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May 17, 2019

Welcome to the May 2019 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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Organo-Halogen Flame Retardants: The End is Nigh

The desire to eliminate additive organo-halogen flame retardants (OHFRs) continues to gain momentum in markets around the world. In our last newsletter we covered Canada's early steps in their process to restrict DBDPE (decabromodiphenyl ethane); today we have updates to actions in Canada, the USA and the EU.

Environment Canada, as of late last week, is looking to restrict DBDPE, which is in common use today as a substitute for decabromodiphenyl ether (DecaBDE, restricted by RoHS). A stakeholder comment period is now open through June 9 to collect information from industry. The call for information, and a schedule for the restriction process, is here.

The US Consumer Product Safety Commission, if you will recall, granted a petition to consider banning the class of organohalogen flame retardants (OFRs) in, among other things, electronic enclosures. They issued a guideline telling manufacturers to move away from this class of substances while engaging the National Academies to develop a scoping plan to conduct the hazard assessment for OHFRs as a chemical class. The National Academies has finally issued its report which finds that, while OHFRs cannot be treated as a single class, "the report outlines a process for assessing the toxicity of the 14 identified subclasses and identifies four scenarios that might occur, depending on how much data is available for the chemicals in a subclass. The report also uses two subclasses to illustrate how the proposed approach to the hazard assessment would work." This could set the stage for class-based, rather than individual chemical-based, restrictions in the future. Bottom line: Stay Tuned.

Finally, the European Commission, in support of the Circular Economy plan, is very near approval of an implementing measure under the Eco-design Directive, 2009/125/EC, that would - among other things - ban the entire class of brominated flame retardants (BFRs) in display, monitor and television enclosures (and associated stands) due to recyclability concerns. If you don't produce these types of products, don't get too comfortable: expect additional implementing measures with this requirement covering other product categories in the future.

Many electronics manufacturers continue to use OHFRs in enclosures. If you are one of them, now it the time to consider alternative designs, materials and - if needed - flame retardant technologies. If you don't know whether your enclosures do use an OHFR that isn't DecaBDE, which I suspect is the case for all the manufacturers that simply ask their suppliers whether the HIPS, ABS or PC/ABS resins they use are RoHS-compliant, now is the time for some real due diligence.

Given their history, the above-mentioned actions and other issues, OHFRs are fundamentally not a good long-term solution for any electronic enclosure application (or for a wide variety of other applications, it seems). Contact DCA for more information and guidance.

Our RoHS 2 Deep Dive is Available

Our well-received two-hour long "deep dive" into RoHS 2 held live last month is now available for download if you missed it. Order it now on the DCA RoHS 2 web page.

Coming in September: The Chemicals Management for Electronics & Electricals USA Conference

Once again I will be co-chairing another Chemical Watch conference Chemicals Management for Electronics and Electricals USA 2019 in Boston on September 16th and 17th. And again we have a great line-up of presentations and panel sessions! Get it on your calendar and, if you would like to attend, please let me know and I'll get a discount on the fee for you (newsletter recipients and clients only!).

DCA Articles & DCA In The News

Note that you can now catch-up on past DCA newsletters on our DCA In The News web page!

April 22, 2019 TTI MarketEYE: Follow-Up: Circular Economy, RoHS and San Francisco. An update on the Circular Economy and the electronics industry, plus an update on EU RoHS as well as the San Francisco Flame Retardance ordinance.

February 6, 2019 DCA Newsletter: February 2019. BFR Restrictions, an upcoming webinar and an upcoming conference.

Events to Attend

September 16-17, 2019: Boston, MA. Chemicals Management for Electronics & Electricals USA 2019. After successful conferences in San Francisco and Brussels, we will co-chair this important conference in New England. Attend for a comprehensive view on the forces driving chemical-related product and business model changes in the electronics industry, and to network with your peers, regulators and others. Contact me for a discount!

June 11-13, 2019: Reston, VA. ACS Green Chemistry & Engineering Conference. Come to fabulous Reston, VA, learn about where green chemistry is in use, where invention is needed, and network with the leaders in the field. We will have a short session focused on battery and photovoltaic technologies, as well as a call-to-arms for invention.

June 10, 2019: Washington, DC. The US Department of Commerce will hold its annual RoHS Conference from 9:15am to 12:15pm. A policy officer from the European Commission, Giuseppina Luvara, will talk about the REACH regulation, past and future. This marks the first time someone from the European Commission has spoken at this conference. In addition, Paul Tennant and Carl Magness of the UK Government, will talk about the latest developments on the RoHS (Restriction on Hazardous Substances) Directive and on the EU Circular Economy. For more information and to RSVP, please contact by Thursday June 6. Admission is free.

By the way, I will not be at this DoC conference; I will be on a plane to Washington, DC instead for the GC&E conference (and the US EPA's Green Chemistry Awards ceremony, which is later that day)! Had I known I would have come in a day earlier. However, I will be attending the ITI/IPC "Conference on Emerging & Critical Environmental Product Requirements on June 7 in San Jose so let me know if you'll be there!

More to come! Stay tuned.

Don't forget to visit our China RoHS Website! We provide access to all the documents you need to understand and comply with the China RoHS regulation. Note that even though EEPs in the initial Catalog had to comply with substance restrictions as of this past March, as of today MIIT has still not issued the Conformity Assessment System!

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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