EPA published a new Proposed Rule to further extend the risk management compliance date for PIP (3:1)-containing articles to October 31, 2024. The prohibition on processing and distribution of PIP (3:1) and PIP (3:1)-containing articles will be effective on that date unless we can make a strong case otherwise.

Because the proposed rule highlights electronics, including wiring harnesses, cables, wiring sleeves, casings, and cords, we want to make sure that the electronics manufacturing industry is aware of the likely relevance of the 2024 prohibition.

We encourage you to review our Request for Information for a detailed list of data and documentation needed to prepare a response to EPA. IPC will continue to collaborate with CTA and ITI to gather the electronics industry’s feedback. We do not plan to oppose the newly proposed extension, but we will request to EPA that it be based on a “manufactured by” compliance date. Also, we will reiterate to EPA our earlier requests to establish an adequate de minimis concentration and to provide specific exemptions including for spare and replacement parts.

We anticipate that the electronics industry will have new or additional data and information based on its efforts to identify PIP (3:1) in its supply chain since the January 2021 final risk management rulemaking.  Also, we anticipate industry members will have more economic impact information to support a request for an exemption for spare and replacement parts. We welcome your feedback in response to the Request for Information by December 1, 2021.

Please see our earlier blog posts regarding PIP (3:1). I welcome your questions about this proposed rule and the recent history of PIP (3:1)-related policy actions.  KellyScanlon@ipc.org

IPC Issues Industry Alert on Prohibition of PIP (3:1), March 1, 2021

USEPA Announces Request for Public Input on PIP (3:1) Final Risk Management Rule, March 12, 2021

Electronics Industry Submits Comments on EPA’s PIP (3:1) Request for Public Input, May 17, 2021

PIP (3:1) Compliance Deadline Extended…At Least Two More Rules Expected, September 8, 2021