Category Archives: nl2021q4

US – EPA Proposes to Delay PIP (3:1) Restriction

The U.S. EPA has proposed a rule that will extend the compliance deadline restricting PIP (3:1) in articles until October 31, 2024 and opens a 60 day public consultation period.

The summary in the proposed rule provides a convenient synopsis:

The Environmental Protection Agency (EPA) is proposing to amend the regulations applicable to phenol, isopropylated phosphate (3:1) (PIP (3:1)) promulgated under the Toxic Substances Control Act (TSCA). Specifically, EPA is proposing to extend the compliance date applicable to the processing and distribution in commerce of certain PIP (3:1)-containing articles, and the PIP (3:1) used to make those articles until October 31, 2024, along with the associated recordkeeping requirements for manufacturers, processors, and distributors of PIP (3:1)-containing articles. EPA is also announcing its intention to commence a new rulemaking effort on PIP (3:1) and four other persistent, bioaccumulative, and toxic (PBT) chemicals that have been regulated under TSCA section 6(h). EPA is anticipating issuing a proposal to this end in 2023.

The proposed rule (which is expected to be approved) will provide EEE manufacturers who import manufactured goods (articles) into the U.S. a reprieve until 2024.

In the proposed rule, the EPA states that some companies and industry groups have indicated a need for even more time (beyond 2024) to comply. The EPA has invited those manufacturers to provided detailed technical information on the applications where PIP (3:1) is needed and the specific technical efforts they have undertaken to substitute.  The EPA has drawn an analogy to the level of technical detail that the EEE industry provides to the European commission to justify specific RoHS exemptions.

The docket id of the proposed rule is EPA-HQ-OPPT-2021-0598-0001 and is available from the website[1].

[1] EPA proposed rule on PIP (3:1),

EU – Four Substances on REACH SVHC Consultation List

On September 5, 2021, ECHA posted a stakeholder consultation on four substances that are under consideration as SVHCs on the REACH Candidate List. The four potential SVHCs are listed in Table 1. These substances are likely to be added to the REACH Candidate List during the next update in December/January.  The IEC 62474 Validation Team is currently reviewing the substances for potential use in EEE.

Table 1: REACH SVHC Consultation List

NameEC NumberCAS Number
(±)-1,7,7-trimethyl-3-[(4-methylphenyl)methylene]bicyclo[2.2.1]heptan-2-one covering any of the individual isomers and/or combinations thereof (4-MBC)
6,6'-di-tert-butyl-2,2'-methylenedi-p-cresol (DBMC)204-327-1119-47-1
S-(tricyclo['2,6]deca-3-en-8(or 9)-yl) O-(isopropyl or isobutyl or 2-ethylhexyl) O-(isopropyl or isobutyl or 2-ethylhexyl) phosphorodithioate401-850-9255881-94-8