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Welcome to the September 2009 Design Chain Associates E-mail Newsletter!
If you've received this newsletter, are not on the DCA mailing list and would like to be, please sign up.
Last March, after a lengthy hiatus, our newsletter returned to your inbox. We declared our desire then to publish it quarterly. Time, however, has not been on our side and here we are 6 months later. Well, we're doing better but still not quite at quarterly. So here's your semi-annual quarterly newsletter!
That said, we are now producing a paid newsletter 4 to 6 times per year covering key developments in environmental regulations and their impacts on our subscribers, which is introduced below in item 3.
In addition, this issue covers several other interesting topics you'll only find discussed - accurately and coherently - here at DCA. You'll see what we mean. Enjoy!
Is your company prepared for economic recovery? There are many signs that an economic recovery is underway or soon will be. Book-to-Bill, inventories, lead times, prices, these are all leading indicators that something is underway.
While economic recovery is difficult to predict and we’ll leave that issue to the many talking heads on the news channels and in Washington, some things are very easy to predict. Here are our practical rules for recovering markets:
DCA rule number 1: Supply always lags demand during recovery
DCA rule number 2: The early bird get the worm or the capacitor
DCA rule number 3: Supplier relationships matter
DCA Rule 1: Supply lags demand during recovery.
DCA Rule 2: The early bird.
DCA Rule 3: Supplier relationships matter. Always true, but more so in a crisis. Never forget that this is a business run by people.
Want more information? DCA can help. We have decades of supply chain experience and have managed through many periods of constraint for companies large and small. Let us do an affordable rapid review of your supply chain processes and we’ll show you how to position yourself to thrive in the upcoming recovery. Contact Tom Valliere for more information.
More and more often, companies large and small are coming to us asking for help staying up on all the new and changing environmental regulations that impact their products in their markets. We have a couple different levels of service for helping companies track and deal with the onslaught of environmental regulation around the world:
Level 1 is a standard service intended to satisfy the needs of companies that do not have the resources or desire to devote internal resources to legislation tracking, have a relatively limited market focus, and are able to interpret the impact to their products. This consists of a report you will receive every 2 to 3 months, focused on critical regulations in the top markets that DCA follows. We provide links to the actual regulatory documents, as well as a concise appraisal of its potential to impact our subscribers, based on our knowledge of our subscribers' products, markets, and methods of selling. The Level 1 services is often supplemented by consulting support. Contact us for a sample copy.
Level 2 is a customizable service intended to satisfy the needs of companies that do not have the resources or desire to devote internal resources to legislation tracking, require specific product impact assessments which are customized based upon country and or geographic region, and want clear and explicit recommendations for actions based upon their products, markets, sales methods and other company-specific requirements. The Level 2 service also includes access to DCA‘s team of highly respected experts who are able to answer questions directly and have access to many government agency officials worldwide.
Contact Mike Kirschner for more information on either or both of these services and learn how we can take this burden off your back in a surprisingly affordable manner.
The venerable passives distributor TTI, a long-time supporter of DCA, asked us to provide bi-monthly articles on environment and supply chain to their MarketEye Research Center. MarketEye is TTI's excellent online vehicle for providing the most accurate and up-to-date market information in the Interconnect, Passive & Electromechanical (IP&E) industry. We urge you to take a look, or pass the link on to your component, design engineering and procurement people.
Last month's installment was a particularly insightful report by Kris Pollet, DCA's Brussels-based Director of EU Law & Policy, entitled Elections for New European Parliament: Impact on Environmental Policy Making.
How does Kris think the parliamentary elections will impact the RoHS and WEEE recasts now in the pipeline? Read the article!
Enforcement agencies in the European Union Member States have become very aggressive in identifying "producers" that have not taken the appropriate actions as required by legislation such as RoHS, WEEE, the Battery Directive and REACH. If your company has not fulfilled its obligations your business risk is very high. Consider taking action now to avoid what could become an "enforcement action". Do not become lulled into a false sense of security by the lack of enforcement action headlines; most companies and enforcement agencies have been able to resolve identified non-compliances without public disclosure.
The reasons for "flying under the radar" could include
The following observation can be made:
Enforcement agencies have started to actively share enforcement data, so there is a very high probability that if you are identified as being in violation in one Member State you will be subject to a close review in all Member States where your product is "put on the market".Member States have made producer registration databases a public record that may be viewed by your competitors, NGOs, and enforcement agencies in other Member States. This public viewing of information has made it very easy to identify companies that have not registered as producers. The economic downturn has required all government agencies to demonstrate the value of their services and we suspect that in some cases environmental compliance has been viewed as a revenue source and generator of jobs for the EU Member State governments. It is no longer a question of if violations will be identified; it is a simple matter of when will enforcement actions be forthcoming for those companies flying under the radar.
DCA is able to help you identify actions required to comply, as well as deal with enforcement body inquiries. Contact Ken Stanvick for a confidential discussion of your situation.
After a 20-year drought of US federal environmental leadership, we are now seeing the first steps of the Obama administration and a Democratic congress towards once again becoming a force in international environmental policy. It's a little slow and clunky, and it's not all "good", but it's been a while since there has been so much activity at this level that actually might amount to something. So it's time, particularly if you are located in, or sell into, the United States of America, to sit up and take notice that federal actions related to environmental regulation of products are actually happening. Here's a short rundown:
So just how good is your traceability back to the mines producing the raw material? And how good can it be when the miners are under the gun to sell (for a pittance) ores that are then quickly smuggled out of the Congo? Some companies have policies, but reality and a lack of supply chain control and information makes enforcement of these policies difficult at best. Is this bill - driven by NGOs - the most effective way to address this problem? Let us know your thoughts.
We've seen media articles and consultant press releases and newsletters simply assuming this is equivalent to EU RoHS and that it impacts "electronic industry" products. Evidently the congressman NEMA got to introduce it, Michael Burgess (R-TX), did too. The reality is that it is vastly different - it impacts "electroindustry" products, defined quite clearly in the bill as
"any product or equipment that is directly used to facilitate the transmission, distribution, or control of electricity, or that uses electrical power for arc welding, lighting, signaling protection and communication, or medical imaging, or electrical motors and generators."This is obviously not the EU RoHS/WEEE scope. This scope is intended to protect NEMA's membership from any state-based RoHS-like regulation that might impact them as well as help give them the appearance of improving environmental performance of their products.
Harmonization of these types of laws is key for industry; this bill is extensively unharmonized with anything else out there. We are now hearing from multiple sources that it is essentially dead.
One key lesson here is to be very careful about who and where you get information from.
At first blush this is a good idea - just why ARE those substances there? Hello? Chemical industry? Can you please explain this? The chemical industry has successfully fought nearly every attempt to force them to produce environmental and health data on their products for decades. That changed with REACH.
Unfortunately, many of the substances are very high volume and used in all sorts of applications. This is a bigger issue than simply removing these substances from commerce (and then, only in the US); while this might be an interesting first step, it is not the far-sighted solution article manufacturers and the planet need (for example, what do we replace those 300 substances with in order to not completely terminate the economy while improving the environment?). We've been talking to deep-thinking academics; environmental thought leaders in major multinational corporations in aerospace, automotive, and electronics; key NGOs; and government regulators about this. The goal is fairly clear, but the path towards it is not, yet.
DCA's PCCA program helps companies that must respond to requests from regulatory agencies and customers for environmental compliance information. These requests often require completing detailed forms (such as IBM's Product Content Declaration, or PCD, form) that often ask for quantitative reporting of substances of concern contained in products, or otherwise require detailed knowledge of substance content and application, such as HP's General Spec for the Environment. The tasks of data collection, assessment of chemical content, and correct form completion can be especially daunting for many SMEs. DCA, in partnership with GreenSoft Technology, provides our clients with a suite of services, including:
Unfortunately, the California DTSC had not yet delivered its next version of the draft regulation on alternatives assessment, despite the fact it was promised on August 4. We expect it to be published this month.
In the meantime, read this DCA-written article from TTI's MarketEye on California's Green Chemistry Initiative to understand our role, what the legislation is about, and our perspective on it.
DCA appears two days in a row, starting off the conference with an in-depth workshop on REACH, then following up on Tuesday with a one-hour update.
A. REACH Workshop: Today and the Future
Monday, November 9, 1:30 pm-5:00 pm
Instructor: Michael Kirschner, President, Design Chain Associates
An in-depth primer on the intricacies of complying with the European Union’s Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation. This session will give you a full briefing on the complex document. Designed for those - particularly article manufacturers - who are less familiar with REACH and need additional background, this workshop is an invaluable introduction to the issues that will be discussed during the conference on November 10.
B. REACH — A Critical Update
Tuesday, November 10, 10:30 am-11:30 am
This update will cover key issues and that impact article manufacturers, including authorization and the new proposed candidate SVHCs. We'll also touch on formulator challenges.
There will be plenty of other great speakers and topics, plus you're in LA in the fall! Get more information and register to attend It’s Not Easy Being Green: Complying with Changing Global Environmental Laws in Irvine, CA.
We value your feedback, insights, and questions on the topics in this newsletter and others. Please contact any of us toll-free at the numbers below, or simply reply to this e-mail.
Best Regards,
Michael Kirschner, 866.DCA.7676 x2
Ken Stanvick, 866.DCA.7676 x4
Tom Valliere, 866.DCA.7676 x5
