DCA Articles and DCA in the News
August 23, 2022 TTI MarketEYE: There's a World of Changes in Product and Packaging Regulations. This month's column covers the updated EU Blue Guide, the French packaging and ink substance restriction, and the progress of a new Chinese VOC standard for electronics.
June 30, 2022 TTI MarketEYE: My Finger Is on the Pulse, but This May Be Arrhythmia. OEHHA failed to pass updates to Proposition 65 short-form warnings in time, and MCCPs and TBBP-A are to be restricted under the EU RoHS Directive.
April 18, 2022 EE Times: A Brave New Circular World. I don't usually discuss regulatory requirements in this column, but today I am.
April 13, 2022 TTI MarketEYE: Q2 Global RoHS Updates: There's No Constant Like Change. The European Commission is upending nearly the entire breadth of environmental regulations that apply to your products. Are you ready for it?
March 24, 2022 EE Times: Systems Thinking and Electronics for the Circular Economy. How does systems thinking apply at the electronics industry level? And is CEP the right organization to do it? They're the only one to do it...
March 10, 2022 PCB Chat: PCB Chat 94: Michael Kirschner on Sustainability Standards. We discuss the open comment period for RoHS 3, the circular economy, and why environmental and sustainability standards have yet to achieve their goals.
February 18, 2022 EE Times: Systems Thinking and the Electronics Engineer. Thinking more broadly and at a higher level enables more robust design. That's 'systems thinking' in a nutshell.
February 17, 2022 TTI MarketEYE: New RoHS and REACH Recommendations Would Add Additional Requirements for Electronics Manufacturers. With more changes to RoHS and REACH just around the corner, electronics manufacturers will soon face a new wave of environmental compliance and regulatory guidelines - and added technical and administrative requirements that will demand more time and resources.
January 17, 2022 EE Times: A Review and a Way to Start. Let me sum up...
December 16, 2021 TTI MarketEYE: Compliance Update: Conflict Minerals, PIP (3:1), Saudi Arabia's 'RoHS' Law. IBM's Conflict Minerals Journey, plus updates on PIP(3:1) and Saudi Arabia RoHS.
December 13, 2021 EE Times: A Modular Smartphone. Another example of a modularly designed, repairable, and upgradeable electronic consumer product. This should be the norm, not the exception.
November 14, 2021 EE Times: Leading Us Out of the Darkness. In this month's column I discuss the laptop produced by Framework (not a DCA client). This product of thoughtful #engineering is a strong step in a circular direction for a relatively complex piece of electronic equipment.
November 10, 2021 EPSNews: Electronics Industry Gets More Time to Replace PiP 3:1. EPA responded to industry concerns and pushed out the compliance date with the PIP (3:1) ban to October 31,2024.
October 19, 2021 TTI MarketEYE: U.S. EPA Extends PIP (3:1) Compliance Deadline; UKCA Mark Delayed - and More. The US EPA is starting to flex its muscle; the electronics industry - and others - must pay attention.
October 12, 2021 EE Times: Update Your Product Reliability Targets. I may be an obsolete reliability engineer but I understand the effect that an extended, second, or even third use life may have on a product and brand equity. Talking to a current reliability expert, Fred Schenkelberg, about reliability, derating, and electronic product design resulted in this month's column in EE Times.
September 20, 2021 EE Times: Durable and Sound. The B&O Beosound speaker gets Cradle-to-Cradle Bronze, the first piece of electronics to do so. I will have more to say about this. And the French government works on electronics durability. Quoi??
September 2, 2021 Green Science Policy Instutite: Guidance on New PFAS Reporting Rule for Manufacturers. This article provides an excellent overview of the proposal. We got a nice shout-out for our "useful ideas for short-term actions businesses can take to prepare for this rule", and Hannah Ray provides some useful ideas of her own for long-term actions to consider.
August 23, 2021 TTI MarketEYE: PFAS Updates, EU and Saudi Arabia RoHS: A Busy Summer for Environmental Compliance. Plenty going on all over the world.
August 12, 2021 EE Times: Design for Repair and Upgrade. Design for reparability and upgradability are de rigueur for the circular economy. Get ready for it.
July 14, 2021 EE Times: Toxic Chemicals in Electronics. Specifying components and materials without knowledge and consideration of chemical substance composition is an ever-growing business risk.
July 6, 2021 Chemical Watch: China close to finalising test methods standard for phthalates in electronics. Does producing a Chinese standard mean MIIT will be adding phthalates to China RoHS? Maybe yes; maybe no.
June 18, 2021 TTI MarketEYE: Changes Ahead for Packaging Requirements and Derating Guidelines; RoHS Survey Results Released. More restricted substances for packaging; why derating may become more popular; and some EU RoHS survey results that may influence the next recast.
June 15, 2021 EE Times: The Other Risk of Using Toxic Materials. The electronics industry is rapidly ceding control of its destiny. Is it too late for actual leadership? Is the CEP the leadership the industry needs?
May 19, 2021 EE Times: Durability, Derating, and Circularity. As EE Times Editor in Chief Brian Santo said, "Designing for extended product life is the same as plain old designing: there are trade-offs." This is the truth. And you better make them or your brand equity will decline as your repair/warranty costs skyrocket.
April 30, 2021 Advanced Sustainable Systems: Why the Circular Economy Will Drive Green and Sustainable Chemistry in Electronics. A perspective paper for the upcoming issue of the journal which has significant content related to the electronics industry.
April 18, 2021 EE Times: The Circular Electronics Partnership - Bold and Optimistic. I review Pathway 1, Design for Circularity.
April 9, 2021 TTI MarketEYE: TSCA Section 6(h) and More RoHS Exemption Renewal Consultations. The US electronics industry gets broadsided by the EPA and the march of EU RoHS exemption renewal application stakeholder comment periods continues.
March 16, 2021 EE Times: Another Sustainability Standard and a Circularity Limitation. The TCO Certified series of sustainability standards and the problem with simple substance bans.
March 9, 2021 DCA Newsletter: March 2021. DCA Courses at Chemical Watch, TSCA, EU Battery Directive, Prop 65 Short-Form Warning changes, and more!
March 1, 2021 Bloomberg Environment & Energy: Electronics Makers Plead for Pause in EPA Toxic Chemical Ban (1). The electronics industry feels the sting of TSCA for the first time in over a generation and neither the EPA nor the industry are prepared for it.
February 23, 2021 TTI MarketEYE: Major Changes to EU's Battery Directive; California's Prop 65 Warning Gets an Update. The Battery Directive goes circular while the Prop 65 Short-Form warning gets longer.
February 14, 2021 EE Times: Standards as a Circularity Checklist Starting Point. Don't boil the ocean: start with what has already been done.
January 17, 2021 EE Times: Product Environmental/Health Safety and Performance Metrics. Identifying and defining metrics: first step to a checklist.
December 21, 2020 DCA Newsletter: December 2020. SCIP, Mea Culpa, RoHS Pack 22, DCA Courses at Chemical Watch, Conferences and Columns
December 18, 2020 TTI MarketEYE: Another Look at Lead as SVHC and a Saudi Arabia RoHS Draft. Lead in glass or ceramic is usually NOT an SVHC; Saudi Arabia plans a RoHS that could be a radical departure.
December 18, 2020 EE Times: Opportunities to Improve Electronics Environmental Safety. Where to get involved in industry-wide efforts.
November 17, 2020 EE Times: Environmental/Human Health Safety: Optional or Not?. Product safety isn't optional; why is environmental and human health safety?
October 20, 2020 DCA Newsletter: October 2020. SCIP, Conferences and Columns
October 19, 2020 EE Times: Is the Biological Nutrient Cycle Possible for Electronics?. An example of a biologically-based material with electron transport functionality demonstrates that there are always other ways to approach a technology challenge.
October 15, 2020 TTI MarketEYE: European and U.S. Updates: No SCIP Delay, and More. EU Chemicals Strategy, and fluorinated flame retardants in polycarbonates are halogenated.
September 14, 2020 EE Times: Designing for Circularity: Hard Disk Drives. REEs and HDDs - circularizing what we destroy.
August 14, 2020 EE Times: Designing for Circularity. The next step in circularizing products is to really understand what it means and what prevents circularity.
August 11, 2020 TTI MarketEYE: REACH Declarations, Packaging Materials and Endangered Elements. We look at what REACH CofCs should contain, the Toxics in Packaging Clearinghouse's call for comments on new substance restrictions, and the American Chemical Society's alarms on endangered elements.
July 17, 2020 EE Times: From Linear to Circular Product Cycle. The first step in circularizing: realizing that we are making decisions without considering circularity and the challenges that brings.
June 26, 2020 TTI MarketEYE: RoHS Updates: Writing Better Declarations; A New Harmonized Standard. I continue my quixotic mission to improve the electronics industry's understanding of what they think they understand so well: RoHS. Or, "why engineers shouldn't compete with word nerds".
June 16, 2020 EE Times: The Electronics Industry Response to Environmental Regulations: Is it Enough?. I look at where the electronics industry is in relation to the demand for improved product environmental and human health safety performance. While there are spots of brilliance, the landscape could be improved.
May 12, 2020 EE Times: Why the Electronics Industry is Being Regulated. EE Times has published my second column, as I make my way along the path of describing what it will take to embed circularity into the electronics industry (and, perhaps, other manufacturing industries).
May 1, 2020 EE Times: EETimes On Air. Brian Santo, EE Times Editor in Chief, interviews me about electronics, environmental regulations and circularity. My segment starts at 17:18, though the rest of the episode is interesting as well.
April 20, 2020 DCA Newsletter: April 2020. SCIP, new EE Times column, free COVID-19 standards
April 17, 2020 EE Times: Environmental and Health Safety; Electronics and the Circular Economy. Read my new column in EE Times, focused on Design for Circularity! Let me know what you think.
April 14, 2020 TTI MarketEYE: EU and U.S. RoHS Update: Expiring Exemptions and Updated Directives. Keeping up with EU RoHS continues to be challenging. The fantasy of harmonizing RoHS implementations around the world is briefly explored in the US.
March 5, 2020 Chemical Watch: Tackling the electronic sector's biggest chemical mangagement challenges: Q&A with Michael Kirschner. What do you think? Are these the biggest challenges?
February 28, 2020 TTI MarketEYE: California Proposition 65 for Electronics Suppliers and Manufacturers; A Must-Read Washington State Draft Report. The West Coast: Prop 65 and Safer Products
December 17, 2019 TTI MarketEYE: (Brazil) RoHS, a Regrettable Substitution and Conflict Minerals: End-of-Year International Roundup. Nothing slows down because of the prospect of mere holidays.
December 10, 2019 DCA Newsletter: December 2019. Another important stakeholder consultation on EU RoHS proposed substances for restriction and tools for the green chemist.
October 14, 2019 TTI MarketEYE: Ecodesign, RoHS and More: The EU Goes on a Tear. With short timelines and extensive requirements, the new ecodesign implementing measures challenge EEE manufacturers. I review the four RoHS proposals for restriction that have been opened up as well.
September 25, 2019 DCA Newsletter: September 2019. An awful lot going on in the European Union.
August 8, 2019 TTI MarketEYE: EcoDesign Meets Circularity; The Challenge of Wearables. The EcoDesign Directive finally moves beyond energy and the product use phase, while wearable technologies must comprehend the implications of new substances and new uses of existing substances.
June 17, 2019 TTI MarketEYE: Updates: China RoHS gets a Conformity Assessment System, and the CPSC Organohalogen Flame Retardant Ban gets a Report.
June 3, 2019 DCA Newsletter: June 2019. The China RoHS 2 Conformity Assessment System.
May 22, 2019 Chemical Watch: China issues conformity assessment rules for RoHS2. Two conformity assessment approaches have been defined, along with a new mark, for EEPs in the initial catalog.
May 17, 2019 DCA Newsletter: May 2019. More on organohalogen flame retardant restrictions and conferences to attend.
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.
February 6, 2019 TTI MarketEYE: Buzzword-Compliance, Electronics and the Circular Economy. Circular Economy is an important buzzword, but isn't fully baked for the electronics industry yet. Have I mixed enough metaphors yet?
December 13, 2018 DCA Newsletter: December 2018. EU RoHS and Sustainable Electronics.
December 5, 2018 TTI MarketEYE: RoHS 3 Begins, as does the RoHS Substance ID Methodology Definition. RoHS 3? Really? Has Mike lost it? Read it and see...
November 22, 2018 Chemical Watch: Call for electronics sector safety standard for environment, health. Unless the electronics industry takes control, government and NGOs will continue to define the path toward environmental and health safety.
November 15, 2018 Chemical Watch: HP Inc: present chemicals management as a business proposition. IBM and HP spoke about how to approach management to improve product-related chemical management.
October 12, 2018 TTI MarketEYE: EU REACH: A Trifecta of Open Stakeholder Consultations. We cover the proposed SVHC consultation as well as important Authorization and Restriction consultations.
October 3, 2018 DCA Newsletter: October 2018. The start of EU RoHS 3, a status update for China RoHS and a guest article from our partner Go Global Compliance!
August 17, 2018 TTI MarketEYE: Lead is now an SVHC - Implications for Manufacturers + Prop 65 & RoHS. Now nearly every manufacturer of EEE will have to disclose an SVHC. Read why in this month's article.
July 17, 2018 Capitol Weekly: Regulating lead-acid batteries. I opine on how DTSC should focus for the next set of Priority Products, and that one of them should not be lead-acid batteries.
July 10, 2018 DCA Newsletter: July 2018. We address occupational exposure under California Prop 65, cover updates to EU RoHS and REACH, and provide an update on San Francisco's Flame Retardant Regulation.
June 11, 2018 TTI MarketEYE: The Low/No-Halogen Conundrum. The electronics industry is confused and unable to come to a conclusion about how to define the halogen-free product requirement. Here's why and here's how I think we should move forward.
May 10, 2018 Chemical Watch: China continues to surprise. An article from the May Global Business Briefing.
April 27, 2018 DCA Newsletter: April 2018. We address additional substances in EU RoHS, the problem with product safety engineering, GCC RoHS, host a guest editorial on new requirements for portable Li-Ion battery packs in Japan, and report on a public hearing for the San Francisco Flame Retardant regulation.
April 2, 2018 TTI MarketEYE: The Chemical Regulatory Potpourri Continues for Electronics. SCCPs, California Proposition 65, Evaluation and SVHCs - oh my!
March 29, 2018 DCA Newsletter: March 2018. We address China RoHS's first "catalog" and provide updates on EU RoHS.
March 13, 2018 ChemicalWatch: Manufacturing CEOs: closing the product safety gap. What can happen when manufacturers fail to incorporate chemical human health and environmental impact into their safety-related engineering function. Here's a PDF of the article.
February 22, 2018 DCA Newsletter: February 2018. We address EU REACH and RoHS, and California Safer Consumer Products' Draft Priority Product Work Plan.
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.
January 18, 2018 DCA Newsletter: January 2018. We address UAE RoHS and Brazil RoHS; and we notify our readers about the upcoming AsiaHub Summit conference in San Francisco as well as the open Call for Abstracts for the 2018 Green Chemistry & Engineering Conference.
December 19, 2017 TTI MarketEYE: Greenpeace Greens it Up in Latest Re-launch Guide. We cover Greenpeace's return to focusing on the electronics industry, after a 5 year hiatus, with their Guide to Greener Electronics 2017; Regulation of Short-Chained Chlorinated Paraffins (SCCPs); testing as a lousy solution to RoHS compliance; and a pointer to my LinkedIn story of Samsung selling illegal product in the USA.
December 3, 2017 LinkedIn What is Wrong At Samsung (and Element)?. Why are Samsung and Element selling televisions in the United States that contain an illegal chemical flame retardant substance?
October 26, 2017 EPSNews: Other 'RoHS' Regulations Challenge Compliance. Some differences in regulations we call "RoHS", focusing on Singapore and Ukraine.
October 12, 2017 TTI MarketEYE: Regulatory Update Follow-UP. This column provides some updates on UAE RoHS, talks about the new US Consumer Product Safety Commission (CSPC) flame retardant user guideline that impacts manufacturers of plastic-enclosed electronics, and covers the EU RoHS Delegated Directive drafts issued (and open for comment through October 17) on the eight RoHS exemption renewal applications from Pack 9 that have been decided.
October 11, 2017 EPSNews: China RoHS 2 Update. Speaking of China RoHS, just what's going on with that? We are in the quiet period...before the storm, perhaps?
October 4, 2017 EPSNews: Answers to Your Key UAE RoHS Questions. Continuing discussions with ESMA show how in flux their approach is. This late in the game this is very troublesome. Who remembers China RoHS ca. December 2006/January 2007??? It's like that.
September 28, 2017 LinkedIn: Some Answers to United Arab Emirates RoHS (UAE Cabinet Decision No. 10/2017) Questions. I finally was able to track down someone at ESMA in the UAE to get some answers to the questions everyone seems to have about UAE RoHS.
August 30, 2017 Compliance & Risks Quarterly Newsletter: RoHS Compliance Terminology. Why this is "RoHS 2" and not "RoHS 3", and so on.
August 3, 2017 TTI MarketEYE: Regulatory Update. United Arab Emirates, China RoHS, Sweden and MCCP, and EU REACH. And that's not even everything. More in the next installment.
June 12, 2017 TTI MarketEYE: Environmental Activism, Government Regulation and YOU. How do you get ahead of all this stuff? Read this, then attend these webinars to find out.
May 30, 2017 ACS Green Chemistry: The Nexus Blog: Featured GC&E Organizers: Leo T. Kenny, Ph.D., Planet Singular & Michael Kirschner, Design Chain Associates, LLC. ACS is profiling session organizers for the Green Chemistry & Engineering Conference coming up in Reston, VA. Read to learn more about Leo and me!
April 11, 2017 TTI MarketEYE: More European Union Updates: Conflict Minerals and RoHS. There's a new Conflict Minerals regulation comin' to town...and some recent important RoHS scope decisions at the Commission.
April 11, 2017 EPS News: How the SEC's Shift on Conflict Minerals Will Impact Electronics. New US Administration: new approach to Conflict Minerals.
February 13, 2017 TTI MarketEYE: How Wrong Were My Predictions from December 2016?. Pretty wrong. Check out updates on EU RoHS and REACH, as well as US Conflict Minerals.
December 13, 2016 TTI MarketEYE: 2017 Look-Ahead. "It's difficult to make predictions, especially about the future", so of course I tried.
October 20, 2016 ChemicalWatch: Branching out across Asia. This is a report on a presentation I gave at Chemical Watch's Asia Summit in Hong Kong in September.
October 14, 2016 TTI MarketEYE: Summer Wrap-Up. It was a busy summer with additional SVHCs in the EU, TSCA Reform in the US, a significant and impactful change to the California Proposition 65 Warning requirement, and Singapore issuing a RoHS-like regulation.
August 26, 2016 TTI MarketEYE: Europe. In this month's article we once again focus on European Union RoHS and REACH.
June 7, 2016 TTI MarketEYE: Updates from China and the European Union. The big news in recent weeks was the release of the China RoHS FAQ on May 16. But that's not all.
April 27, 2016 Electronics Purchasing Strategies: Will EU RoHS Exemptions Expire in July?. Short answer: not the ones that have applications for renewal in place. But this article gives the details on why that's the case and what to expect.
April 5, 2016 TTI MarketEYE: EEE Environmental Compliance News Items. EU RoHS exemption status; Update on United Arab Emirates (UAE) RoHS; and Resistors, Capacitors and EU REACH SVHC Disclosure.
February 10, 2016 TTI MarketEYE: China RoHS 2 has Finally Arrived. Also, a short blurb on the Oko Institut's recommendations on EU RoHS extension applications for exemptions 9b, 13a and 13b.
February 4, 2016 ChemicalWatch: China RoHS2 greatly expands range of products under regime's scope
December 17, 2015 TTI MarketEYE: EU RoHS and REACH Updates. Answering the question: "What's the schedule for the RoHS Exemption Expirations??" Also, next steps on Articles under REACH.
October 13, 2015 TTI MarketEYE: The Meaning of the European Court of Justice Judgment on REACH SVHCs. Interpreting the change in definition and the impact on the electronics industry supply chain.
September 11, 2015 Bloomberg BNA Daily Environment Report: Chemicals of Concern in Product Parts Must Be Disclosed, EU Court of Justice Rules. (subscription required)
September 10, 2015 Electronic Purchasing Strategies: Yet Another (Unharmonized) RoHS?
September 1, 2015 Electronic Purchasing Strategies: Conflict Minerals Ruling Ignites Compliance Confusion
August 13, 2015 TTI MarketEYE: A REACH Update, Plus Another Unharmonized RoHS-like Regulation?