Jabil's Global Category Intelligence Archive

Q2 2022

MATERIALS COMPLIANCE

AREAS OF ACTIVE IMPLEMENTATION

We continue to accelerate our SCIP submission activities and are actively working to integrate these activities into our standard processes and systems across all operations and divisions. In addition, we now offer SCIP compliance services to several customers and suppliers, helping them to achieve their own SCIP compliance goals.

Conflict Minerals Reports for CY2021 are required to be filed with the SEC in May 2022, and with all companies having the same reporting schedule, we are urgently working on last-minute requests from customers and actively helping suppliers to provide their CMRT reports before the upcoming deadline. We encourage all levels of the supply chain to focus their efforts on finishing up as much of their conflict minerals compliance reporting activities as possible before the end of April so that their customers have time to aggregate and report the data to the SEC by May 2022. We continue to see more customers making sourcing decisions and changes based on this important public disclosure.

The new TSCA regulations (PBTs, PIP, etc.) continue to be extremely disruptive and complex. The EPA has extended nearly all enforcement deadlines, including for PIP 3:1 substances, to October 2024. This is a much needed and welcome change that allows companies throughout the supply chain to plan a more diligent and thorough approach and transition away from these substances in a more orderly fashion. We continue to advise suppliers and customers to take this opportunity to evaluate the use of these substances more thoroughly in your products, and work with downstream suppliers too.

We have started to see some increased activity and engagement related to the potential for several new countries to be admitted to the EU, for example Ukraine and Turkey. Several customers have started to evaluate the products they are selling into these countries to see what new products/materials might be subject to existing EU regulations like RoHS, REACH, and SCIP should these countries become EU members. We have only seen very early stages of this analysis/activity, but there seems to be a widely held belief that the Russian invasion of Ukraine will result in a meaningful number of new EU member countries and that those changes may occur more quickly and with shorter runways than we’ve seen historically.

Customer inquiries and industry scrutiny of Cobalt continues to increase, with all levels of the supply chain insisting on greater transparency around Cobalt sourcing, and we expect that trend to accelerate after the May 2022 submission deadline for Conflict Minerals Reports to the SEC. Suppliers should expect to see an increasing number of inquiries and requests for CRT declarations and further scrutiny of the smelters within the supply chain. If you have a Conflict Minerals Compliance Program with existing processes around CMRT declarations, we encourage you to extend that program and process to include Cobalt and the associated CRT declarations.

The United States recently passed a new law, the Uyghur Forced Labor Prevention Act, that bans imports from China’s Xinjiang region unless the importer can prove they were not produced with forced labor. This ban applies to all categories of products and includes any product that was even partially made or assembled in the XinJiang region. We have already experienced a significant increase in customer inquiries on this topic, as product companies and importers work to analyze the impact and begin to gather data to defend against any enforcement actions.

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MATERIALS COMPLIANCE

AREAS OF ACTIVE IMPLEMENTATION

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