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TSCA Compliance Services

tsca

The U.S. Toxic Substances Control Act (TSCA) now impacts electronics producers

 

Recent rule changes to the U.S.  Toxic Substances Control Act (TSCA) has put the electronics industry on high alert.

On January 6, 2021, the US Environmental Protection Agency (EPA) passed new rules banning or restricting five Persistent, Bioaccumulative and Toxic (PBT) substances.

Unlike prior rules which largely applied only to the production, processing and importing of chemicals, these new rules include restrictions on the substances present in articles.

This means electronics producers and other manufacturers will have to ensure their products comply with TSCA. GreenSoft Technology offers a comprehensive TSCA data services and GreenData Manager software solution to help manufacturers with this process.

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PIP-uses-table
Figure 1: Common electronic equipment usage of Isopropylated Phosphate (3:1) (PIP 3:1).

Newly restricted PBT substances can be commonly found in electronic products

 

Of the five restricted PBT substances, PIP 3:1, which is currently widely used as a flame-retardant plasticizer for PVC, has been found to be commonly used in electronic equipment. 

Figure 1, left, shows some of the equipment and components in which PIP 3:1 is commonly present.

Another of the five PBT substances, DecaBDE, was commonly used in electronic equipment in the past, but due to its restriction under the EU RoHS Directive and EU REACH regulation, it has become less common in electronic equipment over time. 

The remaining three restricted substances are not likely to be present in electronic equipment.

Figure 2: The five persistent, bioaccumulative and toxic (PBT) substances regulated by the EPA on January 6, 2021.

Complete substance bans with civil and criminal penalties

 

Starting October 31, 2024, articles manufactured or sold in the U.S. may no longer contain any amount of PIP 3:1.

The clock is ticking for electronics producers to remove this substance from their supply chain.

Violations of the TSCA PBT substance restrictions can result in civil and criminal penalties of $37,500 per violation per day, and could even include up to 1 year of jail time for intentional violations.

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data-analysis

GreenSoft Technology provides supply chain analysis and data collection

As part of our TSCA solution, our data collection will contact your supply chain to collect data on the presence of PBT substances in your products.

You can choose to have our data team collect data on just PIP 3:1, or on PIP 3:1 and DecaBDE, or on all five of the restricted PBT substances.

We will contact your suppliers as many times as it takes to obtain complete and accurate data, and validate that data using a combination of manual and automatic checks.

Compliance and substances analysis reports can be generated by the GreenSoft team or internally by your own team using our award-winning GreenData Manager (GDM) software.

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Contact us today to learn more and get started, and we'll provide you with a FREE Risk Analysis!

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