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moleculesOn June 22nd 2016 President Obama signed into law the TSCA reform bill. On June 7th, 2016 the US Congress passed the US TSCA reform bill and previously, on December 18, 2015 Senate passed "The Frank R. Lautenberg Chemical Safety for the 21stCentury Act", which updates the 1976 Toxic Substances Control Act and gives the EPA broader powers regarding studing and regulate harmful chemicals, as well as restricting states’ abilities to create individual rules regarding chemicals.

Last year, the US House of Representatives  approved TSCA reform as the “TSCA Modernization Act of 2015”. In an overwhelming vote of 398-1 on June 23rd, 2015, the House approved this bill that will amend the Toxics Substances Control Act that has been in place since 1976 and include substantial changes.

The house bill, HR 2576, gives the EPA more power regarding regulatory action on chemicals, mandates a minimum number of risk evaluations per year, requires a list of persistent, bioaccumulative and toxic chemicals within nine months of the bill’s enactment, and after two years, identify chemicals of concern. The bill also allows for confidential business information (CBI) sharing and expiration of CBI claims.

Stay tuned as TSCA develops further.

toxic

The cost is substantial for any product environmental compliance program... A 2008 study regarding the cost of RoHS compliance estimated that the average cost per company was $264,000 to achieve initial RoHS compliance and another $482,000 for annual maintenance. For REACH it is considerably higher. One study estimates the overall cost ranging from €2.8 billion to €12.8 billion over the next 11 years, with a one-time initial cost increase of 6-20% per product. When not complying is not an option, part of your compliance budget should be invested in Product Environmental Compliance (PEC) Software. Here are the top six reasons to make that investment. 

gavel1. Governmental Requirements: Compliance with environmental regulations and directives is the law. Some of this legislation contains inherent language that, when faced with compliance, says “so prove it!” REACH’s Article 5 “No data, No market” principle states that substances shall not be manufactured or sold in the European Union unless they have been registered in accordance the relevant provisions. If your company is targeted for audit, inspection, or review by any enforcement body and you have a PEC software solution in place, you will be able to respond quickly and effectively with an audit-worth trail and comprehensive due diligence activities within your supply chain, and reduce the business impact of regulatory pressures including penalties and enforcement. 

2. Client Requests: GCG receives a constant stream of inquiries from customers trying to respond to their own client requests for compliance verifications. The type of response and response turn-around time can mean retaining or losing your customers. With the right PEC software or service provider for software reports, you will be able to respond quickly to client requests. Virtually all of the largest electronics companies have their own list of restricted substances. These lists often contain many more substances and lower thresholds than are governmentally restricted. Increasingly, they are incorporated into Green Procurement programs. The right PEC software will enable you to respond to whatever substance of concern lists and reports your clients may request from you.

3. Supply Chain Transparency: By increasing your awareness of what’s in your supply chain and reducing the presence of restricted chemicals in your products, you will be able to establish not only an environmentally compliant supply chain but also a socially acceptable supply chain. Establishing and maintaining this supply chain transparency is the new “socially responsible” supply chain paradigm. Supply chain transparency is supported by the Dodd-Frank Wall Street Reform and Consumer Protection Act of July, 2010 (the “Conflict Minerals Law”) and California’s Supply Chain Transparency Act, passed in September 2010. 

4. Internal Efficiency: Achieving and maintaining product environmental compliance is a full-time job. Managing BoMs and responding to requests in your supply chain is just part of this job that is tedious and frustrating. Using a tool as powerful as MDW-ES PEC software will greatly assist your internal staff in establishing and maintaining compliance, managing BoMs, managing your internal MOC (materials of concern) list, and will save exponential amounts time communicating within your supply chain.

green piggy bank5. Cost Reduction: Myriad cost reductions and savings can be realized by using PEC software including: reducing the cost of outside professionals for chemical testing, third-party lab work and legal expertise; reducing your toxicity-related financial exposure; reducing your overall time to compliance, cost, and staff commitments. Most importantly is avoiding the cost of business interruptions and penalties of non-compliance. RoHS2 verbiage includes mandatory recall of all non-compliant products and goes even further by stipulating that distributors are required to notify authorities of non-compliant products.

6. Increased Competitive Advantage: To gain competitive advantage, your approach to compliance should meet or exceed industry and customer expectations by integrating social, ethical, and environmental concerns together with the usual measures of revenue, profit, and legal obligation. By effectively establishing and maintaining compliance, you will be re-assured that your products will stay on the shelves and in your customer’s hands when they are proven to comply with environmental regulations. MDW-ES is the lowest cost, most robust PEC software on the market today with an established track record of assisting customers with PEC compliance for over 8 years . MDW-ES can be easily installed in days vs. months, and with minimal training your staff can be using MDW-ES to comply with governmental requirements, respond to customer requests, and protect its customers and market share. With all these benefits, how can you not afford it? 

But…

“What if I just can’t afford it?”

We understand that budgets get cut and sometimes just start out at zero, and that people get laid off or just quit. If PEC software is not in your company’s budget, or demands for reports are too infrequent to justify a compliance software commitment from your company at this time, GCG’s BoM Management is the perfect solution. GCG’s BoM Management team uses our own MDW-ES PEC software to perform the services for you, eliminating (or postponing) the need to license or buy software, while satisfying your commitments. Once your budget and/or demand for reports justifies PEC software for your organization, GCG’s BoM specialists will transfer any data and reports already generated through our BoM Management services to your database in MDW-ES or GCG’s hosted version of MDW-ES, Green-ESsm SaaS (Software as a Service), making it a seamless transition and putting you in control of past, present, and future BoM Management. GCG's BoM Management services provide a cost effective alternative to internal BoM Management, as outsourcing BoM Management to GCG is less expensive than the opportunity cost of your compliance or quality assurance manager doing the “busy work” or hiring a full-time staffer to manage data and generate reports. If you do have the resources to engage a full-time on-staff professional to do this type of work, our MDW-ES or Green-ES solution is the appropriate tool to assist them in their efforts. 

More information: For more information on GCG’s BoM Management Services, please email us at: This email address is being protected from spambots. You need JavaScript enabled to view it.  or call 1-888-GBChain (1-888-422-4246) x 81 or click here for the BoM Management Services section.

RY2025 Underway!

Reporting Year 2025 (RY2025) is underway marking year 13 of reporting supply chain due diligence of the source and chain of custody of Conflict Minerals under Dodd-Frank.  While past events threatened the domestic Conflict Minerals law, there has been no change in reporting under the law.

Conflict Minerals reporting is an annual obligation for companies in scope of the law, and once the requisite forms are filed with the SEC at the end of May each year, efforts begin for the next reporting year if the project is managed appropriately. Although political decisions could impact Conflict Minerals reporting, the RY2025 cycle started as early as June 2025 for companies that continue their due diligence activities. Companies that have been through the disclosure process know that the due diligence process should not be interrupted if filings are to be done appropriately and by the legal deadline. 

For more on US Conflict Minerals reporting, continue reading below.

Performing supplier Reasonable Country of Origin Inquiries (RCOIs) and smelter RCOIs, and performing subsequent due diligence on smelters regarding their Conflict Free status, is a daunting task. Copious amounts of errors in supplier Conflict Minerals Reporting Templates (CMRTs) makes cleansing these CMRTs and identifying valid smelters a laborious task. The required research regarding smelters in the DRC and surrounding countries, and performing due diligence on these smelters can also be challenging. 

If your company, whether an issuer or an upstream supplier, is still struggling with managing supply chain transparency issues, like Dodd-Frank, let us know how GCG can help. Our successful implementation and management of Conflict Minerals since 2013, for both issuers and suppliers alike, can help you manage your suppliers, conduct supplier and smelter RCOIs, perform required due diligence steps, and prepare form SD and the CMR for the SEC. 

Email us at This email address is being protected from spambots. You need JavaScript enabled to view it. or call us at 888.422.4246. General background information about Dodd-Frank is below.  

What it is: The Dodd-Frank Wall Street Reform and Consumer Protection Act, signed in to law on July 21, 2010, contains Section 1502 which refers to the use of Conflict Minerals in the Democratic Republic of the Congo (DRC). This section is referred to as the Conflict Minerals Law. 

Why it is important: Section 1502 is important to manufacturers and suppliers of electronics because it applies to minerals that are commonly used in electronics.  

What you need to know: The Conflict Minerals Law is not a ban on using certain minerals, however it contains reporting and disclosure requirements for materials contained in products, as well as due diligence, audit and certification requirements.   

The SEC Fact Sheet for disclosing the use of conflict minerals may be found here: https://www.sec.gov/newsroom/press-releases/2012-2012-163-related-materials

The Final Rule may be found here: https://www.sec.gov/files/rules/final/2012/34-67716.pdf 

The SEC Compliance Guide may be found here: https://www.sec.gov/info/smallbus/secg/conflict-minerals-disclosure-small-entity-compliance-guide.htm 

REACH updates occur regularly...  

Here you will find the latest running totals for the REACH SVHC candidate list, authorisation list, and SIN list, plus some of the latest news alerts from the European Chemicals Agency, ECHA.

REACH Running Totals: 

SVHC Candidate List (CL) Entries: 251beakers

Substances on Annex XIV for Authorisation: 59

Substitute it Now (SIN) List: Over 2000 listings

SIN List Database: click here

For the ECHA list of Restricted Substances click, here. For the Registry of SVHC Intentions on ECHA's website click here. This registry allows interested parties to be aware of substances that might be identified as SVHCs before they are included on the candidate list.

The SVHC candidate list is updated regularly by ECHA. The new total is 251 entries as of November 5, 2025. 

Breaking News: 

Latest news alerts from ECHA: