On January 12, 2017, ECHA added four new substances of very high concern (SVHC) to the REACH candidate list. The SVHC list is now at 173 substances. The new SVHC and common usage is found in the table below.
||Reason for Inclusion
||Toxic for reproduction
||Polymers and in manufacture of plastic products
|4-Heptylphenol, branched and linear
|Equivalent level of concern having probable serious effects to environment
||Not registered in EU – uses in R&D
Derivatives may include greases and lubricants
|Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts
· Ammonium nonadecafluorodecanoate
· Decanoic acid, nonadecafluoro-, sodium salt
||Toxic for reproduction
PBT (persistent, bioaccumulative, & toxic)
|Textiles, packaging, firefighting foam
||Equivalent level of concern having probable serious effects to environment
||Resins and lacquers, germicide in cleaning solutions, adhesives, paints, some rubber curing uses for a derivative
On November 22, The EU agreed on a Conflict Mineral Regulation framework. The regulation seeks to inhibit import and sale of minerals and ores that are used to fund armed conflict and infringe upon basic human rights.
Importers of Tin, Tantalum, Tungsten, and Gold (3TG) will be required to review and conduct due diligence upon their supply chain beginning in 2021. Also beholden to the regulation are smelters and refiners of 3TG.
Exempted from the regulation is the import of finished products that may contain 3TG.
Major differences between the EU and US version of the Conflict Minerals regulations include the exemption of imported finished goods by the EU version and an increased scope of where the minerals may have been obtained. EU Conflict Minerals requires all 3TG whereas US Conflict Minerals Act addresses 3TG from the Democratic Republic of Congo and its nine neighboring countries.
As the phase-in period begins for EU Conflict Minerals, please check back with this blog for any and all pertinent updates and changes.
On November 30, the Conflict Free Sourcing Initiative, CFSI, released the newest version (v. 4.20) of the Conflict Minerals Reporting Template, CMRT. This is the 15th new release, the sixth release at version 4, and the first update since CMRT v.4.10, released on April 29, 2016.
Updates to CMRT v.4.20 include corrections to bugs and errors, updated smelter lists, IPC 1755 compatible enhancements to the instructions page and an update to ISO short names for countries, and finally translational improvements for all updated instructions and definitions.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.conflictfreesourcing.org. The next update to the CMRT is anticipated for April 2017.
The new CMRT provides a unique opportunity for corporations and individuals collecting CMRT data as part of their due diligence surrounding a reasonable country of origin inquiry (RCOI) for SEC Reporting. Q Point adopts the stance that data provided from the latest version of the CMRT indicates updated information. That is to say, a CMRT v. 4.01(b) contains older, and perhaps out of date, information when compared to a current CMRT (v. 4.20).
Corporations and individuals may use the new CMRT as a mechanism for gathering updated conflict minerals data and improving overall data collection from their suppliers. Alerting suppliers to the new CMRT may lead to a discussion that sets expectations for routine updates and the use of the latest CMRT version. Exclusive use of the new CMRT will produce Form SD filings with the SEC that will show data received in the current year after November 30, 2016. This will demonstrate the necessary due diligence that is a hallmark of reasonable country of origin inquiry (RCOI). Also, any effort in communicating a requirement and expectations to a supplier can be similarly used in the Form SD.