Is your company addressing Toxic Substances?
Is your company using Forced Labor?
Be part of the solution
Protect the environment and at-risk workers
Make sure your company is addressing
Chemical Compliance and Responsible Sourcing
Brenda B. Baney
Product Stewardhip Expert
Addressing the above in a cost effective and efficient manner allows your company to utilize the resources within to create and enhance your 'environmental and social stories' in order to determine the right priorities. It is often the better long term strategy to go beyond emissions and metrics and look for unconventional partnerships with your suppliers and customers.
Are your customers asking what REACH substances are found in your products? Or is your company being asked to send conflict minerals and other responsible sourcing forms showing your due diligence of your supply chain. Do you know that other regions, like the EU, have enacted legislation adding minerals and new conflict areas to be surveyed? BCubed works with multiple industry leaders to assure common data fields and similarities across formats so that it is possible to gather data from lower supplier tiers (i.e. raw material manufacturers). Your company may benefit from the knowledge of an expert who has over 30 years experience with deep supply chains and environmental topics for the 'durable goods' industries. Compliance, of course, but also anticipating next moves:
California Prop 65
Brenda is one of the true experts on supply chain compliance, with extensive experience designing and administering programs in both a large corporate environment and as a consultant. When it comes to separating the wheat from the chaff, she is wheat!
Michael R. Littenberg
ROPES & GRAY LLP
Your Corporate Responsibility concerns
Today's Top 3
1.2020 EU Circular Economy Action Plan drives SCiP database
On 11 March 2020, the EU adopted a new Circular Economy Action Plan which includes measures along the entire life cycle of products. This plan outlines the EU's intention to restrict single-use products, tackle premature obsolescence, ban the destruction of unsold durable goods, provide consumers with information on durability, reparability and ensure that they benefit from true “right to repair”. The SCiP database means your must report ALL SVHCs found in any part or sub-part in your product. Reporting starts January 1, 2021.
2.EU Conflict Minerals Legislation In Place starting Jan 2021!
On January 24, 2017, the European Parliament’s International Trade Committee approved the text of the conflict minerals regulation submitted following the three-way trilogue negotiations that were completed on November 22, 2016. The legislation comes into force January 1, 2021 and although aimed at raw material importers, article producers were strongly encouraged to provide reports about their responsible sourcing due diligence and material sourcing practices. The EU definition of 'conflict areas' includes Argentina, Indonesia and others not cited within the US Dodd-Frank Act or included within many business current diligence practices.
3.Effective strategies for assessing up-coming substance/material bans
Industry substance lists and other items like above will drive requirements down the supply chain for assessing, substituting, and reporting of hazardous substances found in products and components.
* Question and Answer format
Did You Know?
The U.S. House of Representatives passed H.R. 2576 to reform the Toxics Substances Control Act. June 22, 2016 Reforming TSCA which has essentially remained unchanged since its passage in 1976.
How will the new Biden administration set priorities for EPA and other Chemical Reform that has been on a backburner for years?
Over 50% of firms expect the cost of expert compliance staff to rise in 2018. Thomas Reueters Special Report
Amazon has a restricted substance list that applies to all food contact products. Will TOYS and other "durable goods" be next?
The EU REACH Candidate List of Substances of Very High Concern is now Over 444 distinct chemicals!
and continues to grow!
Does your supply chain management team understand the risks of mineral and raw material availability on your production?
What about improving the connections between Engineering, Purchasing, and Sales to assure all customer requirements are being addressed and communicated properly?
Determine your cost of compliance and reduce it with a more efficient process
Make sure your company is addressing all relevant legislation
Understand your current customers' specifications fully in order to prepare to handle new requirements and new customers
Feel free to give me a call and we can set up a time to discuss your project.
I'm looking forward to working with your company on it's product stewardship challenges.