SAVE THE DATE – RBA and RMI Annual Conference 2019

Total Parts Plus will be attending the 11th Annual Conference of the Responsible Business Alliance (RBA) and the Responsible Minerals Initiative (RMI) held October 21 and 22 at the Santa Clara Convention Center in San Jose, California.


As RBA’s biggest event of the year, this conference will focus on corporate social responsibility in global supply chains with top speakers from industry, civil society, and government. During the program, conference participants will gain valuable insight on the progress to date of RMI’s collective efforts as well as how companies can make better decisions when it comes to mineral sourcing and corporate social responsibility.


Please stop by our booth to see how TPP can support your company with Conflict Minerals and Environmental Compliance.


For more information visit the RBA & RMI Conference website:


To register for the 2019 RBA and RMI Annual Conference:


The Responsible Minerals Initiative is an Initiative of the Responsible Business Alliance (RBA) and is a multi-industry initiative of over 380 member companies. Its members contribute to the development and international uptake of a range of tools and resources focused on minerals supply chain due diligence, including independent third-party assessment programs for smelters, Minerals Reporting Templates, supply chain risk assessment tools, Country of Origin data, and guidance documents on responsible sourcing of tin, tantalum, tungsten and gold, and cobalt.


Final Report for assessment of two RoHS exemption requests (Pack 16) published

The final report on the study to assess two exemption requests in Annexes III and IV to the RoHS Directive (2011/65/EU) have been prepared by Oeko-Institut e.V and peer reviewed by Fraunhofer Institute IZM and published on the European Commission’s CIRCABC website as well as on Oeko’s own website.

The report was prepared under the Framework Contract: “Assistance to the Commission on technical, socio-economic and cost-benefit assessments related to the implementation and further development of EU waste legislation” and outlines the outcome of the assessment of the renewal of exemption IV.42 and the request for a new exemption for lead and hexavalent chromium compounds in electric and electronic initiators of explosives for civil (professional) use.

The key outcomes include a recommendation for extension of exemption IV.42 to 30 June 2026, from the original expiry date of 30 June 2019. Regarding the requested new exemption for lead and hexavalent chromium in electric and electronic initiators of explosives for civil (professional) use, the authors recommend a narrower scope of the exemption to be valid for five years. The exemption is recommended to apply not to all lead and hexavalent chromium compounds but to lead diazide, lead styphnate, lead dipicramate, orange lead (lead tetroxide), lead dioxide in electric and electronic initiators of explosives and barium chromate in long time pyrotechnic delay charges, both for civil (professional) use.

18 SVHCs proposed for authorization

The European Chemicals Agency (ECHA) has on October 1st, recommended 18 substances of very high concern (SVHCs) to be included in REACH Annex XIV, the Authorisation List. The substances are toxic for reproduction, endocrine disrupting, carcinogenic, very persistent and very bioaccumulative (vPvB) or respiratory sensitisers or a combination thereof. The substances have been included in the recommendation due to their intrinsic properties combined with high volume and widespread uses according to ECHA, potentially posing a threat to both human health and the environment.

ECHA considered comments from public consultation (September-December 2018) and the Member State Committee when making the decision on which substances from the Candidate List to include in the Authorisation List and their respective sunset dates in their recommendation to the European Commission.

The annex to ECHAs press release on the matter lists the 18 substances concerned and the full recommendation includes more details on the substances such as CAS number as well as recommended sunset dates and reasons for inclusion in the recommendation. The final decision on the inclusion now lies with the European Commission in collaboration with Member States and the European Parliament.

For more information on how TPP can assist you in evaluating your products for SVHCs and Authorized substances click here or contact us.

ECHA Releases Requirements for Upcoming SCIP Database

Article 9 of the Waste Framework Directive requires suppliers of articles which contain an SVHC above the REACH threshold of 0.1% w/w to provide, at a minimum, the name of the SVHC(s) present per Article 33 of the REACH Regulation.


On September 9th, 2019 the European Chemicals Agency (ECHA) released a guide regarding the requirements for the Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database. This database is designed to facilitate the collection and public availability of SVHC information for use by waste operators, consumers, NGOs, etc.


Companies which supply articles containing SVHC(s) above the threshold (EU producers and assemblers, EU importers, and EU distributors) will be required to provide sufficient information to allow safe usage of articles to ECHA, from January 5th, 2021. Some of the mandatory information to be submitted to the SCIP database will include:


  1. The identification of the article.
  2. The identification of the SVHC present.
  3. Information regarding the safe use of the article, if necessary.


The SCIP database will have three main objectives:


  1. Decrease the generation of waste containing SVHC(s) by supporting SVHC substitution.
  2. Make available information to improve waste treatment operations.
  3. Allow authorities to monitor SVHC(s), including their lifecycle and waste stages.


A conceptual model and additional information on the database is available at the ECHA website.


SCIP database will improve transparency on hazardous substances in articles


Additionally, ECHA has commissioned a team to collect feedback via an informal, stakeholder survey from both potential duty holders as well as potential users of the database. This survey will be used as a targeted consultation in order to further develop material categories and safe-use instructions, as well as assist in the standardization and dissemination of information via the SCIP database. You can access the Stakeholder Survey Questionnaire by following the link below.


Stakeholder Survey Questionnaire


Contact a TPP sales representative to find out more about how TPP can help you meet your compliancy goals for SVHC declaration, Article XVII information, and REACH regulatory requirements.


TPP – Total Parts Plus

RoHS, REACH, Conflict Minerals, Prop 65, and Obsolescence


Fort Walton Beach, FL

New RoHS Directive Amendment and Category 11 Product Type

On Monday, 22 July 2019, EU Directive 2015/863 added 4 new restricted substances as well as product Category 11 to the original list of 6 substances and original 10 categories laid out in Directive 2002/95/EC and amended by Annex II of Directive 2011/65/EU.

What does that really mean for manufacturers and importers?

The new directive is applicable to all new electrical and electronic products placed on the European Union market – regardless of being imported or manufactured in the EU, and it requires that products bearing the ‘CE’ mark are presumed to comply with the directive (in the absence of evidence to the contrary).

Any EEE products not covered by the original Categories 1-10 come into scope as Category 11 products (i.e., 2-wheeled electric vehicles, electronic cigarettes, cannabis vaporizers, vape pens, electrical cables less than 250V, etc.) and have slight differences when compared to the other categories:

  • All products, regardless of their import date, must comply after 22 July 2019 (stock from before 22 July 2019 may no longer be sold in the EU unless already compliant).
  • No allowances are made for non-compliant spare parts after 22 July 2019.

What are the 10 restricted substances?

The original 6 substances consisted of 4 heavy metals and 2 flame retardants:

  • Lead (Pb) – a heavy metal used in printed circuit boards, paints, and pigments.
  • Mercury (Hg) – a heavy metal used in lighting and automotive switches.
  • Cadmium (Cd) – a heavy metal used in plastic pigmentation and photocells.
  • Hexavalent Chromium (CR VI) – a heavy metal used to prevent corrosion of metal finishes.
  • Polybrominated biphenyls (PBBs) – flame retardant used in appliances, electronics, and textiles.
  • Polybrominated diphenyl ethers (PBDEs) – flame retardant used in electronics and furniture.

All the new additions are phthalates – a plasticizing compound used to add flexibility and durability:

  • Bis(2-Ethylhexyl) phthalate (DEHP) – used in cable insulation and as a softener for PVC.
  • Butyl benzyl phthalate (BBP) – used in flexible adhesives, coatings, inks, and vinyl products.
  • Dibutyl phthalate (DBP) – used in flexible varnishes, nail polish, and variety of rubbers and paints.
  • Diisobutyl phthalate (DIBP) – used in printing inks, adhesives, and cosmetic applications.



What are the effective dates?

Effective Date


22 July 2019

1: Large Household Appliances (LHA)

22 July 2019

2: Small Household Appliances (SHA)

22 July 2019

3: IT and Telecoms Equipment

22 July 2019

4: Consumer Equipment

22 July 2019

5: Lighting Equipment

22 July 2019

6: Electrical and Electronic Tools

22 July 2019

7: Toys, Leisure and Sports Equipment

22 July 2021

8: Medical Devices

22 July 2021

9: Monitoring and Control Equipment (including Industrial)

22 July 2019

10: Automatic Dispensers

22 July 2019

11: Other EEE not covered above (catch-all)


Are there exemptions or transition periods?

Category 8 and 9 products have 2 years remaining and fall into scope on 22 July 2021. There are additional exemptions for specific applications or industries; the current status is reported on the European Commission website.

How can Total Parts Plus help?

TPP provides customers with dedicated resources for the time-consuming tasks of surveying suppliers, out of scope assessments, conducting analytical research, validating data, and monitoring exemptions.

TPP customers also have access to our extensive database of pre-approved compliant parts via our web-based Compliance Management Module (CMM) which empowers companies to easily manage and monitor their environmental compliance data.

How do you get started?

Contact Total Parts Plus to learn more or schedule a demo.
Call:       +1.850.244.7293

Four New Substances Added to the REACH Candidate List of SVHCs

The European Chemicals Agency (ECHA) has added an additional four substances to the Candidate List of Substances of Very High Concern (SVHC), bringing the total number of SVHCs to 201 as of July 16th, 2019.  The four new substances are added based on their reprotoxic and endocrine disrupting characteristics amongst other potentially hazardous effects to human health and the environment

  • 2-methoxyethyl acetate (CAS # 110-49-6)
  • Tris(4-nonylphenyl, branched and linear) phosphite (TNPP) with ≥ 0.1% w/w of 4-nonylphenol, branched and linear (4-NP)
  • 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts and its acyl halides (covering any of their individual isomers and combinations thereof)
  • 4-tert-butylphenol (CAS # 98-54-4)

The SVHC Candidate List is updated biannually with new substances being reviewed for addition on a continual basis. Suppliers of articles which contain an SVHC substance above a concentration of 0.1% w/w have a legal obligation to provide customers with enough information to allow safe usage of the article – at minimum, the name of the SVHC(s) present above the REACH threshold must be communicated.

Find out how TPP can help you keep track of the REACH requirements, including SVHC Candidate List updates by contacting us.

Read ECHA’s official press release here for more information about the SVHC Candidate List.

China RoHS2

The Chinese agencies SAMR (State Administration for Market Regulation) and MIIT (Ministry of Industry and Information Technology) have released the long-awaited Voluntary Certification

Implementation Rules as of May 22, 2019. These rules, which are based on product type, were created to ensure the validity and consistency of the China RoHS2 self-certification process regarding environmental compliance and will go into effect November 1, 2019.

Companies may choose either a self-certification route or obtain “technical documentation” from a third party service. This information is to be submitted via an online public service platform within 30 days of the product being placed on the market.

In addition to the self-certification process, new China Green Product logos have been released which will be used to identify which certification process was utilized to declare compliancy. These new logos will not replace the current China RoHS 2 logos; rather, they will be used in addition to the current China RoHS 2 markings.

You can review the official statement released by SAMR at Voluntary Certification Implementation Rules.

Find out how TPP can help you meet your compliancy goals regarding China RoHS 2 and more at TPP – Total Parts Plus.

TPP Application Update

TPP has added an XML API feature for the reporting of RoHS II (2011/65/EU) compliance including the amendment added by Directive (EU) 2015/863. The change was implemented in the TPP XML API test account May 23rd, 2019 to allows customers to implement the feature before the amendment takes effect July 22nd, 2019.

The attribute RoHS10 was added to the parts elements for material content response and reflects the RoHS II compliance status to current 6 RoHS II substances and the 4 phthalates added by Directive (EU) 2015/863. The 10 indicates the current number of substances restricted. 

If you have questions or comments, please contact:

Cathy Iler                                                                             Nikki Johnson                   

850.244.7293 x 1005                                                        850.244.7293 x 1036                             

TPP verified as an IPC 1752A WAM 1, 2 & 3 solution provider 2018

The IPC 1752A standard is used extensively for communicating compliance information throughout the supply chain for electrical and electronic products. To meet changing industry requirements and legislation, the standard is regularly updated and maintained by industry experts.

IPC introduced an annual review process for solution providers in 2014 in which a review committee of industry experts verify that companies IPC 1752A XML files comply with current requirements.

All solution providers are invited to submit example XML files reporting IPC 1752A Class A, C and/or D in Request/Reply and/or Distribute mode. The review committee inspects, comments and verifies that the files submitted;

  • Comply with IPC 1752A XML file format
  • Use IPC 1752A lists of regulated substances and exemption correctly

The standard includes an XML Schema outlining the structure and rules to be followed in the IPC 1752A declaration files. It specifies types of data elements to be included as well as the order in which they must be reported. To accurately communicate materials information using the standard, correct use of defined industry naming conventions is critical. It is also essential to accurately use the dynamic lists of regulated substances and exemptions for compliance with the standards.

Total Parts Plus is pleased to announce that we are a verified solution provider of IPC 1752A Class A, C and D declarations in both Request/Reply and Distribute mode in the 2018 review process and we look forward to participating in the upcoming 2019 process starting in April.

TPP provides a free IPC 1752 generator located here and an IPC 1752 generator available for purchase which includes features not provided in the free tool.  For more information on TPP’s IPC 1752 generator tools or IPC 1752 collection and generation services, contact our sales department here or email  To find out more about the solution provider review process visit IPC Materials Declaration Data Exchange Standards.

RoHS project, Pack 17 – Assessment of three exemption requests

A project assessing three exemption requests with regards to the RoHS directive’s Annex IV has been initiated by Oeko-Institut e.V. – Institute for Applied Ecology. The Annexes of the directive are to be adapted based on scientific and technical progress as outlined in Article 5 and the Environment Directorate-General of the European Commission has requested assistance in providing scientific and technical support for the evaluation of exemption requests with regards to RoHS2 from a consortium led by the Oeko-Institut.

Two of the three requests are for new exemptions of Bis-(ethylhexyl) phthalate (DEHP) for use in certain medical equipment applications, called on by COCIR and GE Healthcare. The third request is for the renewal/amendment of the existing exemption 31a (Annex IV) and also addresses DEHP as well as Di-isobutyl phthalate (DIBP) and Benzyl butyl phthalate (BBP) and their use in spare parts for repair or refurbishment of medical devices, called for by COCIR.

The evaluation is to be performed in co-operation with the European Commission and stakeholders from the electrical and electronic industry, NGO’s and independent experts through a project specific website as well as mailing lists for which stakeholders can register as well as workshop or meetings as needed. A stakeholder consultation is expected to be launched in March and the project will end in August.

For more information visit Oeko-Institut’s RoHS Evaluations website.