for PFAS The U.S. Environmental Protection Agency (EPA) has proposed a reporting and record- keeping requirement for PFAS under TSCA. Following amendments to TSCA implemented by the FY 2020 National Defense Authoriza- tion Act (NDAA), the EPA proposed that per- sons who manufacture (including import) PFAS since Jan. 1, 2011, must report information on their PFAS uses, production volumes, dis- posal methods, potential exposures, and haz- ards. For the purposes of the proposed rule, articles containing PFAS, including imported articles containing PFAS (such as articles con- taining PFAS as part of surface coatings), are included in the scope of reportable chemical substances. Providing data on PFAS from over a decade ago can potentially pose significant Where are PFAS found in electronics? • Wires and cables • Printed circuit boards • High temperature film capacitors • Liquid crystal displays • Semiconductors Fluoropolymers, a group of polymers within the family of PFAS, are used in electronics applications in high stress or harsh environments. Polytetra- fluoroethylene (PTFE) for example, is a fluoropolymer used in insulation on wires and cables where high-volume data transmission is required.