EDACafe Industry Predictions for 2020 – GreenSoft Technology, Inc.

2020 is ringing in a new decade of technological advancement. As governments focus more and more on environmental protection and the control of toxic chemicals, producers of electronic components and products will be facing an unprecedented expansion of substance control requirements.

In July 2019, the EU Restriction of Hazardous Substances (RoHS) Directive, which is applicable to most electronic products imported or sold within the EU, expanded its substance control list from six substances to ten for most categories of electrical equipment. These four new substances are phthalates commonly found in electronic products, forcing many material and component providers to redesign their offerings.  Similar RoHS regulations in China and UAE have also recently enacted expansions to requirements, both in scope and technical requirements. As such, regulations such as EU RoHS will become an ongoing validation exercise, as opposed to how many companies approach the issue today – as a one-time certification effort.

However, even more daunting than the RoHS-style requirements which are expanding globally is a new requirement coming out of the EU. Under the newly recast EU Waste Framework Directive, suppliers of electronic products which are imported or sold in the EU will experience a significant increase in obligations under Article 33 of the EU REACH Regulation. Under REACH article 33, suppliers must evaluate their products for SVHCs (Substances of Very High Concern – currently there are over 200 of them, with more added every 6 months), and if any are found present above reporting thresholds, the supplier must communicate the presence of the substance to professional customers, such as importers and resellers.

Under these new obligations, in addition to this supply-chain communication requirement, producers will now need to upload detailed information to a new database managed by the European Chemicals Agency.  Titled “Substances of Concern In articles as such or in complex objects (Products),” this “SCIP” database will not only be accessible by consumers and waste operators, but also to enforcement agencies. With the depth and accuracy of data needed to demonstrate compliance to REACH Article 33 obligations exploding in 2020, electronic component producers will be expected to provide this elevated level of data to their customers, as producers must start loading this data to the database on Jan 5, 2021.  Suppliers will be expected not only to provide the name of the SVHC present, but also the ID of the article containing the SVHC, the concentration range of the SVHC, the material category of the material containing the SVHC, safe use of the article and the SVHC, and more.

And don’t forget California Proposition 65! From 2017 to 2018, Prop 65 enforcement settlements increased by 40%.  Because Prop 65 is largely enforced by private bounty-hunter law firms, it is expected that this trend will continue. As many electronics companies have been forced to pay out large settlements, producers of electronic equipment will be looking more and more to component and material providers to provide the data needed to prevent these costly enforcement actions.

In summary, the expansion of RoHS requirements globally, the establishment of the far-reaching SCIP database, and the ever-expanding sea of California bounty-hunter law firms looking for Prop 65 violations are all coming together into the perfect storm. This is in addition to new substance use justification requirements facing medical device manufacturers under the newly recast EU Medical Devices Regulation (MDR), the recent increased enforcement of the EU regulation on Persistent Organic Pollutants (PoPS), as well as many other emerging and expanding global requirements.

So, get ready for some fun in 2020, and buckle up, because, this is just the beginning!

Tags: Predictions

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