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Jabil's Global Category Intelligence Archive
Q1 2022
Jabil's Global Category Intelligence Archive
Q1 2022
MATERIALS COMPLIANCE
AREAS OF ACTIVE IMPLEMENTATION
SCIP activities and program frameworks have finally started to coalesce across the supply chain. Many of the most mature organizations have now submitted tens of thousands of SCIP notifications into the new centralized system via well-known industry platforms such as SAP EHSM, BOMCheck, and IMDS. We anticipate these submissions will continue to accelerate dramatically throughout first half of 2022.
We also anticipate regulatory enforcement action will increase starting in Q1 of 2022, with regulators already starting to reach out to some of the largest companies with no submissions into the SCIP system. If you have not yet made any submissions into the SCIP system, we encourage you to do so as quickly as possible in Q1 2022 to avoid raising concerns with regulators. Jabil has now made nearly 500 notifications into the SCIP system, and estimate we are approaching 20% completion towards full compliance with this regulation.
Conflict Minerals Compliance is now in full swing, and all layers of the supply chain are working feverishly to complete the declaration gathering and analyzing activities to support their SEC filing that is due in May. If you have not yet completed a CMRT for your customers, you should prioritize that effort early in Q1 2022. This is a critical compliance requirement for all US publicly traded companies that are required to file a report with the SEC.
The new TSCA regulations (PBTs, PIP, etc.) continue to be extremely disruptive and complex. The EPA recently moved the enforcement deadline temporarily to March of 2022 but has now completed a more substantial review that resulted in a more detailed enforcement extension. Enforcement of the 3:1 PIP rules has been extended to October 2024. This has always been the more challenging and complex of the new TSCA regulations, so this new extension provides a much more realistic timeline for compliance.
In addition, new rulemaking and enforcement deadlines for the 5 PBT chemicals has been extended to the spring of 2023. These are all welcome changes that provide a much more realistic compliance timeline. This is a monumental undertaking for any company with operations inside the US or who ship products for sale within the US. It is critical that you leverage this additional time to identify the presence of any of these substances within your products/materials. We believe further extensions are extremely unlikely, as the new deadlines do provide sufficient time for compliance activities. test link
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