As awareness increases about the human and environmental impacts of substances in products, 2022 will likely be a year of increased product compliance regulations and stricter enforcement. That, paired with supply chains around the world continuing the deal with the fallout from the COVID-19 pandemic, means that companies should continuously look ahead and keep a close eye on compliance changes that could impact their products.
In the coming year, your company may be impacted by some of these 2022 product compliance trends. Be ready with a robust and responsive compliance team prepared to meet upcoming challenges.
Continued Supply Chain Issues
After a 2021 laden with supply chain issues, almost everyone around the world hoped we would be able to resolve them by the end of the year. Unfortunately, with continued materials shortages, port congestion and other issues, it looks like supply chain issues will continue for some time into 2022.
Advanced preparation is key to mitigating your company’s risk. Communicate with your supply chain early and often, diversify your sourcing where you can and plan for shipping delays. When it comes to compliance, make sure your team is ready to go with all the necessary data early so regulations don’t further hold up importation of your materials or products.
Governments and consumers around the world are growing increasingly concerned about the effects of PFAS (per and polyfluoroalkyl substances) in products. Recently, both the EU and the US have announced that new PFAS restrictions are being considered.
We will likely see these restrictions expand further, and manufacturers should begin to investigate their products. Start by understanding what, if any, PFAS your products contain now. Then, where it is appropriate, start looking for replacement substances as soon as possible to avoid manufacturing and shipping disruptions.
Updates to SCIP
The new Substances of Concern in Products (SCIP) database was a big change for compliance programs in 2021. In 2022, companies should be getting used to submitting requested data to this database.
As SCIP becomes more widely adopted, however, companies should keep their eye out for software updates. In November 2021, the European Chemicals Agency (ECHA) released SCIP database version 2.0. This update improves search functionality and includes adaptation to the new IUCLID format.
It is possible that we will see more updates and improvements to the database in 2022, and companies will need to be aware of how any updates impact their compliance workflow.
Increased Focus on Conflict Minerals
Awareness of environmental and human rights concerns has increased in recent years, and conflict minerals regulations have followed suit. Conflict minerals regulations are designed to decrease the minerals acquired from areas where the sourcing of those minerals directly feeds regional conflict. Traditionally these have included minerals known as 3TG (tin, tantalum, tungsten, and gold). But recently more minerals, such as cobalt, have also become a focus.
In 2022, we can expect to see stronger enforcement for conflict minerals regulations as well as possible requirements for minerals beyond 3TG. Be ready by continuing your due diligence in assessing conflict minerals risks in your supply chain and communicating your requirements to your suppliers.
Possible New EPA Regulations
With a new US administration in place, it is likely that the United States will see new regulations from the Environmental Protection Agency (EPA). Chemicals restrictions are again becoming a focus of the EPA, and as such we can expect stronger enforcement and possible new rules.
The best way to be prepared for stricter regulations is to have a full materials declaration (FMD) for your materials and products. An FMD will make all the requested data available at your fingertips, enabling you to meet new regulations easily without scrambling for new information.
Get Product Compliance Support from Tetra Tech
Make your transition into the new year seamless and successful by preparing now for possible 2022 regulatory changes. Tackling compliance challenges before they become an issue will prevent your products from being held up because of supply chain or reporting issues.
Tetra Tech’s expert compliance team is here to support your company with regulatory needs in the new year. From IMDS or SCIP training to reporting management solutions, we can help you with your 2022 compliance goals.