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February 22, 2018

Welcome to the February 2018 Design Chain Associates E-mail Newsletter!

In addition to DCA's newsletters, keep an eye on DCA's bi-monthly articles in TTI's MarketEYE Resource Center.

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EU REACH Update - Enforcement and more SVHCs

REACH-En-Force (Ref-4), coordinated by ECHA's Enforcement Forum, aimed to identify non-compliance with restricted substances under Annex XVII.

Inspectors checked 5,625 products comprising 1,009 mixtures, 4,599 articles and 17 substances. Overall 18% of products tested were out of compliance. Read the press release and read the report.

And don't forget that Annex XVII restrictions apply to your products too! It's not just SVHCs you have to ask your suppliers about. How many REACH "declarations" do you receive that are only about SVHCs?

That said, seven more SVHCs were added to the candidate list last month.

EU RoHS - More Exemption Renewal Draft Directives and a New Substance Review

Last week the European Commission issued a suite of draft Delegated Directives addressing Annex III exemptions 7(c)-II, 7(c)-IV, 8(b), 15, 21, 29, 32 and 37. I wrote a short article about it on LinkedIn and summarized the proposed renewals here. The article also briefly covers a new study to support the review of the list of restricted substances and to assess a new exemption request under RoHS 2. The key goals of the study are:

This will be an important study to pay attention to and participate in. Several of these substances, including diantimony trioxide, TBBPA and Beryllium, are widely used in electronic components and materials.

The study has an 18 month timeline and we can expect stakeholder consultations to begin in the near future.

California Safer Consumer Products: Draft 2018-2020 Priority Product Work Plan

DTSC will hold a public workshop regarding the Draft 2018-2020 Priority Product Work Plan on February 26, 2018, from 10:00 A.M. to 12:00 P.M. Pacific Time. DTSC is also holding a written public comment period from February 12, 2018, until March 9, 2018. Anyone interested may submit comments regarding the Draft Work Plan to DTSC.

DCA Articles & DCA In The News

February 17, 2018 LinkedIn: Some Long-Awaited Resolution for EU RoHS Exemptions and a New Substance Restriction Review. This article summarizes several draft delegated directives proposing to amend Annex III of RoHS to renew certain exemptions as well as information about a new substance restriction review.

February 15, 2018 ChemicalWatch: UAE's RoHS-like regulation causing 'mass confusion'. UAE ESMA fails to clarify what they need and fails to put in place the infrastructure necessary to implement it in time to meet the regulation's in-force date of Jan. 1, 2018.

Events to Attend

February 26-27, 2018: San Francisco, CA. ChemicalWatch's AsiaHub Summit USA. Mike will present two recent case studies of compliance failures, and what you can do to make sure your company is not the next one.

May 14-16, 2018: San Jose, CA. 2018 IEEE Symposium on Product Safety Engineering. Mike will discuss the relationship between Product Safety Engineering and Product Environmental/Human Health Safety and Compliance.

June 18-20, 2018: Portland, OR. ACS Green Chemistry & Engineering Conference. Mike co-chairs a session on the semiconductor and electronics industries. This will be an extremely interesting session - make plans to come to Portland now!! Details coming next month!

More to come! Stay tuned.

Contact and Feedback

We value your feedback and insights on the topics in this newsletter and anything else we're involved with. You can contact us at the number below, or simply reply to this e-mail.

This newsletter covers only a fraction of how we support our clients. DCA offers expertise and consulting services in all the areas covered above, as well as many others. Please contact us to discuss your needs.

Best Regards,
Michael Kirschner

Design Chain Associates LLC


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