COMPLIANCE GLOSSARY

Acrylamide is a chemical listed under Proposition 65 as a carcinogen. It was first listed on January 1, 1990, under the ‘State’s Qualified Experts’ mechanism. Acrylamide forms naturally in starchy foods (e.g., potato chips, french fries, bread, coffee) when cooked at high temperatures through the Maillard reaction. OEHHA has established a No Significant Risk Level (NSRL) of 0.2 micrograms per day for acrylamide. Proposition 65 has been the subject of significant litigation over acrylamide in food products, including a landmark First Amendment lawsuit by the California Chamber of Commerce challenging mandatory cancer warnings on coffee and other foods containing acrylamide.

An Additional Settlement Payment (ASP) is a payment made by a defendant in a Proposition 65 enforcement action above and beyond civil penalties, typically directed to a non-governmental third-party organisation (such as an environmental or public health group) rather than to OEHHA. ASPs became controversial because private enforcers could direct these payments to affiliated organisations they controlled or chose. California Attorney General regulations (Title 11, CCR, Chapter 4) significantly restrict ASPs: ASPs must not exceed 75% of the civil penalties in the settlement, must have a sufficient nexus to the underlying litigation and benefit California residents, and must be subject to judicial approval in court judgments.

Under U.S. Dodd-Frank Act Section 1502 and SEC Rule 13p-1, 'adjoining countries' are the nations that share a border with the Democratic Republic of the Congo (DRC) and are included in the definition of 'Covered Countries' subject to conflict minerals disclosure requirements. These countries are: Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.

An adverse impact is a negative effect on people or the environment resulting from a company’s own operations, its subsidiaries, or through its value chain relationships. Under the EU Corporate Sustainability Due Diligence Directive (CSDDD) and the European Sustainability Reporting Standards (ESRS E1–S4), companies must identify, prevent, mitigate, and account for actual and potential adverse impacts. The CSDDD (Directive (EU) 2024/1760) distinguishes between: actual adverse impacts (harm already occurring) and potential adverse impacts (harm that may occur if not prevented). Adverse impacts span environmental harm (e.g., GHG emissions, biodiversity loss, water pollution) and social harm (e.g., forced labour, unsafe working conditions, violation of human rights).

Aqueous Film-Forming Foam (AFFF) is a firefighting foam formulated with fluorosurfactants, typically PFOS-based or fluorotelomer-based PFAS, to suppress flammable liquid fires (Class B fires). AFFF creates a thin aqueous film that spreads over the fuel surface, cutting off oxygen and preventing reignition. Due to the persistence and toxicity of the PFAS it contains, AFFF has become one of the most significant point sources of PFAS contamination in soil and groundwater globally.

The Additional Minerals Reporting Template (AMRT), formerly known as the Pilot Reporting Template (PRT), is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) for collecting due diligence information on minerals not covered by the CMRT (3TG) or EMRT (cobalt, copper, graphite, lithium, mica, nickel). The AMRT allows input for up to ten user-specified minerals. AMRT version 1.31 was released on April 17, 2026; the next version is anticipated in Fall 2026.

Analytical testing for TSCA PBT compliance involves laboratory analysis to determine the presence and concentration of restricted PBT chemicals in materials or products. Common techniques include XRF for bromine screening (DecaBDE indicator), GC-MS for organic PBT identification, and ICP for elemental analysis. Results are compared against applicable concentration thresholds (e.g., 0.3% for 2,4,6-TTBP, 1% for PCTP).

Annex I of Directive 2011/65/EU lists the ten categories of electrical and electronic equipment (EEE) subject to RoHS restrictions: (1) Large household appliances; (2) Small household appliances; (3) IT and telecommunications equipment; (4) Consumer equipment; (5) Lighting equipment; (6) Electrical and electronic tools; (7) Toys, leisure, and sports equipment; (8) Medical devices; (9) Monitoring and control instruments (including industrial monitoring and control instruments); (10) Automatic dispensers. All EEE placed on the EU market must fall within one of these categories to determine applicable restrictions, exemptions (Annex III or IV), and CE marking obligations.

Annex II of Directive 2011/65/EU lists the ten restricted hazardous substances and their maximum concentration values (MCVs) in homogeneous materials. The ten substances and their MCVs are: Lead (Pb): 0.1% (1000 ppm); Mercury (Hg): 0.1% (1000 ppm); Cadmium (Cd): 0.01% (100 ppm); Hexavalent chromium (Cr⁶⁺): 0.1% (1000 ppm); Polybrominated biphenyls (PBBs): 0.1% (1000 ppm); Polybrominated diphenyl ethers (PBDEs): 0.1% (1000 ppm); Bis(2-ethylhexyl) phthalate (DEHP): 0.1% (1000 ppm); Butyl benzyl phthalate (BBP): 0.1% (1000 ppm); Dibutyl phthalate (DBP): 0.1% (1000 ppm); Diisobutyl phthalate (DIBP): 0.1% (1000 ppm). Directive (EU) 2025/2456 (December 12, 2025) requires the Annex II substance list to be reviewed by ECHA at least once every four years.

Annex III of Directive 2011/65/EU lists specific applications or uses of restricted substances that are exempted from the substance restrictions for all EEE categories in Annex I. Exemptions under Annex III are granted when substitution of a restricted substance is technically or scientifically impracticable, or when the negative impacts on reliability, safety, or environmental impact of substitutes would outweigh the benefits. On July 25, 2025, the EU Commission published an updated comprehensive list of existing, withdrawn, and ongoing Annex III exemptions. On September 8, 2025, delegated directives C(2025)5961 and C(2025)5939 added exemptions for lead in steel, aluminium, copper alloys, and high-melting temperature solders. Each exemption carries an expiry date; manufacturers must monitor renewals. Directive (EU) 2025/2456 transfers exemption application processing from the European Commission to ECHA.

Annex IV of Directive 2011/65/EU lists exemptions from restricted substance restrictions that apply exclusively to medical devices (EEE category 8) and monitoring and control instruments (EEE category 9). Annex IV exemptions exist because these sectors often require long product lifecycles, specific performance characteristics, and safety assurance levels that make substitution of restricted substances particularly difficult. As with Annex III, each Annex IV exemption is time-limited and must be renewed. The EU Commission’s July 25, 2025 list update includes Annex IV exemption status. Directive (EU) 2025/2456 also transfers Annex IV exemption applications to ECHA.

Annex XIV of REACH is the Authorisation List: the list of Substances of Very High Concern (SVHCs) whose placing on the market or use is prohibited after a specified Sunset Date unless an authorisation covering that specific use has been granted by the European Commission, or the use is exempt. Each Annex XIV entry specifies a Latest Application Date (LAD) and a Sunset Date. The LAD is typically 18 months before the Sunset Date; submitting an application by the LAD allows continued use pending the Commission decision.

An Annex XV dossier is the scientific and technical documentation submitted to ECHA to support: (1) identification of a substance as an SVHC for inclusion in the Candidate List; (2) proposals for new or amended restrictions under Annex XVII; or (3) proposals for inclusion in the Authorisation List (Annex XIV). Dossiers may be submitted by ECHA itself or by a Member State. The dossier must demonstrate that the substance meets the relevant hazard criteria and that regulatory action is warranted.

Annex XVII of REACH is the legally binding Restriction List, setting conditions on the manufacture, placing on the market, or use of specific substances, either as such, in mixtures, or in articles. As of 19 June 2025, Annex XVII contains 77 entries. Key recent additions include: Entry 77 (formaldehyde and releasers: emissions limits for furniture, wood-based articles, and vehicle interiors, applicable from 6 August 2026 for furniture and 6 August 2027 for road vehicles); expanded Entry 63 (lead in PVC: ≤0.1% from 29 November 2024); and new CMR substance additions under Commission Regulation (EU) 2025/1731 (effective 1 September 2025, adding TBBPA, N,N-dimethyl-p-toluidine, TPO photoinitiator, BPAF, dibutyltin maleate, and dibutyltin oxide to Appendices). Commission Regulation (EU) 2025/1090 (effective 2 June 2025) added restrictions on DMAC (N,N-dimethylacetamide) and NEP (1-ethylpyrrolidin-2-one).

An annual sustainability statement is the formal ESG reporting output required under the EU Corporate Sustainability Reporting Directive (CSRD) (Directive (EU) 2022/2464). It forms part of a company’s management report and must be prepared in accordance with the European Sustainability Reporting Standards (ESRS). The statement must cover information on: environmental matters (climate, pollution, water, biodiversity, circular economy); social matters (own workforce, workers in value chain, affected communities); governance matters (business conduct); and the company’s due diligence process. From the 2024 financial year, Wave 1 companies (large public interest entities with >500 employees) must publish their first annual sustainability statements.

Under the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 'armed groups' are defined as groups distinct from government or state military forces that use violence to pursue political or economic goals, including seizure or taxation of mineral extraction, transport, or trade. Identifying and avoiding the financing of armed groups is a core objective of both the U.S. Dodd-Frank Section 1502 and EU Conflict Minerals Regulation (EU) 2017/821.

Under REACH Article 3(3), an ‘article’ is an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. Articles include manufactured products such as electronic components, furniture, textiles, vehicles, and toys. Substances or mixtures intentionally released from articles during use (e.g., printer ink cartridges) are subject to article notification obligations if they meet SVHC thresholds.

Under TSCA PBT rules (40 CFR Part 751), an article is a manufactured item formed to a specific shape, with end-use function dependent on that shape, and with no commercial-purpose chemical change during use. Fluids and particles are excluded. This definition determines scope for PIP (3:1) and DecaBDE restrictions.

Under the TSCA Section 8(a)(7) PFAS Reporting Rule (40 CFR Part 705), an “article” is a manufactured item that is formed to a specific shape or design during manufacture, where its end-use function is dependent in whole or in part upon its shape or design during end use. This includes finished goods, components, and subassemblies that contain or were manufactured using PFAS. Importers of articles containing PFAS are subject to reporting obligations under TSCA 8(a)(7), though the November 2025 proposed revisions would exempt imported articles from reporting.

Article 33 of REACH requires suppliers of articles containing Candidate List SVHCs above 0.1% weight by weight (w/w) to provide sufficient information to allow the safe use of the article to professional recipients automatically, and to consumers within 45 days of request, free of charge. At minimum, the SVHC name must be communicated. This obligation arises immediately upon a substance’s inclusion in the Candidate List, regardless of tonnage. As of February 4, 2026, the Candidate List contains 253 entries.

Article 7(2) of REACH requires producers and importers of articles to notify ECHA when: (a) the article contains a Candidate List SVHC above 0.1% w/w, and (b) the total quantity of that SVHC present in all articles placed on the EU market by that producer/importer exceeds one tonne per year. Notification must be submitted within six months of the substance’s inclusion in the Candidate List. As of February 4, 2026, the Candidate List contains 253 entries; notifications for substances added on that date are due by August 4, 2026.

Artisanal and Small-Scale Mining (ASM) refers to informal or semi-formal mining activities conducted by individuals or small groups with limited mechanization, often operating in developing countries. ASM is a significant source of 3TG minerals, particularly gold, tin, tantalum, and tungsten in the DRC and adjoining countries. ASM operations are associated with higher conflict mineral risk because they frequently operate in conflict-affected areas and may be subject to control or taxation by armed groups.

The California Attorney General (AG) is the primary government enforcement authority for Proposition 65 under Health & Safety Code §25249.7. The AG has authority to file civil enforcement actions for Proposition 65 violations, review and comment on private enforcement settlements and judgments, and collect 75% of all civil penalties assessed. The AG’s office publishes annual summaries of Proposition 65 settlements and judgments. The AG also maintains regulations governing private party enforcement (Title 11, CCR, Chapter 4). In 2024, the AG’s office recorded over 1,300 Proposition 65 settlements totalling tens of millions of dollars.

An Authorisation Application (AfA) under REACH is the formal submission made by a manufacturer, importer, or downstream user to ECHA requesting permission to continue using an Annex XIV substance after its Sunset Date. The application must include: a Chemical Safety Report for the applied-for uses; an Analysis of Alternatives; a Substitution Plan if technically and economically feasible alternatives exist; and a Socio-Economic Analysis (SEA) where adequate control cannot be demonstrated. Applications are evaluated by ECHA’s RAC and SEAC committees; the final decision is taken by the European Commission.

Under RoHS Directive 2011/65/EU Article 3(12), an authorised representative is any natural or legal person established within the EU who has received a written mandate from a manufacturer located outside the EU to act on their behalf in relation to specified obligations. Authorised representatives for RoHS purposes may: draw up the technical file; draw up and sign the Declaration of Conformity; keep the DoC available to national authorities; cooperate with market surveillance authorities; and provide national authorities with all necessary information on the product’s conformity. Non-EU manufacturers may appoint an authorised representative, though it is not mandatory under RoHS (unlike some other EU directives).

An authorized person is any individual specifically authorized by the owner/operator to enter a regulated area where DecaBDE or PIP (3:1) is manufactured or processed. Only authorized persons with required PPE may enter.

Battery minerals due diligence refers to the supply chain transparency and risk management obligations applicable to minerals used in battery manufacturing, including cobalt, lithium, graphite (natural), nickel, copper, and manganese. While not classified as 3TG conflict minerals under Dodd-Frank, these minerals are subject to growing due diligence requirements under the EU Battery Regulation (EU) 2023/1542, emerging ESG frameworks, and customer-driven reporting via the EMRT and AMRT templates.

Bioaccumulation refers to the progressive build-up of PFAS in living organisms over time, where the rate of intake exceeds the rate of elimination. PFAS bioaccumulate due to their extreme chemical stability—the carbon-fluorine bond resists metabolic breakdown. Certain PFAS, particularly long-chain perfluoroalkyl acids like PFOA and PFOS, bind to proteins in blood serum and liver tissue and can have half-lives of several years in the human body. Bioaccumulation is a key criterion in hazard classification under REACH, the Stockholm Convention, and EPA risk assessments.

The second PBT criterion under TSCA Section 6(h). A substance is bioaccumulative when it accumulates in living organisms faster than eliminated. All five TSCA PBT chemicals were determined bioaccumulative through EPA 2018 peer-reviewed assessments.

Biodiversity refers to the variety of life on Earth — ecosystems, species, and genetic diversity. Ecosystem services are the benefits that functioning ecosystems provide to humans and society (e.g., pollination, water purification, climate regulation, soil fertility). In ESG reporting, ESRS E4 (Biodiversity and Ecosystems) under the CSRD requires companies to disclose impacts, dependencies, risks, and opportunities related to biodiversity and ecosystems. The TNFD (Taskforce on Nature-related Financial Disclosures) framework provides voluntary guidance for nature-related financial disclosures, which ISSB is building on.

Biomonitoring refers to the measurement of the body burden of a chemical in biological media (blood, urine, tissue, breast milk) to assess actual human exposure levels. In the Proposition 65 context, OEHHA uses biomonitoring data when available to estimate actual exposure levels and derive safe harbor thresholds. Under California’s Biomonitoring Program (SB 1379), OEHHA and the California Department of Public Health conduct population-level biomonitoring studies. Biomonitoring data can be relevant evidence in Proposition 65 enforcement litigation when demonstrating that actual exposure to a listed chemical is below the NSRL or MADL.

Bisphenol A (BPA) is a chemical listed under Proposition 65 as a reproductive toxicant (female endpoint) effective May 11, 2015, and separately listed as a reproductive toxicant (developmental endpoint) effective April 6, 2018. OEHHA has established a Maximum Allowable Dose Level (MADL) for BPA of 3 micrograms per day (female reproductive endpoint). BPA is widely used as a monomer in polycarbonate plastics and epoxy resins, appearing in food can linings, water bottles, thermal paper, and medical devices. BPA’s listing led to widespread reformulation of consumer products and significant enforcement litigation.

Bisphenol S (BPS) is an analogue of bisphenol A used as a BPA substitute in plastics, thermal papers, and personal care products. On January 28, 2025, California’s Developmental and Reproductive Toxicant Identification Committee (DARTIC) voted 9 to 0 to list Bisphenol S as a reproductive toxicant (male reproductive endpoint) under Proposition 65. Following the DARTIC vote, OEHHA proceeds to formally add the chemical to the Proposition 65 list, typically within approximately one year of the committee vote. Once listed, a warning would be required for exposures above the applicable Maximum Allowable Dose Level (MADL), which OEHHA has not yet established for BPS as of April 2026.

Bill of Materials (BOM) screening for TSCA PBT involves systematically reviewing all materials, components, and substances in a product BOM against the five restricted PBT chemicals and their concentration thresholds. This is the primary compliance verification method for manufacturers and importers.

Brazil’s RoHS-equivalent regulation is ABNT NBR 16156:2013 (Electrical and Electronic Products — Restriction of the Use of Certain Hazardous Substances), developed by the Brazilian Association of Technical Norms (ABNT). It restricts the same six hazardous substances as EU RoHS 1 (Pb, Hg, Cd, Cr⁶⁺, PBBs, PBDEs) at equivalent concentration limits. Brazil’s regulatory framework also includes the National Solid Waste Policy (Lei 12.305/2010) and specific sector agreements for EEE, which create extended producer responsibility (EPR) obligations. INMETRO (National Institute of Metrology, Quality, and Technology) oversees conformity assessment for electronics in Brazil.

In the context of TSCA Section 8(a)(7), a byproduct is a chemical substance produced without a separate commercial intent during the manufacture, processing, use, or disposal of another chemical substance or mixture. PFAS byproducts can form during manufacturing processes (e.g., fluoropolymer production) or during thermal decomposition of PFAS-containing materials. Under the original October 2023 rule, byproducts were reportable; the November 2025 proposed revision would exempt PFAS manufactured as byproducts from reporting.

Cadmium (Cd) is one of the ten restricted hazardous substances under RoHS Directive 2011/65/EU. It is restricted in all EEE at a maximum concentration value of 0.01% (100 ppm) by weight per homogeneous material — the strictest of all RoHS substance limits. Cadmium is used in electroplating, pigments, stabilisers, and certain semiconductor applications. Directive (EU) 2024/1416 (published May 21, 2024) narrowed the exemption for cadmium in LED chips: Annex III entry 39(a) expired November 21, 2025; entry 39(b) was created with a revised, narrower scope for specific remaining applications.

A Conflict-Affected and High-Risk Area (CAHRA) is a region characterized by armed conflict, widespread violence, weak governance, or systematic violations of international law, in which the extraction and trade of minerals may contribute to or be linked to these conditions. The OECD Due Diligence Guidance defines CAHRAs as the geographic areas where due diligence obligations are most critical. The EU Commission maintains an indicative, non-exhaustive list of CAHRAs under Regulation (EU) 2017/821, most recently updated through procurement under EC-TRADE/2025/OP/0006.

The California Code of Regulations (CCR) contains the implementing regulations for Proposition 65 in Title 27 (Environmental Protection), Division 4 (Safe Drinking Water and Toxic Enforcement Act of 1986), Chapter 6 (Clear and Reasonable Warnings), Sections 25600–25900. These regulations define: the criteria for a ‘clear and reasonable warning’ (Article 6); safe harbor warnings for consumer products (Articles 6 and 6.1); safe harbor warnings for specific exposure scenarios (e.g., food, dietary supplements, passenger vehicle parts, recreational marine vessel parts under new §§25607.50–25607.53, effective January 1, 2025); listing mechanisms (Article 3); and safe harbour levels (Article 7). Title 11 CCR Chapter 4 governs private enforcement reporting requirements.

California’s Electronic Waste Recycling Act (CA EWRA, Public Resources Code §42460 et seq.) is a state-level US regulation that restricts certain hazardous substances in covered electronic devices (CEDs) sold in California. The CA EWRA restricts four of the six EU RoHS 1 substances (Pb, Hg, Cd, Cr⁶⁺) at the same concentration limits as EU RoHS in CEDs. Covered devices are primarily video display devices with screens larger than four inches. California operates a state-level e-waste recycling fee system funded through the CEDs advance recycling fee (ARF). California’s ARF is paid at point-of-sale by consumers; manufacturers bear product compliance obligations.

The Candidate List is ECHA’s list of Substances of Very High Concern (SVHCs) identified under Article 59 of REACH. Substances are added following a formal process including Annex XV dossier submission, public consultation, and Member State Committee agreement. As of February 4, 2026, the Candidate List contains 253 entries. ECHA updates the list periodically — typically in January and June each year, with occasional interim updates. Candidate List inclusion triggers immediate obligations under Articles 7, 31, and 33 of REACH.

A carbon footprint is the total greenhouse gas (GHG) emissions — expressed in CO₂ equivalent (CO₂e) — caused directly and indirectly by an individual, organisation, product, or supply chain over a defined period. Organisational carbon footprints are measured using the GHG Protocol Corporate Standard (Scope 1, 2, and 3 emissions). Product carbon footprints are measured per unit of product over its lifecycle, typically using life cycle assessment (LCA) methodology per ISO 14067:2018 (Carbon Footprint of Products). GHG Protocol is currently updating its corporate suite of standards (final standard expected 2027).

Carbon neutrality means that an entity’s net GHG emissions equal zero through a combination of emissions reductions and carbon offsetting. A company claims carbon neutrality when residual Scope 1 and Scope 2 emissions (and sometimes Scope 3) are offset by verified carbon removal or avoidance credits. The ISO 14068-1:2023 standard (Carbon Neutrality) provides the international framework for credible carbon neutral claims. Carbon neutrality differs from Net Zero: carbon neutral focuses on balancing emissions with offsets; net zero requires deep absolute emissions reductions before any residual offsetting.

A carbon offset is a measurable, verifiable, and credible reduction or removal of GHG emissions from one source that is used to compensate for emissions produced elsewhere. Carbon offsets are generated through projects such as reforestation, renewable energy installation, methane capture, and direct air capture. The Integrity Council for the Voluntary Carbon Market (ICVCM) Core Carbon Principles (CCPs, published 2023) establish the quality standards for high-integrity voluntary carbon credits. Article 6.4 of the Paris Agreement establishes the international crediting mechanism (PACM), which became operational in 2025.

The carbon-fluorine (C–F) bond is the defining chemical feature of all PFAS. With a bond dissociation energy of approximately 485 kJ/mol, it is one of the strongest single bonds in organic chemistry. This exceptional strength is what makes PFAS resistant to heat, water, oil, chemical solvents, and biological degradation—properties that are commercially valuable but environmentally persistent. The C–F bond is the structural reason PFAS are called “forever chemicals.”

A carcinogen under Proposition 65 is a chemical that is ‘known to the state to cause cancer.’ Chemicals are added to the Proposition 65 list as carcinogens through four mechanisms: (1) formal identification by the state’s Carcinogen Identification Committee (CIC) of OEHHA’s Scientific Advisory Panel; (2) required listing of chemicals identified by an authoritative body (such as IARC, US EPA, NTP, FDA) as causing cancer; (3) formal identification under California’s Labor Code (occupational carcinogens); or (4) chemicals identified in regulations as causing cancer via other state or federal processes. The No Significant Risk Level (NSRL) is the relevant safe harbour threshold for carcinogens. Vinyl acetate was added as a carcinogen effective January 3, 2025.

The Carcinogen Identification Committee (CIC) is the state’s qualified experts body within OEHHA’s Scientific Advisory Panel responsible for identifying chemicals as known to cause cancer for purposes of Proposition 65 listing. The CIC evaluates scientific evidence on carcinogenicity and can vote to list chemicals as carcinogens when the evidence clearly shows cancer causation in humans or animals. The CIC can also review chemicals for potential delisting. In December 2025, OEHHA referred ethoprop to the CIC for review for possible delisting from the Proposition 65 carcinogen list.

The CE marking (Conformité Européenne) is the mandatory conformity marking indicating that an EEE product complies with applicable EU legislation, including the RoHS Directive 2011/65/EU. Under RoHS Article 7, EEE manufacturers must affix the CE marking before placing products on the EU market. The CE marking under RoHS must appear on the product itself or on its packaging, and must be accompanied by a Declaration of Conformity. For EEE, CE marking also encompasses compliance with other applicable directives (e.g., Low Voltage Directive, EMC Directive).

Under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, also known as “Superfund”), the EPA has designated PFOA and PFOS as hazardous substances. This designation means that releases of these PFAS above reportable quantities must be reported to the National Response Center, and responsible parties may be held liable for cleanup costs at contaminated sites. The Trump Administration (2025–) has retained these designations and is developing a framework for future PFAS hazardous substance designations that incorporates economic impact considerations.

A Certificate of Merit is a mandatory pre-filing requirement for private enforcers bringing Proposition 65 warning violation enforcement actions. Under Health & Safety Code §25249.7(d), a private enforcer must include with their 60-Day Notice of Violation a certificate stating that they have consulted with a person with relevant expertise who has reviewed facts, studies, or other data regarding the alleged exposure, and that based on this review there is a reasonable and meritorious case for bringing a Proposition 65 action. The factual information supporting the certificate must also be provided to the California Attorney General. Courts may sanction frivolous enforcement actions where the certificate is deemed insufficient.

PFAS are classified by the length of their perfluorinated carbon chain. Long-chain PFAS include perfluoroalkyl carboxylic acids with 8 or more carbons (C8+, e.g., PFOA) and perfluoroalkyl sulfonic acids with 6 or more carbons (C6+, e.g., PFOS/PFHxS). Short-chain PFAS have fewer perfluorinated carbons (e.g., PFBS at C4, PFHxA at C6 carboxylic). This classification matters because long-chain PFAS tend to be more bioaccumulative, while short-chain PFAS are more mobile in water and harder to remove in treatment.

Chain of custody in conflict minerals refers to the documented sequence of entities — from mine to smelter/refiner to downstream manufacturer — through which a mineral passes, with records at each transfer point establishing provenance and responsible sourcing status. A robust chain of custody allows downstream companies to trace whether minerals originated from conflict-affected areas and whether each transfer point exercised responsible sourcing practices.

A Chemical Safety Assessment (CSA) is a hazard and risk assessment conducted by a REACH registrant for a substance manufactured or imported above 10 tonnes per year that is classified as hazardous or is PBT/vPvB. The CSA follows the methodology in Annex I and includes: hazard assessment (physico-chemical, human health, environmental); PBT/vPvB assessment; exposure assessment; and risk characterisation. The results are documented in the Chemical Safety Report (CSR).

A Chemical Safety Report (CSR) is the formal document recording the results of a Chemical Safety Assessment. It is a mandatory part of a REACH registration dossier for substances above 10 t/year that are classified as hazardous or PBT/vPvB. The CSR documents hazard data, DNELs, PNECs, exposure scenarios, risk characterisation ratios, and risk management measures. Exposure scenarios from the CSR are appended to Safety Data Sheets (eSDS).

China RoHS (Management Methods for the Restriction of Hazardous Substances in Electrical and Electronic Products) is China’s national regulation restricting hazardous substances in EEE. The current regulation, Order No. 32 (China RoHS 2), was issued by MIIT (Ministry of Industry and Information Technology) and entered into force January 1, 2016, with full phase-in by July 1, 2019. China RoHS restricts the same six substance groups as EU RoHS (lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs), but applies a different concentration limit framework and requires additional labeling: products containing restricted substances above thresholds must display the orange hazardous substances marking; products below thresholds display the green product logo.

The October 2024 revision provides a permanent exclusion from PIP (3:1) prohibitions for circuit boards and wire harnesses, including terminal/fuse covers, cable sleeves, casings, connectors, and tapes. PIP (3:1) can continue in these applications without time limitation.

A circular economy is an economic model designed to eliminate waste and the continual use of resources by keeping products, materials, and substances in use for as long as possible through reuse, repair, remanufacturing, and recycling, in contrast to the linear ‘take-make-dispose’ economy. In ESG reporting, ESRS E5 (Resource Use and Circular Economy) under the CSRD requires companies to disclose resource inflows, outflows, waste generation, and circular economy practices. The EU Circular Economy Action Plan (2020) and Packaging and Packaging Waste Regulation (PPWR) (EU) 2025/40 provide the legislative framework.

TSCA violations, including non-compliance with PBT restrictions, can result in civil penalties up to $51,489 per day per violation (2024 inflation-adjusted maximum under 40 CFR 19.4). EPA has authority to inspect facilities, request compliance records, and initiate enforcement actions. Criminal penalties may apply for knowing or willful violations.

The maximum civil penalty under Proposition 65 is  $2,500 per violation per day for knowing and intentional violations of the warning or discharge prohibition provisions (Health & Safety Code §25249.7(b)). Courts consider multiple factors in determining the appropriate penalty amount, including: the nature and extent of the violation; the number of violations; the economic benefit gained by the violator; the deterrent effect; and the presence of any good faith efforts to comply. Private enforcers retain 25% of any civil penalties recovered; 75% is paid to OEHHA. In practice, civil penalties in private enforcement settlements are often much lower than the maximum, with attorney’s fees and costs constituting the largest component of most settlements.

A ‘clear and reasonable warning’ is the standard of warning required by Proposition 65 (Health & Safety Code §25249.6) when a business exposes any individual to a listed chemical above the applicable safe harbour level. A warning meets this standard when it is: (a) clear — provided in a manner that clearly communicates to each individual a message that the product or location contains a listed chemical and the nature of the health risk; and (b) reasonable — provided by a method reasonably calculated to reach the individual before exposure to the listed chemical. OEHHA’s Title 27 CCR regulations provide safe harbour warnings (both long-form and short-form) that, if followed exactly, are deemed to satisfy the clear and reasonable warning standard.

Climate risk refers to the financial and business risks arising from climate change, categorised as: (1) Physical risks — acute (extreme weather events: storms, floods, heat waves) and chronic (gradual changes: sea-level rise, temperature shifts, precipitation pattern changes); and (2) Transition risks — risks arising from the transition to a low-carbon economy, including policy and regulatory changes, technology shifts, market changes, and reputational impacts. Both IFRS S2 (Climate-related Disclosures) and ESRS E1 (Climate Change) require companies to disclose physical and transition climate risks and their financial implications.

The Classification, Labelling and Packaging (CLP) Regulation (EC) No 1272/2008 is the EU regulation governing the hazard classification, labelling, and packaging of chemical substances and mixtures. CLP implements the UN Globally Harmonised System (GHS) in the EU. Harmonised classifications under CLP (Annex VI) determine REACH obligations: substances classified as CMR Cat 1A/1B, PBT, or vPvB qualify as SVHCs under REACH Article 57 and may be added to the Candidate List.

A CMR substance is a chemical classified as Carcinogenic, Mutagenic, or Toxic for Reproduction under CLP Regulation (EC) No 1272/2008. Categories: 1A (known CMR effect on humans), 1B (presumed CMR effect, primarily based on animal evidence), and 2 (suspected CMR). Under REACH Article 57(a)(b)(c), substances classified as CMR Cat 1A/1B qualify as SVHCs and can be added to the Candidate List and subsequently to the Authorisation List (Annex XIV). Commission Regulation (EU) 2025/1731 (effective 1 September 2025) added newly classified CMR 1B substances including TBBPA, N,N-dimethyl-p-toluidine, and others to Annex XVII Appendices.

The Conflict Minerals Reporting Template (CMRT) is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) for exchanging due diligence information on tin, tantalum, tungsten, and gold (3TG) across supply chains. It facilitates identification of smelters and refiners used, country of origin data, and compliance status. CMRT version 6.6 is the current version, released April 17, 2026, introducing two new Product List fields: Requester Product Number and Requester Product Name. The next version is anticipated in Spring 2027.

Coltan is the informal name for columbite-tantalite, a metallic ore from which tantalum is extracted. Coltan is listed by name in Dodd-Frank Section 1502 as one of the conflict mineral ores. The DRC is one of the world’s largest coltan producers, and eastern DRC coltan mining has been directly linked to funding armed groups. Coltan is processed at tantalum refiners/processors, which are audited under RMAP for responsible sourcing.

Competent authorities under Regulation (EU) 2017/821 are the Member State authorities designated to receive conflict minerals due diligence documentation, conduct checks, and enforce the regulation. Article 10 of the Regulation requires each Member State to designate one or more competent authorities. In Germany, the competent authority is the Federal Office of Economics and Export Control (BAFA); in France, it is the Customs and Excise Authority. Competent authorities have the power to request documentation, conduct audits, and apply sanctions for non-compliance.

A Compliance Check is a formal ECHA evaluation process under REACH Article 41 to verify whether the information in a registration dossier complies with the information requirements of Annexes VII–X. ECHA selects dossiers for compliance checks based on risk-based criteria. If the dossier is found to be incomplete or inaccurate, ECHA issues a Decision requiring the registrant to submit additional information within a defined timeline. ECHA has progressively increased the rate of compliance checking since 2013.

TSCA PBT compliance dates vary by chemical and activity. Key milestones include: March 8, 2021 (PCTP manufacturing/processing ban); January 6, 2026 (2,4,6-TTBP distribution restrictions); October 31, 2024 (PIP 3:1 processing prohibitions for many uses); October 31, 2026 (PIP 3:1 article distribution prohibition); January 21, 2025 (DecaBDE/PIP 3:1 workplace safety provisions). Various phase-in periods extend from 7 to 30 years for specific PIP (3:1) uses.

Concentration thresholds establish minimum PBT chemical concentrations below which restrictions do not apply. Key thresholds: 2,4,6-TTBP at 0.3% by weight; PCTP at 1% by weight. The October 2024 revision introduced/clarified thresholds for PIP (3:1) and DecaBDE.

Under TSCA Section 8(a)(7), manufacturers may claim certain reported PFAS data as Confidential Business Information (CBI). CBI claims protect proprietary information such as specific chemical identities, manufacturing volumes, and processing details from public disclosure. However, EPA applies substantiation requirements—companies must justify why the data qualifies for confidential treatment. EPA retains the data for regulatory use but withholds it from public access if the CBI claim is upheld.

Conflict minerals are minerals whose extraction and trade in conflict-affected areas finances armed groups or contributes to human rights abuses. Under U.S. Dodd-Frank Section 1502, conflict minerals are defined as columbite-tantalite (coltan, the ore of tantalum), cassiterite (the ore of tin), gold, wolframite (the ore of tungsten), and their derivatives, specifically tantalum, tin, tungsten, and gold (collectively known as 3TG). The EU Conflict Minerals Regulation (EU) 2017/821 covers the same four minerals and their ores.

A Conflict Minerals Report (CMR) is a document filed by SEC registrants as an exhibit to Form SD when their RCOI and due diligence determine that conflict minerals may have originated in the DRC or adjoining countries and are not from recycled or scrap sources. The CMR must describe the due diligence measures taken, including the framework used (e.g., OECD Due Diligence Guidance), the facilities used to process the conflict minerals, the country of origin of the minerals, and efforts to determine mine or location of origin.

The term ‘DRC conflict-free’ was defined under the original SEC conflict minerals rules as minerals that did not directly or indirectly finance or benefit armed groups in the DRC or adjoining countries. However, following a 2014 U.S. Court of Appeals decision (National Association of Manufacturers v. SEC), SEC guidance states that companies should not be required to describe their products as ‘DRC conflict-free,’ ‘not DRC conflict-free,’ or ‘DRC conflict undeterminable’ in the Conflict Minerals Report. Instead, companies describe their due diligence efforts and findings.

A conformant smelter or refiner is a smelter or refiner facility that has completed an audit under the Responsible Minerals Assurance Process (RMAP) or another recognized due diligence scheme and has been found to meet all applicable requirements. Conformant status means the facility has demonstrated that its sourcing practices do not fund armed groups in conflict-affected areas. RMAP maintains a publicly available list of conformant, active, and eligible facilities by metal.

A conformity assessment is the process by which a manufacturer evaluates and demonstrates that an EEE product meets the requirements of the RoHS Directive 2011/65/EU before placing it on the EU market. Under RoHS Article 8, the conformity assessment procedure involves: conducting the assessment (material testing, supplier declarations, analysis); compiling the Technical Documentation (per Annex VI or EN IEC 63000:2018); drawing up a Declaration of Conformity (DoC); and affixing the CE marking. Unlike some EU directives, RoHS does not require involvement of a third-party Notified Body — it is a manufacturer self-declaration process.

Replacement parts for consumer electronic equipment receive a 7-year phase-in before PIP (3:1) prohibition takes effect. This is separate from the permanent circuit board/wire harness exclusion.

The EU Corporate Sustainability Due Diligence Directive (CSDDD) (Directive (EU) 2024/1760) requires large companies to conduct mandatory human rights and environmental due diligence across their value chains. The CSDDD was published in the Official Journal on 5 July 2024 and entered into force on 25 July 2024. Companies in scope must: adopt and implement a due diligence policy; identify actual and potential adverse impacts on human rights and the environment in their operations and value chains; prevent, mitigate, or end identified impacts; establish or participate in a complaints mechanism; and publicly report on due diligence. Under Omnibus I (December 2025 provisional agreement): CSDDD application has been delayed by one year; scope is proposed to be reduced to companies with >1,000 employees and net turnover >€450M.

The EU Corporate Sustainability Reporting Directive (CSRD) (Directive (EU) 2022/2464) requires large companies to disclose standardised sustainability information in their annual management reports, prepared in accordance with the European Sustainability Reporting Standards (ESRS). The CSRD replaced the Non-Financial Reporting Directive (NFRD). Wave 1 (large public interest entities >500 employees) applied from the 2024 financial year, with reports published in 2025. The Stop-the-Clock Directive (Directive (EU) 2025/794, in force April 17, 2025) postponed Wave 2 and Wave 3 by two years. The Omnibus I provisional agreement (December 2025) proposes reducing scope to companies with >1,000 employees and net turnover >€450M, cutting the number of affected companies by approximately 80%.

The Developmental and Reproductive Toxicant Identification Committee (DARTIC) is the state’s qualified experts body within OEHHA’s Scientific Advisory Panel responsible for identifying chemicals as known to cause birth defects, developmental toxicity, or other reproductive harm for purposes of Proposition 65 listing. DARTIC evaluates scientific evidence on reproductive and developmental toxicity. On January 28, 2025, DARTIC voted 9 to 0 to list Bisphenol S (BPS) as a reproductive toxicant (male reproductive endpoint) under Proposition 65. DARTIC also reviews chemicals for the MADL (Maximum Allowable Dose Level) determination process.

A de minimis exemption establishes a minimum concentration threshold below which PFAS in a product, mixture, or article is not subject to reporting or restriction requirements. In the EPA’s November 2025 proposed revision to the TSCA 8(a)(7) PFAS Reporting Rule, a 0.1% (1,000 ppm) by weight de minimis threshold was proposed for PFAS in mixtures and articles. The original October 2023 final rule contained no de minimis threshold, requiring reporting of any known PFAS presence regardless of concentration.

DecaBDE (CAS 1163-19-5) is a brominated flame retardant restricted under TSCA Section 6(h). Used in textiles, plastics, adhesives, foam, wire/cable insulation, electronics, and building materials. The January 2021 rule prohibited most uses; the October 2024 revision added PPE requirements, water release prohibition, and extended the nuclear wire/cable deadline.

A Declaration of Conformity (DoC) is the formal written statement in which a manufacturer declares that an EEE product meets all applicable requirements of the RoHS Directive 2011/65/EU (and any other applicable EU directives). Under RoHS Article 13, the DoC must: identify the product; reference the applicable directives and standards used; include the name and address of the manufacturer; be signed by an authorised representative; and confirm the product complies with Annex II substance restrictions and any applicable exemptions. The DoC must be kept and made available to market surveillance authorities for ten years after the product is placed on the market.

A derogation is a time-limited exemption that permits the continued manufacture, placing on the market, or use of a restricted substance for specific applications where technically feasible alternatives are not yet available. In the EU’s universal PFAS restriction proposal under REACH Annex XVII, the dossier submitters have proposed multiple derogations for sectors including medical devices, semiconductors, defense, aerospace, and certain industrial applications. Derogation periods typically range from 5 to 13.5 years after the restriction enters into force.

A designated representative is any individual or organization to whom a potentially exposed person gives written authorization to access workplace exposure records, monitoring data, and medical information related to DecaBDE or PIP (3:1) exposure.

In addition to its warning requirements, Proposition 65 contains a separate prohibition under Health & Safety Code §25249.5 against the knowing discharge or release of a listed chemical into any source of drinking water or into water or onto land where it will pass into drinking water. This discharge prohibition applies to businesses with 10 or more employees. The discharge prohibition is distinct from the warning requirement and applies regardless of whether the quantity of chemical discharged causes a ‘significant risk’ as defined under the warning provisions. The threshold is whether the discharge creates a ‘significant risk’ of exposure to the population served by the drinking water source.

Under TSCA, distribution in commerce means to sell, introduce for sale, or hold after introduction into commerce. Includes import. Many PBT prohibitions target distribution—meaning companies cannot sell or import PBT-containing products after the prohibition date.

Under RoHS Directive 2011/65/EU Article 3(14), a distributor is any natural or legal person in the supply chain (other than the manufacturer or importer) who makes EEE available on the EU market. Distributors have specific RoHS obligations under Article 11: verify that the EEE bears CE marking; check that the manufacturer and importer have fulfilled their documentation obligations; ensure the EEE is accompanied by the required documentation; and not place EEE on the market where they have reason to believe it is not compliant.

A Derived No-Effect Level (DNEL) is the level of exposure to a substance above which humans should not be exposed. DNELs are derived by registrants as part of the Chemical Safety Assessment (Annex I) and are reported in the Chemical Safety Report. DNELs are substance-specific and route-specific (inhalation, dermal, oral) and distinguish between workers and the general population. They appear in Safety Data Sheet Section 8 and serve as reference values for risk characterisation.

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (enacted July 21, 2010) is the U.S. legislative provision requiring SEC-registered issuers that manufacture or contract to manufacture products containing tin, tantalum, tungsten, or gold (3TG) — where such minerals are necessary to the product’s functionality or production — to disclose annually whether those minerals originated in the DRC or adjoining countries. Section 1502 added Section 13(p) to the Securities Exchange Act of 1934 and directed the SEC to promulgate implementing rules.

Double materiality is the concept under the EU CSRD and ESRS requiring companies to assess sustainability topics from two perspectives simultaneously: (1) Financial materiality (also called ‘outside-in’): how sustainability risks and opportunities affect the company’s financial performance, cash flows, or access to capital; and (2) Impact materiality (also called ‘inside-out’): how the company’s activities, products, and value chain affect people and the environment. A topic is material if it is material from either or both perspectives. ESRS 1 (General Requirements) defines the Double Materiality Assessment (DMA) process. EFRAG’s proposed revised ESRS (exposure drafts, July 2025) simplifies the DMA process.

Companies distributing PIP (3:1) or DecaBDE must notify recipients through SDS or product labels with EPA-mandated language. The 2024 revision updated notification language and set a transition window (February 2025 – May 2026).

Under REACH Article 3(13), a downstream user (DU) is any natural or legal person established in the EU, other than the manufacturer or importer, who uses a substance, either on its own or in a mixture, in the course of their industrial or professional activities. Downstream users include formulators, processors, and industrial users. They are distinct from distributors. Downstream users have specific REACH obligations including: checking eSDS coverage, preparing downstream user CSRs where required, notifying ECHA of uncovered uses under Article 38, and applying appropriate risk management measures.

The Democratic Republic of the Congo (DRC) is the primary geographic focus of global conflict minerals regulation. The DRC is rich in 3TG minerals and has experienced decades of armed conflict in which mineral revenues have funded armed groups. Under U.S. Dodd-Frank Section 1502 and SEC Rule 13p-1, the DRC is the central ‘covered country.’ Under EU Regulation (EU) 2017/821, the DRC is a primary conflict-affected and high-risk area. Both frameworks aim to prevent minerals extracted in the DRC from financing armed conflict.

Drinking water standards for PFAS set maximum contaminant levels (MCLs) or quality thresholds for PFAS compounds in public water supplies. In the U.S., EPA finalized the National Primary Drinking Water Regulation (NPDWR) in April 2024, setting individual MCLs of 4 parts per trillion (ppt) for PFOA and PFOS, and a hazard index-based limit for mixtures of PFHxS, PFNA, HFPO-DA (GenX), and PFBS. The EU Drinking Water Directive (EU) 2020/2184 sets a limit of 0.1 µg/L for 20 specified PFAS and 0.5 µg/L for total PFAS, applicable from January 2026.

Due diligence in the context of conflict minerals refers to the ongoing process of risk identification, assessment, and management that companies must apply to their mineral supply chains to ensure minerals do not originate from sources that fund armed conflict or contribute to human rights violations. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition, 2016) is the internationally recognized framework aligned with both Dodd-Frank Section 1502 and EU Regulation (EU) 2017/821.

The European Chemicals Agency (ECHA) is the EU regulatory body established by REACH Regulation (EC) No 1907/2006 to manage the technical, scientific, and administrative aspects of REACH. ECHA maintains the registration database, operates the REACH-IT system, coordinates substance evaluation and restriction processes, manages the Candidate List, Authorisation List (Annex XIV), and the SCIP database, and provides scientific opinions through its Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC). Since 16 September 2025, ECHA hosts the new ECHA CHEM database as the primary substance information portal.

The European Chemicals Agency (ECHA) has been formally entrusted with scientific and technical tasks under the RoHS Directive following the adoption of Directive (EU) 2025/2456 (published December 12, 2025). Under this amendment: ECHA is responsible for preparing dossiers for substance restrictions under Annex II; restriction proposals may be prepared by Member States or by ECHA upon Commission request; ECHA processes exemption applications (previously handled by the European Commission); and the Annex II substance list must be reviewed regularly by ECHA, at least once every four years.

Electrical and Electronic Equipment (EEE) is defined in RoHS Directive 2011/65/EU Article 3(1) as equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields, and is designed for use with a voltage rating not exceeding 1000 V for alternating current and 1500 V for direct current. RoHS applies to EEE falling within the product categories in Annex I. Open scope (covering all EEE not explicitly excluded) applies since 22 July 2019 following the phased implementation under Directive 2011/65/EU.

EFRAG is the European Financial Reporting Advisory Group, an independent body established under the CSRD (EU) 2022/2464 as the standard-setter for European Sustainability Reporting Standards (ESRS). EFRAG develops draft ESRS for adoption by the European Commission as delegated acts. EFRAG published the first set of draft ESRS in April 2022 and final recommendations in November 2022; the Commission adopted them in July 2023 (Delegated Regulation (EU) 2023/2772). EFRAG submitted simplified ESRS technical advice to the Commission in December 2025, following the Omnibus I mandate. Revised ESRS are expected to be adopted by the Commission in Q2 2026.

The Extended Minerals Reporting Template (EMRT) is a free, standardized reporting template developed by RMI for collecting due diligence information on cobalt, copper, graphite (natural), lithium, mica, and nickel — minerals not covered by the CMRT but increasingly subject to regulatory and customer-driven due diligence requirements. EMRT version 2.11 was released April 17, 2026. Key changes include IPC-1755-compatible enhancements, updated ISO country abbreviations, correction of a Declaration tab date input issue, and refreshed Smelter Reference and Standard Smelter Lists. The next EMRT version is anticipated in Spring 2027.

EN IEC 63000:2018 (Technical Documentation for the Assessment of Electrical and Electronic Products with Respect to the Restriction of Hazardous Substances) is the harmonised European standard specifying the technical documentation requirements for RoHS compliance. It defines the content, structure, and evidence requirements for technical documentation used to demonstrate conformity with Directive 2011/65/EU, including: supplier declarations, test reports, material data sheets, risk assessment, and a declaration of compliance. Compliance with EN IEC 63000:2018 gives a presumption of conformity with the RoHS technical documentation requirements.

Endocrine disruptors (EDs) are substances that interfere with the hormonal systems of living organisms. Under REACH Article 57(f), substances identified as having endocrine-disrupting properties with probable serious effects on human health or the environment — and for which there is scientific evidence of probable serious effects — may be identified as SVHCs on the basis of ‘equivalent concern.’ ECHA’s Integrated Regulatory Strategy identifies EDs as a priority substance group for restriction and SVHC identification under the REACH Recast.

A Proposition 65 enforcement action is a civil lawsuit filed in California Superior Court alleging that a business has violated the warning or discharge prohibition provisions of the Act. Enforcement actions may be brought by: (1) the California Attorney General; (2) district attorneys; (3) city attorneys of cities with populations over 750,000; or (4) private persons or organisations acting in the public interest (‘private enforcers’). A private enforcer must first provide a 60-Day Notice of Violation to the alleged violator, the AG, and applicable district or city attorney. If no government enforcer initiates action within 60 days of the notice, the private enforcer may file suit. In 2024, there were over 1,300 Proposition 65 settlements, totaling tens of millions of dollars.

An Environmental Impact Assessment (EIA) is the formal process of identifying, predicting, evaluating, and mitigating the environmental consequences of a proposed project or activity before it is approved. In the EU, the EIA Directive (Directive 2011/92/EU, as amended by Directive 2014/52/EU) requires EIA for specified categories of public and private projects. In ESG reporting, EIA data informs ESRS E1–E5 disclosures on environmental impacts and forms part of the evidence base for double materiality assessment. EIA findings also feed into product and operational carbon footprints.

EPA is the federal authority administering and enforcing TSCA, including PBT restrictions under Section 6(h). EPA promulgated the 2021 and 2024 PBT rules, conducts inspections, and enforces compliance with civil penalties up to $51,489/day/violation.

Under the TSCA Section 8(a)(7) Reporting Rule (40 CFR Part 705), EPA defines PFAS as any chemical substance or mixture containing a chemical substance that structurally contains at least one of three sub-structures: (1) R–(CF2)–CF(R’)R”, where both CF2 and CF moieties are saturated carbons; (2) R–CF2OCF2–R’, where R and R’ can be F, O, or saturated carbons; and (3) CF3C(CF3)R’R”, where R’ and R” can be F or saturated carbons. This definition requires at least two fluorinated carbons, making it narrower than the OECD definition.

ESG stands for Environmental, Social, and Governance — the three categories used to evaluate a company’s sustainability performance, risks, and opportunities. Environmental criteria cover climate change, GHG emissions, pollution, water use, biodiversity, and circular economy. Social criteria cover human rights, labour practices, community relations, diversity, health and safety, and supply chain working conditions. Governance criteria cover corporate governance structures, anti-corruption, executive pay, board composition, and business ethics. ESG has no single universal regulatory definition but is operationalised through frameworks including CSRD/ESRS (EU), IFRS S1/S2 (global), GRI Standards, and SEC climate disclosure rules (US).

ESG (Environmental, Social, and Governance) frameworks increasingly incorporate conflict minerals due diligence as a social and governance disclosure expectation, independent of legal requirements. Institutional investors, sustainability ratings agencies (e.g., MSCI, Sustainalytics), and industry frameworks such as the Global Reporting Initiative (GRI 408/409 on child and forced labour, GRI 3 on material topics) reference responsible mineral sourcing as a social risk metric. Companies not subject to Dodd-Frank or EU Regulation may still face conflict minerals disclosure expectations from investors and customers through ESG channels.

The European Sustainability Reporting Standards (ESRS) are the mandatory disclosure standards under the CSRD (EU) 2022/2464, adopted by the European Commission as delegated acts. The first set of sector-agnostic ESRS (ESRS Set 1) was adopted in Commission Delegated Regulation (EU) 2023/2772 in July 2023, effective from January 2024. ESRS Set 1 comprises 12 standards: 2 cross-cutting (ESRS 1: General Requirements; ESRS 2: General Disclosures) and 10 topical (E1–E5: environmental; S1–S4: social; G1: governance). A Quick-Fix Delegated Act was adopted July 11, 2025 (published November 13, 2025). Revised simplified ESRS are expected from the Commission in Q2 2026 based on EFRAG’s December 2025 technical advice.

Essential use is a policy framework concept used to evaluate whether the continued use of a hazardous substance (such as PFAS) is justified because no technically and economically feasible alternatives exist and the use is necessary for health, safety, or critical societal functions. While not yet a formal legal criterion in all jurisdictions, essential use has been referenced in the EU’s Chemicals Strategy for Sustainability, in the universal PFAS restriction proposal’s derogation framework, and in several U.S. state PFAS laws as a basis for granting or denying exemptions.

Regulation (EU) 2017/821 of the European Parliament and of the Council, dated 17 May 2017, lays down supply chain due diligence obligations for Union importers of tin, tantalum, tungsten, their ores, and gold originating from conflict-affected and high-risk areas (CAHRAs). The Regulation entered into full force on 1 January 2021. It applies to EU importers above volume thresholds set in Annex I, ensuring that no less than 95% of total volumes imported into the EU of each mineral is subject to obligations. On October 16, 2025, the European Commission formally recognized RMAP as equivalent to the Regulation’s requirements via Implementing Decision (EU) 2025/2071.

The EU Taxonomy Regulation (EU) 2020/852 is a classification system defining which economic activities are environmentally sustainable. Activities must meet four conditions to qualify as ‘taxonomy-aligned’: (1) make a substantial contribution to at least one of six environmental objectives; (2) do no significant harm (DNSH) to any of the other five objectives; (3) comply with minimum social and governance safeguards; and (4) comply with technical screening criteria set out in EU delegated regulations. The six objectives are: climate change mitigation; climate change adaptation; sustainable use and protection of water; transition to a circular economy; pollution prevention and control; and protection of biodiversity. The Taxonomy Climate Delegated Act was revised July 4, 2025, with simplifications applicable from January 1, 2026.

The Eurasian Economic Union (EAEU) Technical Regulation 037/2016 ‘On Restriction of the Use of Hazardous Substances in Electrical and Electronic Products’ is the RoHS-equivalent regulation for EAEU member states: Russia, Belarus, Kazakhstan, Armenia, and Kyrgyzstan. TR EAEU 037/2016 entered into force March 1, 2018, and restricts the same six hazardous substances as EU RoHS 1 (Pb, Hg, Cd, Cr⁶⁺, PBBs, PBDEs) at the same concentration limits. Compliance requires a conformity declaration or certificate of conformity, and products must bear the EAC (Eurasian Conformity) mark.

An exclusion exempts a specific use from PBT manufacturing, processing, or distribution prohibitions. Some are permanent (circuit boards for PIP 3:1), others are time-limited phase-ins. The 2024 revision revised and clarified exclusions, narrowing some and creating new ones.

An exemption under RoHS Directive 2011/65/EU is a specific authorisation for the use of a restricted substance in a defined application or material where substitution is technically or scientifically impracticable, or where the negative environmental, health, or consumer safety impacts of substitutes would outweigh the benefits. Exemptions are listed in Annex III (all EEE categories) and Annex IV (medical devices and monitoring/control instruments only). Under Article 5, exemptions are time-limited and must be renewed. Renewal applications must be submitted at least 18 months before expiry. Following Directive (EU) 2025/2456 (December 12, 2025), exemption applications are submitted to ECHA.

TSCA Section 6(h) mandates expedited action for PBT chemicals. Unlike Section 6(a) requiring formal risk evaluation, Section 6(h) directs EPA to reduce exposure to the extent practicable without cost-benefit analysis. Created by the Lautenberg Act (2016).

The 2024 revision requires export notification to EPA for DecaBDE-containing wire and cable destined for nuclear power generation facilities outside the U.S. This provision ensures EPA awareness of DecaBDE exports even under the nuclear exclusion.

An exposure assessment is the quantitative or qualitative evaluation of the actual amount of a listed chemical that an individual is exposed to from a specific product, facility, or activity. Under Proposition 65, a warning is required only when exposure exceeds the applicable safe harbour level (NSRL for carcinogens; MADL for reproductive toxicants). OEHHA provides guidance on calculating exposure levels, including its ‘Proposition 65 Exposure Calculator,’ and technical guidance documents specifying default exposure assumptions (e.g., body weight, inhalation rates, dermal absorption factors, ingestion rates). Businesses may use product-specific exposure data to demonstrate that exposures do not require warnings.

Owners/operators must conduct initial and periodic monitoring of worker exposure in regulated areas. Monitoring data cannot exceed 5 years old. Initial deadlines: May 5, 2025 (most facilities); November 9, 2026 (federal agencies, non-federal labs).

An Exposure Scenario (ES) is the set of conditions, including operational conditions and risk management measures, that describe how a substance can be used safely. Exposure scenarios are developed by registrants as part of the Chemical Safety Assessment for substances manufactured or imported above 10 t/year that require a CSR. They are communicated to downstream users as annexes to the extended Safety Data Sheet (eSDS). If a downstream user’s use is not covered by any ES in the supplier’s eSDS, the DU must take action.

An extended Safety Data Sheet (eSDS) is a Safety Data Sheet that includes one or more Exposure Scenarios appended to Section 16. The eSDS is required when a Chemical Safety Report has been prepared for the substance (i.e., hazardous substances or PBT/vPvB substances above 10 t/year). It communicates the specific conditions of safe use (operational conditions, risk management measures) for each identified use to downstream users in the supply chain. The eSDS is the primary REACH communication tool for chemical supply chains.

Financed emissions are the GHG emissions attributable to a financial institution’s loans, investments, and other financial activities, representing the institution’s contribution to the carbon footprint of its clients and investees. Financed emissions fall under Scope 3 Category 15 of the GHG Protocol Corporate Value Chain Standard. IFRS S2 requires financial institutions to disclose financed emissions. In December 2025, the ISSB issued targeted amendments to IFRS S2 GHG emissions disclosures clarifying that financial firms may limit reporting to financed emissions from loans and investments (assets under management), and that facilitated emissions from investment banking and insurance underwriting are excluded.

TSCA Section 6(h) restricts five PBT chemicals: (1) DecaBDE (CAS 1163-19-5); (2) PIP (3:1) (CAS 68937-41-7); (3) 2,4,6-TTBP (CAS 732-26-3); (4) HCBD (CAS 87-68-3); (5) PCTP (CAS 133-49-3). Each has distinct prohibitions, exclusions, and compliance dates in 40 CFR Part 751, Subpart E.

The five-step OECD framework is the internationally recognized due diligence process for responsible mineral sourcing from conflict-affected and high-risk areas, established in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition, 2016). The five steps are: (1) Establish strong company management systems; (2) Identify and assess risks in the supply chain; (3) Design and implement a strategy to respond to identified risks; (4) Carry out independent third-party audit of supply chain due diligence at identified checkpoints; (5) Report annually on supply chain due diligence.

Fluoropolymers are a subclass of PFAS consisting of high-molecular-weight polymers with a carbon-only backbone in which some or all hydrogen atoms are replaced by fluorine. Common fluoropolymers include polytetrafluoroethylene (PTFE, brand name Teflon), polyvinylidene fluoride (PVDF), fluorinated ethylene propylene (FEP), and perfluoroalkoxy alkane (PFA). Fluoropolymers are widely used in industry due to their exceptional chemical resistance, thermal stability, low friction, and electrical insulation properties.

A fluorosurfactant is a surface-active agent (surfactant) in which at least one of the hydrocarbon tails has been partially or fully fluorinated. Fluorosurfactants lower the surface tension of water far more effectively than hydrocarbon surfactants, making them essential in applications requiring wetting, leveling, or film formation on low-energy surfaces. Common PFAS-based fluorosurfactants include PFOS, PFOA salts, and fluorotelomer-based products. They are used in firefighting foams, metal plating, semiconductor manufacturing, and textile treatments.

A fluorotelomer is a type of polyfluoroalkyl substance produced via the telomerization process, in which tetrafluoroethylene (TFE) is reacted with a telogen to create fluorinated carbon chains of varying lengths. Fluorotelomer-based products include fluorotelomer alcohols (FTOHs, e.g., 6:2 FTOH, 8:2 FTOH), fluorotelomer acrylates, and fluorotelomer sulfonates. The nomenclature ‘X:Y’ indicates X perfluorinated carbons followed by Y non-fluorinated carbons. Fluorotelomers are widely used in textile treatments, paper coatings, and food packaging.

A food safe harbour warning is a specific Proposition 65 safe harbour warning format for foods that expose consumers to listed chemicals above safe harbour levels. OEHHA’s December 2024 amendments (effective January 1, 2025) added a new short-form food warning option under Title 27 CCR §25607.53. For food products, the long-form warning has historically been required; the new short-form food warning option must include the name of at least one listed chemical. For cancer risk: ‘Consuming this product can expose you to [chemical name], a chemical known to the State of California to cause cancer. For more information go to www.P65Warnings.ca.gov/food.’ Similar format applies for reproductive toxicants.

“Forever chemicals” is a widely used informal term for per- and polyfluoroalkyl substances (PFAS). The term reflects the defining characteristic of these substances: their extreme environmental persistence. The carbon-fluorine bonds in PFAS resist thermal, chemical, photolytic, and biological degradation under normal environmental conditions. As a result, PFAS accumulate in soil, water, air, and living organisms indefinitely. While not a regulatory or scientific term, “forever chemicals” has become the dominant public and media framing for PFAS and drives public pressure for regulatory action.

Form SD is the SEC disclosure form under which SEC-registered companies file their annual conflict minerals disclosures. Required by Exchange Act Section 13(p) and Rule 13p-1 (implementing Dodd-Frank Section 1502), Form SD must be filed annually by May 31 for the prior calendar year. Form SD requires companies to disclose: whether conflict minerals are necessary to the functionality or production of their products, the results of their Reasonable Country of Origin Inquiry (RCOI), and — if applicable — a Conflict Minerals Report describing due diligence measures.

The general provisions section applies across all five PBT chemicals in Subpart E. The 2024 revision added the repair and maintenance exclusion here, applicable to all PBT chemicals. General provisions also establish the applicability of Subpart E and cross-cutting definitions.

GenX is the trade name for a processing technology using hexafluoropropylene oxide dimer acid (HFPO-DA, CAS No. 13252-13-6) and its ammonium salt as replacements for PFOA in fluoropolymer manufacturing. GenX chemicals were introduced by Chemours as a shorter-chain alternative to PFOA but have since been identified as persistent and toxic. HFPO-DA has been added to the REACH Candidate List as an SVHC and is subject to EPA drinking water standards (Hazard Index approach).

The Glasgow Financial Alliance for Net Zero (GFANZ) is a global coalition of financial institutions (banks, insurers, asset managers, asset owners) committed to accelerating the decarbonisation of the global economy and reaching net zero GHG emissions by 2050. GFANZ was established at COP26 in November 2021 and encompasses over 675 member firms managing over $150 trillion in assets. Member institutions must commit to: setting science-based net-zero targets covering all emission scopes; regularly reporting progress; reviewing targets every five years; and aligning portfolio activities with net-zero pathways.

The Greenhouse Gas (GHG) Protocol is the most widely used international accounting framework for quantifying and managing GHG emissions from private and public sector operations, value chains, and products. Developed by the World Resources Institute (WRI) and World Business Council for Sustainable Development (WBCSD), the GHG Protocol’s Corporate Standard (2004) defines Scope 1, 2, and 3 emission categories. IFRS S2 mandates the use of GHG Protocol as the measurement standard for corporate GHG disclosures. The GHG Protocol is undergoing its first major revision of its corporate suite of standards, with updates to the Scope 3 standard currently under public consultation (final standard expected 2027). In September 2025, ISO and the GHG Protocol announced plans to harmonize their standards.

Global RoHS equivalents are national or regional regulations that restrict the same or similar hazardous substances as the EU RoHS Directive in electrical and electronic equipment. Key global RoHS equivalents include: China RoHS (Order No. 32, 2016); UK RoHS (SI 2012/3032, as amended); India E-Waste Management Rules (E-Waste Rules 2022); Japan J-Moss (JIS C 0950:2008); South Korea Resource Recycling Act (RRA, Act No. 18547); Turkey RoHS (AEEE Yönetmeliği); California Electronic Waste Recycling Act (CA EWRA); Saudi Arabia (SASO RoHS); Taiwan (CNS 15663); Ukraine (UkrSEPRO); Brazil (ABINEE/ABNT NBR 16156:2013); and Eurasia/EAEU (Technical Regulation TR EAEU 037/2016).

Gold (Au) is one of the four 3TG conflict minerals under Dodd-Frank Section 1502 and EU Regulation (EU) 2017/821. Gold is extracted from ores and is used in electronics (contacts, connectors), jewellery, dental applications, and financial products. Gold presents the most complex conflict minerals traceability challenge among 3TG minerals because it is fungible, traded globally in standardized forms, and a significant source of ASM revenues in the DRC and adjoining countries. Gold refiners are the pinch point for gold supply chain due diligence.

Governance in ESG refers to the internal systems, practices, and processes by which a company is directed and controlled, including: board composition, diversity, and independence; executive compensation and sustainability linkage; audit and risk management frameworks; anti-corruption and anti-bribery policies; transparency and disclosure; whistleblower protections; and political engagement. ESRS G1 (Business Conduct) under the CSRD covers: corporate culture, protection of whistleblowers, animal welfare, political engagement, management of relationships with suppliers, and corruption/bribery. IFRS S1 requires governance disclosures of sustainability-related financial information.

A government enforcer under Proposition 65 is a state or local government authority authorised to bring enforcement actions for Proposition 65 violations. Government enforcers include: the California Attorney General (with primary authority); district attorneys of any California county; and city attorneys of cities with populations exceeding 750,000 (currently Los Angeles, San Diego, San Jose, and San Francisco). If a government enforcer initiates a Proposition 65 action within 60 days of receiving a 60-Day Notice of Violation from a private party, the private party is preempted from filing their own suit. Government enforcement actions are generally considered more credible and complex than private enforcement actions.

Greenwashing occurs when an organisation makes misleading, exaggerated, or unsubstantiated environmental or sustainability claims about its products, services, or operations. In the EU, the Greenwashing Directive (EU) 2024/825 (Empowering Consumers for the Green Transition Directive, applicable from March 2026) prohibits unsubstantiated sustainability claims, unverified environmental labels, and misleading claims about future sustainability performance. The Green Claims Directive (COM(2023) 166, under negotiation) will additionally require pre-substantiation of environmental claims before market use.

The Global Reporting Initiative (GRI) Standards are the world’s most widely used voluntary sustainability reporting framework, enabling organisations to report on their environmental, social, and governance (ESG) impacts in a standardised, comparable way. GRI Standards are structured as: GRI 1 (Foundation 2021), GRI 2 (General Disclosures 2021), and topic-specific standards (GRI 300 series: environmental; GRI 400 series: social). The GRI Standards use an impact materiality perspective (focusing on actual and potential impacts on people and the environment). GRI and the ESRS are aligned through an interoperability mapping developed jointly by GRI and EFRAG.

HCBD (CAS 87-68-3) is a chlorinated compound restricted under TSCA Section 6(h). Used as a solvent, heat transfer fluid, and chemical intermediate. Manufacturing and processing are banned except as a byproduct at or below 1% by weight. Also regulated under EU POPs and the Stockholm Convention.

Hexavalent chromium (Cr⁶⁺, chromium(VI)) is one of the ten restricted hazardous substances under RoHS Directive 2011/65/EU, restricted at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. Hexavalent chromium is used in decorative and functional electroplating (e.g., hard chrome plating, chromate conversion coatings on aluminium and zinc), corrosion inhibitors in cooling systems, and pigments. In EEE, it is most commonly found in surface finishes and protective coatings on metal components.

A homogeneous material is defined in RoHS Directive 2011/65/EU Article 3(20) as a material that cannot be mechanically disjointed into different materials — meaning a single material, uniform throughout its composition. RoHS maximum concentration values (MCVs) for restricted substances apply at the homogeneous material level, not at the product or component level. Examples: a plastic pellet, a wire coating, a solder alloy, a plating layer, or a glass substrate. A component such as a capacitor is not a homogeneous material; it must be disaggregated into its constituent homogeneous materials for assessment.

Human rights due diligence (HRDD) is the ongoing process through which companies identify, prevent, mitigate, and account for how they address actual and potential adverse human rights impacts in their operations and value chains. The UN Guiding Principles on Business and Human Rights (UNGPs, 2011) provide the foundational HRDD framework. In the EU, the CSDDD (Directive (EU) 2024/1760) mandates HRDD as a legal obligation for companies above defined thresholds. The OECD Due Diligence Guidance for Responsible Business Conduct (2018) provides operational guidance aligned with the UNGPs.

IEC 62321 is the international standard series specifying test methods for determining the concentrations of restricted substances in EEE, developed by IEC Technical Committee 111 (Environmental standardization for electrical and electronic products). The series covers: IEC 62321-1 (Introduction and Overview); IEC 62321-2 (Disassembly, disjointment, and mechanical sample preparation); IEC 62321-3 (Screening for lead, mercury, cadmium, total chromium, total bromine — XRF); IEC 62321-4 (Mercury by CV-AAS, CV-AFS, ICP-OES, ICP-MS); IEC 62321-5 (Cadmium, lead, total chromium by AAS, ICP-OES, ICP-MS); IEC 62321-6 (Polybrominated biphenyls and polybrominated diphenyl ethers by GC-MS); IEC 62321-7-1 (Hexavalent chromium in polymer and electronics by colorimetric method); IEC 62321-7-2 (Hexavalent chromium in solid materials); IEC 62321-8 (Phthalates by GC-MS).

IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information is the International Sustainability Standards Board’s (ISSB) overarching standard requiring entities to disclose material information about sustainability-related risks and opportunities. Issued in June 2023 and effective from January 1, 2024 (with earlier application permitted), IFRS S1 sets out the: objective of sustainability-related financial disclosures; general requirements for how to prepare and present disclosures; and four core pillars (Governance, Strategy, Risk Management, and Metrics & Targets) applicable across all sustainability topics. IFRS S1 must be applied together with IFRS S2.

IFRS S2 Climate-related Disclosures is the ISSB standard requiring entities to disclose information about climate-related risks and opportunities. Issued June 2023, effective January 1, 2024. IFRS S2 builds on TCFD recommendations and requires disclosures across four pillars: Governance (board oversight of climate risks); Strategy (climate risks and opportunities, scenario analysis, transition plan); Risk Management (how climate risks are identified and managed); and Metrics and Targets (GHG emissions — Scope 1, 2, and 3 — and other climate metrics). IFRS S2 mandates the use of GHG Protocol for emissions measurement. In December 2025, the ISSB issued targeted amendments to IFRS S2 GHG emissions disclosures (effective for reporting periods beginning January 1, 2027).

Impact materiality (also called ‘inside-out’ materiality) is one of the two dimensions of the CSRD’s double materiality concept. A sustainability topic is impact-material when the company’s own activities or value chain relationships cause, contribute to, or are directly linked to significant actual or potential adverse or positive impacts on people or the environment. Under ESRS 1, impact materiality assessment considers: the severity of the impact (scale, scope, irremediability for actual impacts; severity and likelihood for potential impacts); the company’s ability to influence the impact; and whether the impact is actual or potential.

Under TSCA, import equals manufacturing and distribution in commerce. Importing articles, products, or substances containing restricted PBT chemicals triggers the same prohibitions as domestic production. The 2024 revision explicitly aligned import prohibitions with domestic use prohibitions for PIP (3:1) and DecaBDE.

Under REACH Article 3(11), an importer is any natural or legal person established within the EU who is responsible for the import of substances, mixtures, or articles into the EU customs territory. EU importers bear the same registration obligations as EU manufacturers: substances imported above 1 tonne per year must be registered by the importer unless they are registered by a non-EU manufacturer’s Only Representative. Importers of articles must comply with Article 33 and Article 7(2) notification obligations for SVHC-containing articles.

Under RoHS Directive 2011/65/EU Article 3(13), an importer is any natural or legal person established within the EU who places EEE from a third country on the EU market. Importers have significant RoHS obligations under Article 10: ensure the EEE has been subjected to the conformity assessment procedure; ensure the manufacturer has drawn up a Declaration of Conformity; ensure CE marking is affixed; verify the manufacturer’s technical documentation; attach their own name and contact address to the product; and not place non-compliant EEE on the market. Importers must also cooperate with market surveillance authorities and maintain copies of the DoC for ten years.

In the context of TSCA Section 8(a)(7), an impurity is a PFAS substance that is unintentionally present in a chemical substance, mixture, or article as a result of manufacturing processes, raw material contamination, or environmental exposure. The November 2025 proposed revision to the PFAS Reporting Rule would exempt PFAS present as unintentional impurities from reporting requirements. This recognizes that many manufacturers have no knowledge of or control over trace PFAS contamination in incoming materials.

An Independent Private Sector Audit (IPSA) is a third-party audit of a company’s Conflict Minerals Report (CMR) conducted by an independent, qualified audit firm. The original SEC conflict minerals rule required issuers to obtain an IPSA of their CMR. However, the SEC Division of Corporation Finance issued staff guidance in 2017 stating that it would not recommend enforcement action if companies did not obtain the IPSA. This de facto suspension of IPSA enforcement has remained in place; however, the Form SD filing requirement has continued.

India’s RoHS-equivalent regulation is contained in the E-Waste (Management) Rules, currently the E-Waste (Management) Rules 2022 issued by the Ministry of Environment, Forest and Climate Change (MoEFCC). Schedule II of the Rules restricts the same six hazardous substances as EU RoHS (lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs) at the same concentration limits. The Rules apply to manufacturers, producers, importers, and dealers of 21 product categories of EEE listed in Schedule I. Compliance requires Extended Producer Responsibility (EPR) registration with the Central Pollution Control Board (CPCB).

“Intentionally added PFAS” refers to PFAS that are deliberately included in a product, mixture, or manufacturing process for a functional purpose (e.g., water resistance, oil repellency, chemical resistance, non-stick properties). This is distinct from PFAS present as unintentional impurities or contaminants. Several U.S. state laws (e.g., Maine, Minnesota, Washington, Colorado, New York) use “intentionally added” as the threshold for product bans and disclosure requirements, rather than a numeric concentration limit.

An Interpretive Guideline is an official statement issued by OEHHA that interprets Proposition 65 regulations as applied to specific factual scenarios, without creating new legal obligations. Interpretive Guidelines clarify how existing law applies and are available to any person or business seeking guidance. They are distinct from Safe Use Determinations (SUDs), which are issued in response to specific factual requests and can be relied upon as a defence to a subsequent enforcement action. Interpretive Guidelines are published on the OEHHA website and may address product categories, exposure scenarios, or warning format questions.

IPC-1755 is the international data exchange standard that governs how conflict minerals information is structured, formatted, and transmitted between supply chain partners. Developed by IPC (Association Connecting Electronics Industries), IPC-1755 enables machine-readable and automated exchange of CMRT and EMRT data between companies and compliance platforms. Both the CMRT and EMRT are designed to align with IPC-1755. CMRT 6.6 includes enhancements that remain fully compatible with IPC-1755.

The ITSCI (ITRI Tin Supply Chain Initiative) Programme is a supply chain transparency and traceability scheme for 3TG minerals — particularly tin, tantalum, and tungsten — operating in artisanal mining regions of Central Africa, including the DRC, Rwanda, and Burundi. ITSCI implements a bagging and tagging system at mining sites to track mineral origin from mine to export, and includes an incident reporting system to identify and address human rights and security incidents. ITSCI membership is widely used by smelters as evidence of responsible upstream sourcing for RMAP audits.

IUCLID is the software application developed by ECHA and OECD for recording, storing, maintaining, and exchanging data on intrinsic and hazard properties of chemical substances. REACH registrants use IUCLID to prepare and submit registration dossiers to ECHA via REACH-IT. IUCLID dossiers contain physico-chemical data, toxicological and ecotoxicological data, classification and labelling, and Chemical Safety Reports. ECHA regularly updates IUCLID to align with regulatory and format changes.

J-Moss (Japanese Industrial Standard JIS C 0950:2008 — ‘Marking for the Presence of the Specific Chemical Substances for Electrical and Electronic Equipment’) is Japan’s RoHS-equivalent marking standard. It applies to seven categories of EEE and six restricted substances (the same six as EU RoHS 1: lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs). J-Moss requires a J-Moss mark to be displayed on products indicating whether restricted substances are present above a threshold. Unlike EU RoHS, J-Moss is a JIS standard (not a law), making it a market expectation rather than a legal mandate in most cases, though it aligns with the Law for the Promotion of Effective Utilization of Resources (LPEUR).

‘Known to the state’ is the standard under Proposition 65 (Health & Safety Code §25249.8) for chemicals that have been officially listed as causing cancer or reproductive harm. A chemical is ‘known to the state’ to cause cancer or reproductive toxicity when OEHHA has officially listed it on the Proposition 65 chemical list through one of the approved listing mechanisms (CIC/DARTIC determination, authoritative body listing, Labor Code listing, or regulatory listing). This specific legal phrase distinguishes chemicals that trigger Proposition 65 obligations from chemicals that are merely suspected of causing harm. Once a chemical is ‘known to the state,’ the warning and discharge prohibitions apply.

Korea RoHS is implemented through the Act on the Resource Circulation of Electrical and Electronic Equipment and Vehicles (Resource Recycling Act, RRA), Act No. 18547, last amended 2022, administered by the Ministry of Environment (MoE). The RRA restricts the same six hazardous substances as EU RoHS 1 (lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs) in EEE, at the same concentration limits. Compliance requires: a hazardous substance content label on products; submission of substance content information to the Korea Environmental Industry & Technology Institute (KEITI); and meeting e-waste take-back obligations.

RoHS labeling requirements vary by jurisdiction. Under EU RoHS 2 (Directive 2011/65/EU), no product-level substance content label is required; instead, the CE marking signifies RoHS compliance and is the visible compliance indicator. However, many global RoHS equivalents require explicit substance content labels on products: China RoHS mandates an orange (hazardous substances present above threshold) or green (compliant product) logo; Japan J-Moss requires a J-Moss content mark; Korea RRA requires hazardous substance content labeling; India E-Waste Rules require labeling with hazardous substance presence; and Saudi Arabia SASO RoHS and Taiwan CNS 15663 have specific labeling requirements.

The Latest Application Date (LAD) is the deadline by which an application for authorisation of an Annex XIV substance must be submitted to ECHA to allow continued use of that substance beyond its Sunset Date while the application is being evaluated. The LAD is specified in each Annex XIV entry, typically set 18 months before the Sunset Date. If a complete application is submitted before the LAD, the applicant may continue use legally until the European Commission makes a decision, even if the Sunset Date has passed.

The Frank R. Lautenberg Chemical Safety for the 21st Century Act (2016) amended TSCA and created Section 6(h) for expedited PBT regulation. It replaced the old least burdensome standard with reduce exposure to the extent practicable for PBT chemicals.

Lead (Pb) is one of the most frequently cited chemicals in Proposition 65 enforcement. Lead is listed as both a carcinogen (listed October 1, 1992) and a reproductive toxicant (listed February 27, 1987). OEHHA has established a Maximum Allowable Dose Level (MADL) for lead of 0.5 micrograms per day (reproductive toxicity). For cancer risk, a No Significant Risk Level of 15 micrograms per day applies. Lead is found in a wide range of consumer products including electronics, jewellery, ceramics, plumbing fixtures, toys, and food contact materials. Lead-in-jewellery and lead-in-consumer-electronics cases represent some of the most common Proposition 65 enforcement actions.

Lead (Pb) is the most commonly regulated restricted substance under RoHS Directive 2011/65/EU, restricted at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. Lead was historically used extensively in EEE: as solder (tin-lead alloys), in glass (CRT displays, leaded glass in lamps), in stabilisers for PVC cables, in surface treatments (lead-based paints, coatings), and in batteries. RoHS restricts lead in all EEE categories across Annex I, subject to specific exemptions in Annex III (all categories) and Annex IV (medical devices and monitoring/control instruments). Delegated directives C(2025)5961 and C(2025)5939 (September 8, 2025) updated lead exemptions for steel, aluminium, copper alloys, and high-melting temperature solders.

A Life Cycle Assessment (LCA) is a systematic analytical method for evaluating the environmental impacts of a product, service, or process across all stages of its life: from raw material extraction through manufacturing, distribution, use, and end-of-life disposal or recycling. LCA is standardised under ISO 14040:2006 (Principles and Framework) and ISO 14044:2006 (Requirements and Guidelines). LCA quantifies impacts across multiple environmental categories: climate change (GHG emissions), water use, land use, eutrophication, acidification, toxicity, and resource depletion. LCA provides the methodological foundation for product carbon footprints (ISO 14067) and eco-design requirements.

A listing mechanism is one of four approved processes through which OEHHA adds chemicals to the Proposition 65 list as known to cause cancer or reproductive toxicity. The four mechanisms are: (1) the Formally Required Mechanism (chemicals identified by an authoritative body such as IARC, NTP, US EPA, or FDA as causing cancer or reproductive harm); (2) the State’s Qualified Experts mechanism (CIC or DARTIC determination based on scientific evidence review); (3) the Labor Code Mechanism (chemicals listed as occupational carcinogens under the California Labor Code); and (4) the Regulations/Administrative Action Mechanism (chemicals listed through specified state or federal regulatory processes). Each mechanism has distinct criteria, procedures, and timelines.

A long-form warning is the primary safe harbour warning format under Proposition 65 regulations (Title 27 CCR §25603 and §25607 et seq.), providing consumers with detailed information about their exposure to a listed chemical. For consumer products, the long-form warning must include: the Prop 65 warning symbol (yellow triangle with black exclamation mark); the signal word ‘WARNING:’ (or ‘CA WARNING:’ or ‘CALIFORNIA WARNING:’ per January 2025 amendments); at least one listed chemical name; and a reference to www.P65Warnings.ca.gov. For consumer products with carcinogen exposure: ‘WARNING: This product can expose you to [chemical name], which is known to the State of California to cause cancer. For more information go to www.P65Warnings.ca.gov.’

The lookback period under TSCA Section 8(a)(7) is the historical timeframe for which manufacturers (including importers) must report PFAS-related data. The rule requires reporting for each year between January 1, 2011, and December 31, 2022, in which a company manufactured or imported PFAS or PFAS-containing products. This 12-year retrospective window was mandated by the National Defense Authorization Act (NDAA) for Fiscal Year 2020.

Under REACH Article 3(9), a manufacturer is any natural or legal person established within the EU who manufactures a substance within the EU. EU manufacturers of substances above 1 tonne per year must register those substances with ECHA before placing them on the EU market. Manufacturers are primary duty holders for registration, Chemical Safety Assessment, Safety Data Sheet preparation, and supply chain communication obligations.

Under SEC Rule 13p-1 implementing Dodd-Frank Section 1502, a ‘manufacturer’ is a company that (1) manufactures a product or (2) contracts to manufacture a product. A company is considered to ‘contract to manufacture’ if it has some actual influence over the manufacturing of the product. The SEC has stated that a company that merely affixes its label to a generic product or negotiates basic product specifications (such as color or size) may not be considered to contract to manufacture for conflict minerals purposes.

Under TSCA, the term “manufacturer” includes any person who manufactures or imports a chemical substance. For TSCA Section 8(a)(7) PFAS reporting, this means that any company that manufactured PFAS domestically or imported PFAS—in any form including as a component of a mixture or article—at any time between 2011 and 2022 is subject to reporting obligations. The TSCA definition of “manufacture” is broad: it covers production, preparation, compounding, and processing of a chemical substance.

Under RoHS Directive 2011/65/EU Article 3(11), a manufacturer is any natural or legal person who manufactures EEE, or who has EEE designed or manufactured and markets that EEE under their own name or trademark. Manufacturers have the most comprehensive RoHS obligations under Article 7: design and manufacture EEE in accordance with Annex II restrictions; draw up required technical documentation; conduct the conformity assessment; draw up the Declaration of Conformity; affix CE marking; affix name, registered trademark, and address on the EEE; provide instructions and safety information; take corrective actions when EEE is non-compliant; and cooperate with market surveillance authorities.

Under TSCA § 3(9), manufacture means to import, produce, or manufacture a chemical substance. This captures importers, domestic producers, and companies that compound PBT-containing products.

Market surveillance is the activity by which competent national authorities in EU Member States verify that EEE placed on the EU market complies with applicable legislation, including RoHS Directive 2011/65/EU. Under Article 19 of RoHS and Regulation (EU) 2019/1020 (Market Surveillance Regulation), national authorities may: inspect products and documentation; require manufacturers, importers, or distributors to provide technical documentation and DoC; conduct or commission substance testing; and order corrective action, market withdrawal, or product recall for non-compliant EEE. RAPEX (now SAFETY Gate) is the EU rapid alert system through which Member States notify each other of dangerous non-compliant products.

A materiality assessment is the process by which a company identifies and prioritises the sustainability topics most relevant to its business, stakeholders, and impacts. Under the CSRD/ESRS framework, companies must conduct a Double Materiality Assessment (DMA) covering both financial materiality (impact on the company) and impact materiality (the company’s impact on people and the environment). GRI Standards use an impact-only materiality concept. IFRS S1/S2 use financial materiality only (the ‘outside-in’ perspective). The EFRAG revised ESRS (July 2025 EDs) simplify the DMA process, making it more principles-based and less prescriptive.

A Maximum Allowable Dose Level (MADL) is the safe harbour level established by OEHHA for chemicals listed as reproductive toxicants under Proposition 65. Below the MADL, a business is not required to provide a Proposition 65 reproductive toxicant warning. The MADL is set at 1/1000 of the level shown to have no observable effect in the most sensitive reproductive endpoint study. Key MADLs include: lead: 0.5 μg/day; BPA: 3 μg/day; phthalates (DEHP): 8.7 μg/day; di-n-butyl phthalate (DBP): 8.7 μg/day; methanol: 47,000 μg/day. MADLs are published in Title 27 CCR §25805 and OEHHA’s Proposition 65 list (Excel version).

Maximum concentration values (MCVs) are the substance-specific concentration limits above which a restricted substance is prohibited in a homogeneous material under RoHS Directive 2011/65/EU. The MCVs in Annex II are: 0.1% (1000 mg/kg or 1000 ppm) for lead (Pb), mercury (Hg), hexavalent chromium (Cr⁶⁺), PBBs, PBDEs, DEHP, BBP, DBP, and DIBP; and 0.01% (100 mg/kg or 100 ppm) for cadmium (Cd). These limits apply per homogeneous material within the EEE, not per product or component. MCVs are not equivalent to maximum impurity levels — homogeneous materials containing restricted substances above the MCV must either use an applicable exemption or be eliminated from the product.

A Maximum Contaminant Level (MCL) is the highest concentration of a contaminant allowed in public drinking water under the U.S. Safe Drinking Water Act (SDWA). In April 2024, EPA finalized MCLs for six PFAS: 4 ppt for PFOA, 4 ppt for PFOS, 10 ppt for PFHxS, 10 ppt for PFNA, 10 ppt for HFPO-DA (GenX), and a Hazard Index of 1 for mixtures of PFHxS, PFNA, HFPO-DA, and PFBS. Public water systems must comply with these standards by 2029.

Mercury (Hg) is one of the ten restricted hazardous substances under RoHS Directive 2011/65/EU, restricted at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. Mercury was historically used in fluorescent lamps (compact fluorescent lamps — CFLs), mercury-containing switches and relays, and measuring instruments. Several Annex III exemptions exist for mercury in specific lamp types and measuring instruments where substitution is technically difficult. The transition to LED lighting has significantly reduced mercury use in consumer lighting EEE, though certain professional lighting and measuring instrument exemptions remain active.

Mine of origin refers to the specific mining location from which a mineral was extracted. In conflict minerals frameworks, identifying the mine of origin is the ultimate objective of supply chain traceability, as it allows companies to determine whether minerals came from conflict-affected areas and whether the mining operation exercised responsible practices. However, for most 3TG minerals, traceability beyond the smelter/refiner to the mine level is not yet achievable at scale. The OECD Due Diligence Guidance calls on companies to make ‘reasonable efforts’ to identify mine of origin.

Minnesota’s PFAS reporting law (SF 2744, enacted 2024) is one of the most comprehensive state-level PFAS regulations in the United States. It requires manufacturers selling products containing intentionally added PFAS in Minnesota to report PFAS usage data to the Minnesota Pollution Control Agency (MPCA) through the PRISM reporting platform. The first major reporting deadline is July 1, 2026. The law covers all product categories and requires disclosure of PFAS identity, function, and concentration.

Under REACH Article 3(2), a mixture is a mixture or solution composed of two or more substances. Mixtures as such are not registered under REACH, but the substances they contain must be registered. Suppliers of mixtures must provide Safety Data Sheets to professional recipients for classified mixtures, and must communicate SVHC content above 0.1% w/w to recipients and consumers. The REACH SDS obligations (Articles 31–32) apply throughout the mixture supply chain.

The 2024 revision established: 15-year phase-in for PIP (3:1) in new motor vehicle parts; 30-year phase-in for replacement motor vehicle parts. These replace the previous exclusion and recognize automotive service life requirements.

A tailored safe harbour warning for motor vehicle parts is a new warning format added by OEHHA’s December 2024 amendments (effective January 1, 2025), codified at Title 27 CCR §25607.50. This safe harbour warning applies to exposures that occur during the purchase, handling, or installation of parts for motor vehicles (cars, SUVs, vans, pickup trucks, motorcycles, ATVs). The required warning text is: ‘WARNING: Handling passenger or off-highway motor vehicle parts can expose you to chemicals such as phthalates and lead, which can cause cancer and reproductive harm. To minimize exposure, service the vehicle in a well-ventilated area, wear gloves, and wash your hands. For more information go to www.P65Warnings.ca.gov/motor-vehicle-parts.’

The National Defense Authorization Act (NDAA) for Fiscal Year 2020 (§7351) provided a statutory definition of PFAS for the purposes of TSCA Section 8(a)(7) reporting. The NDAA defines a perfluoroalkyl substance as “a man-made chemical of which all of the carbon atoms are fully fluorinated carbon atoms” and a polyfluoroalkyl substance as “a man-made chemical containing a mix of fully fluorinated carbon atoms, partially fluorinated carbon atoms, and nonfluorinated carbon atoms.” This congressional definition framed EPA’s subsequent rulemaking.

Under SEC Rule 13p-1, a conflict mineral is ‘necessary to the functionality or production’ of a product when it is intentionally included in the product and either (a) necessary for the product to function as intended (‘necessary to functionality’) or (b) required in the production process that creates the product (‘necessary to production’). Conflict minerals that are incidentally present in the product or that are contained in common materials (such as off-the-shelf components) where the manufacturer had no influence over their inclusion may not be considered ‘necessary.’

Net zero means achieving a balance between the greenhouse gases emitted and those removed from the atmosphere, such that net GHG emissions equal zero. Under the Science Based Targets initiative (SBTi) Corporate Net Zero Standard (2021), achieving net zero requires: (1) reducing absolute Scope 1, 2, and 3 GHG emissions by at least 90% from a base year (or 95% in some sectors) by no later than 2050; and (2) neutralising any residual (remaining <5–10%) emissions through permanent carbon removal (not offsets). The Paris Agreement’s 1.5°C pathway aligns with global net zero GHG emissions by mid-century. Net zero differs from carbon neutral: carbon neutral allows offsetting all current emissions; net zero requires near-total elimination.

The Non-Financial Reporting Directive (NFRD) (Directive 2014/95/EU) was the predecessor EU sustainability reporting framework to the CSRD, requiring large public interest entities with >500 employees to disclose non-financial information on environmental, social, employee, anti-corruption, and human rights matters. The NFRD was criticised for lack of consistency, comparability, and depth of disclosure. It was replaced by the CSRD (Directive (EU) 2022/2464), which introduced mandatory ESRS standards and expanded scope. Entities already reporting under the NFRD (approximately 11,000 companies) were the original Wave 1 CSRD entities.

'No data, no market' is the foundational REACH principle under Article 5: no substance may be manufactured in or imported into the EU, either on its own, in a mixture, or in an article, above 1 tonne per year without prior registration with ECHA, unless it is exempt. This principle reverses the pre-REACH approach, placing the burden of demonstrating safety on industry rather than on regulators.

A No Significant Risk Level (NSRL) is the safe harbour exposure level established by OEHHA for chemicals listed as carcinogens under Proposition 65. Below the NSRL, a business is not required to provide a Proposition 65 cancer warning. The NSRL is set at the level of exposure that would cause no more than one excess case of cancer in 100,000 individuals exposed over a 70-year lifetime. Key NSRLs include: lead: 15 μg/day; acrylamide: 0.2 μg/day; arsenic: 10 nanograms/day; benzene: 12.7 μg/day; cadmium: 0.05 μg/day (tobacco); styrene: 27 μg/day. NSRLs are published in Title 27 CCR §25703 and OEHHA’s Proposition 65 list.

A non-isolated intermediate is a PFAS substance that is produced and consumed within a continuous chemical manufacturing process without being deliberately removed from the reaction vessel, accumulating in storage, or being transferred between facilities. The November 2025 proposed revision to TSCA 8(a)(7) would exempt non-isolated intermediates from reporting, recognizing that these transient substances may never exist outside the reactor and are often uncharacterizable.

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition, 2016) is the primary international framework for conflict minerals supply chain due diligence. It provides a five-step due diligence process applicable to all companies in the mineral supply chain. It includes a general guidance chapter applicable to all minerals and metal-specific supplements for gold (Supplement on Gold), tin, tantalum, and tungsten (Supplement on Tin, Tantalum and Tungsten). Both the U.S. Dodd-Frank/SEC rule and EU Regulation (EU) 2017/821 are aligned with this guidance.

The Organisation for Economic Co-operation and Development (OECD) defines PFAS as “fluorinated substances that contain at least one fully fluorinated methyl (–CF3) or methylene (–CF2–) carbon atom (without any H/Cl/Br/I atom attached to it).” This 2021 definition is the broadest widely-adopted PFAS definition, covering an estimated 10,000+ substances. It serves as the basis for the EU’s universal PFAS restriction proposal under REACH and is the most commonly referenced definition in international regulatory and scientific contexts.

The Office of Environmental Health Hazard Assessment (OEHHA) is the primary California state agency responsible for implementing Proposition 65 (the Safe Drinking Water and Toxic Enforcement Act of 1986). OEHHA’s Proposition 65 responsibilities include: maintaining and updating the list of chemicals known to cause cancer or reproductive harm (900+ chemicals as of April 2026); establishing safe harbour levels (NSRLs and MADLs); developing and amending warning regulations (Title 27 CCR); issuing interpretive guidelines and Safe Use Determinations; supporting the Scientific Advisory Panel (including CIC and DARTIC); and receiving 75% of all civil penalties from Proposition 65 enforcement actions.

The EU Omnibus I package refers to the European Commission’s proposals published February 26, 2025 (COM(2025) 801 and COM(2025) 812) and the subsequent December 2025 provisional agreement between the European Parliament and Council to significantly simplify EU sustainability reporting and due diligence requirements. Key changes under the provisional agreement: CSRD scope reduced to companies with >1,000 employees and net turnover >€450M (reducing coverage by approximately 80%); Wave 2 and Wave 3 CSRD delayed by two years (Stop-the-Clock); CSDDD application delayed one year; ESRS simplified (revised standards expected Q2 2026); EU Taxonomy reporting simplified. On February 24, 2026, the EU Council officially approved the Omnibus I directive.

Proposition 65 warning regulations include specific requirements for products sold online and through catalogs. Under Title 27 CCR §25600.2(b), for an internet purchase, the Proposition 65 warning must be provided before the purchaser completes the purchase (i.e., before the transaction is finalised on the website). The warning must be clearly associated with the product listing. Under the January 2025 amendments, retailers must display a new short-form warning online within 60 calendar days after receiving notice of the new short-form warning from a manufacturer (for internet purchases made prior to January 1, 2028). Warnings delivered after purchase or at time of delivery do not qualify for safe harbour protection.

An Only Representative (OR) is a legal person established in the EU who is appointed by a non-EU manufacturer to fulfil registration obligations under REACH on behalf of EU importers of the manufacturer’s substances. Under Article 8, when an OR is appointed, EU importers of the represented substances become downstream users and are relieved of registration obligations for those substances. The OR registers with ECHA, maintains the registration, and reports EU importers to ECHA.

The entity responsible for regulated areas, PPE, exposure monitoring, signage, and recordkeeping at workplaces handling DecaBDE or PIP (3:1).

P65Warnings.ca.gov is the official California state website maintained by OEHHA that consumers and businesses are directed to in all Proposition 65 safe harbour warnings. This website provides: consumer information about specific chemicals and their health effects; product category fact sheets; business resources; the full Proposition 65 chemical list; frequently asked questions; and links to regulatory and enforcement information. All Proposition 65 safe harbour warning formats (long-form and short-form) must include a reference to www.P65Warnings.ca.gov or the relevant subcategory URL (e.g., www.P65Warnings.ca.gov/food, www.P65Warnings.ca.gov/motor-vehicle-parts).

The Paris Agreement is the legally binding international climate treaty adopted at COP21 on December 12, 2015 and entered into force on November 4, 2016 under the UN Framework Convention on Climate Change (UNFCCC). Its central aim is to limit global average temperature increase to well below 2°C above pre-industrial levels and pursue efforts to limit it to 1.5°C. Parties (countries) must submit Nationally Determined Contributions (NDCs) and progressively strengthen them every five years. The Paris Agreement’s Article 6 establishes international carbon markets. Net zero GHG emissions globally by mid-century is required to achieve the 1.5°C goal.

Polybrominated biphenyls (PBBs) are a group of brominated flame retardants historically used in plastics for EEE. PBBs are restricted under RoHS Directive 2011/65/EU at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. PBBs were phased out of most EEE applications before the introduction of RoHS due to environmental and health concerns. The primary concern is their persistence, bioaccumulation potential, and toxicity (PBT properties). PBBs are assessed together with PBDEs in RoHS technical documentation.

Polybrominated diphenyl ethers (PBDEs) are a group of brominated flame retardants used in plastics, printed circuit boards, and textile applications in EEE. PBDEs are restricted under RoHS Directive 2011/65/EU at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. Ten individual congener groups include decabromodiphenyl ether (DecaBDE), octaBDE, and pentaBDE. DecaBDE was subject to debate but is now also restricted following alignment with Stockholm Convention obligations and REACH restrictions. PBDEs are assessed using IEC 62321-6.

A PBT chemical is persistent (resists degradation), bioaccumulative (builds up in organisms), and toxic (causes adverse effects). TSCA Section 6(h) requires expedited action to reduce exposure to the extent practicable. Five chemicals are currently regulated.

PBT stands for Persistent, Bioaccumulative, and Toxic—three hazard properties that, when a substance meets all three criteria, trigger the highest level of regulatory concern. Under REACH Annex XIII, PBT criteria include specific half-life thresholds for persistence, bioconcentration factors, and toxicity endpoints. Many PFAS meet PBT or the related vPvB (very Persistent, very Bioaccumulative) criteria, which is the primary basis for their SVHC identification under REACH.

A PBT (Persistent, Bioaccumulative, and Toxic) substance is a substance meeting the criteria set out in Annex XIII of REACH for all three properties simultaneously: persistence (degradation half-lives in water, sediment, or soil exceeding specified thresholds), bioaccumulation (bioconcentration factor (BCF) or bioaccumulation factor (BAF) exceeding specified thresholds), and toxicity (showing chronic toxicity effects in freshwater or marine organisms, or classified as CMR 1A/1B, or showing endocrine-disrupting effects). PBT substances qualify as SVHCs under REACH Article 57(d).

PCTP (CAS 133-49-3) is a rubber vulcanization accelerator. All manufacturing/processing banned above 1% by weight since March 8, 2021. No phase-in periods or time-limited exclusions.

Perfluorooctane sulfonic acid (PFOS, CAS No. 1763-23-1) is a fully fluorinated eight-carbon sulfonic acid and one of the earliest PFAS to face global regulatory action. PFOS was widely used in firefighting foams (AFFF), metal plating, and stain-resistant treatments. It was listed under the Stockholm Convention in 2009 (initially with acceptable purposes, further restricted in 2019), restricted under the EU POPs Regulation, and designated as a hazardous substance under U.S. CERCLA.

Perfluorooctanoic acid (PFOA, CAS No. 335-67-1) is a fully fluorinated eight-carbon carboxylic acid and one of the most widely studied and regulated PFAS. PFOA was historically used as a processing aid in fluoropolymer manufacturing (e.g., PTFE production) and as a component of surface treatment formulations. It is classified as a Group 1 carcinogen by IARC (2023), is listed as a Persistent Organic Pollutant under the Stockholm Convention (2019), is restricted under REACH, and is designated as a hazardous substance under CERCLA.

The first PBT criterion. A substance is persistent when it resists environmental degradation and remains in soil, water, sediment, or air for extended periods. All five TSCA PBT chemicals are persistent.

The 2024 revision requires PPE for workers in DecaBDE/PIP (3:1) regulated areas: at minimum NIOSH-approved respiratory protection (half-mask N100 or equivalent). Effective January 21, 2025 for most workplaces.

Undecafluorohexanoic acid (PFHxA, CAS No. 307-24-4) is a short-chain (C6) perfluorocarboxylic acid. PFHxA and its salts and related substances face restriction under EU REACH Annex XVII, with the restriction entering into force in April 2026. This restriction was proposed by German authorities in 2019 and adopted by the European Commission. It covers PFHxA, its salts, and precursors that can degrade to PFHxA in the environment.

Perfluorohexane sulfonic acid (PFHxS, CAS No. 355-46-4) is a six-carbon perfluoroalkyl sulfonic acid that was widely used as a shorter-chain alternative to PFOS. PFHxS was listed under the Stockholm Convention (Annex A, elimination) in 2022 with no acceptable purposes or specific exemptions—making it the most strictly controlled PFAS under the treaty. PFHxS is also on the REACH Candidate List as an SVHC.

A time-limited transition period before a PBT prohibition takes full effect. PIP (3:1) timelines: 7 years (consumer electronics replacement), 10 years (manufacturing equipment), 15 years (new motor vehicle parts, aerospace lubricants), 25 years (service life replacement), 30 years (replacement motor vehicle parts).

Phthalates are a group of plasticiser chemicals listed under Proposition 65 as reproductive toxicants. Multiple phthalates are individually listed: Di(2-ethylhexyl) phthalate (DEHP) — listed as causing reproductive toxicity (male and female), MADL: 8.7 μg/day; Di-n-butyl phthalate (DBP) — listed, MADL: 8.7 μg/day; Diisodecyl phthalate (DIDP), Diisononyl phthalate (DINP), and others are also listed. Phthalates are commonly found in PVC plastic products, vinyl flooring, cables, medical devices, personal care products, and food packaging. Phthalates are specifically named in the new motor vehicle parts tailored warning (§25607.50) effective January 2025.

Four phthalate plasticisers were added to the RoHS restricted substances list by Directive 2015/863/EU, amending Annex II: bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP). All four are restricted at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. They apply to EEE categories 1–7 and 10 from July 22, 2019; categories 8, 9, and 11 (medical devices, monitoring instruments, in vitro diagnostics) from July 22, 2021. The four phthalates are used as plasticisers in PVC and other polymers to make them flexible.

In conflict minerals supply chains, the ‘pinch point’ is the point in the supply chain where all upstream ore flows converge before being transformed into a metal product that cannot be traced back to its original source. For 3TG minerals, the smelter or refiner is the pinch point. Once ore is smelted into metal, individual origin traceability is effectively lost. This is why conflict minerals due diligence frameworks focus audit activity at the smelter/refiner level rather than requiring each downstream manufacturer to trace minerals to the mine level.

PIP (3:1) (CAS 68937-41-7) is an organophosphate flame retardant and functional fluid. The most complex TSCA PBT chemical: numerous exclusions, phase-ins, concentration thresholds, downstream notification, and workplace safety. Key dates: October 2024 processing prohibitions; October 2026 article distribution prohibition.

PMT (Persistent, Mobile, and Toxic) and vPvM (very Persistent and very Mobile) are substance hazard categories proposed under the REACH Recast as additional SVHC criteria in Article 57. PMT/vPvM substances are particularly concerning because their mobility means they can contaminate drinking water sources at concentrations that cannot be removed by conventional water treatment. ECHA has already begun identifying PMT/vPvM substances under Article 57(f) (equivalent concern) pending the formal Article 57 amendment expected under the REACH Recast.

A Predicted No-Effect Concentration (PNEC) is the environmental concentration of a substance below which adverse effects on the environment are not expected to occur. PNECs are derived for relevant environmental compartments (freshwater, marine water, sediment, soil, and secondary poisoning) as part of the Chemical Safety Assessment (Annex I). They are used in the environmental risk characterisation: the risk characterisation ratio (RCR) = measured/predicted environmental concentration (PEC) divided by the PNEC.

The EU Persistent Organic Pollutants Regulation ((EU) 2019/1021, recast) implements the Stockholm Convention on POPs within EU law, banning or severely restricting the production, placing on the market, and use of listed persistent organic pollutants. Several PFAS are listed as POPs: PFOS (2009), PFOA and its salts and related compounds (2019), PFHxS (2022), and long-chain PFCAs (C9–21, listed in 2025 with a global ban from December 2026). The POPs Regulation takes precedence over REACH for listed substances.

TSCA Section 6(h)(4) requires EPA to reduce exposure to the extent practicable—meaning achievable, feasible, workable, and reasonable without full cost-benefit analysis. This explains why some uses are banned (alternatives exist) while others get exclusions (alternatives unavailable).

A PFAS precursor is a substance that can be transformed—through environmental degradation, biological metabolism, or industrial processing—into a terminal perfluoroalkyl acid (PFAA) such as PFOA, PFOS, or other persistent PFAS. Common precursor classes include fluorotelomer alcohols (FTOHs), perfluoroalkyl sulfonamides, and side-chain fluorinated polymers. Approximately 90% of the 4,700+ PFAS identified in the OECD’s 2018 database are potential precursors to PFAAs.

A private enforcer (sometimes called a ‘citizen enforcer’ or colloquially a ‘bounty hunter’) is a private individual or organisation who brings Proposition 65 enforcement actions ‘in the public interest’ under Health & Safety Code §25249.7. Private enforcers may bring suit if: (1) they have provided a 60-Day Notice of Violation to the alleged violator, the AG, and applicable district or city attorney; and (2) no government enforcer has filed suit within 60 days. Private enforcers who prevail receive 25% of assessed civil penalties plus attorney’s fees and costs. In 2024, there were over 1,300 Proposition 65 private enforcement settlements totalling tens of millions of dollars in payments to private enforcers and their attorneys.

Under TSCA § 3(13), processing means preparation of a chemical after manufacture for distribution: formulation, blending, incorporation into products. Processing prohibitions may have different dates than manufacturing or distribution prohibitions.

Proposition 65 (formally the Safe Drinking Water and Toxic Enforcement Act of 1986) is a California voter initiative (Ballot Initiative, November 4, 1986) codified at California Health & Safety Code §25249.5 et seq. It requires: (1) businesses with 10 or more employees to provide a ‘clear and reasonable’ warning before knowingly exposing any person to a listed chemical above the safe harbour level; and (2) businesses to refrain from knowingly discharging listed chemicals into drinking water sources. As of April 2026, there are approximately 900 chemicals on the Proposition 65 list. The law is enforced by the California AG, district attorneys, city attorneys, and private enforcers. It applies to products sold or exposures occurring in California.

The Proposition 65 list is the official catalogue of chemicals ‘known to the state of California to cause cancer, birth defects or other reproductive harm’ maintained by OEHHA. As of April 2026, the list contains approximately 900 chemicals. OEHHA updates the list periodically — chemicals are added through the four listing mechanisms (CIC/DARTIC determination, authoritative body, Labor Code, regulatory listing). OEHHA publishes the list in PDF and Excel format on its website; the Excel version includes listing dates, safe harbour levels, and listing mechanism for each chemical. Businesses must screen their products and operations against the current Proposition 65 list.

Public reporting in conflict minerals refers to the obligation for companies to publicly disclose their conflict minerals due diligence activities, findings, and smelter data on an annual basis. For U.S. SEC registrants, this is accomplished through Form SD and the attached Conflict Minerals Report, both publicly filed with the SEC via EDGAR and posted on the company website. Under EU Regulation (EU) 2017/821, Article 9 requires Union importers to make their supply chain due diligence policies and practices publicly available on the internet on an annual basis.

Quantum dots are semiconductor nanocrystals used in display technologies (QLED displays, photoluminescent films in LCDs) to enhance colour accuracy and efficiency. Cadmium selenide (CdSe) quantum dots contain cadmium, a restricted substance under RoHS Annex II at 0.01% (100 ppm) per homogeneous material. Annex III entry 39(a) provided an exemption for cadmium in quantum dots for LED chips, which expired November 21, 2025 following Directive (EU) 2024/1416 (published May 21, 2024). Directive (EU) 2024/1416 created a revised, narrower-scope exemption entry 39(b) covering specific remaining quantum dot applications that cannot yet be replaced with cadmium-free alternatives.

RAC is ECHA’s Risk Assessment Committee, responsible for preparing scientific opinions on: restriction proposals under Annex XVII; authorisation applications and review reports; and substance evaluation conclusions. RAC assesses the risks to human health and the environment and evaluates whether proposed restrictions or conditions are appropriate to adequately control identified risks. RAC opinions feed into the European Commission’s final decisions on restrictions and authorisations.

RAC (Committee for Risk Assessment) and SEAC (Committee for Socio-Economic Analysis) are the two independent scientific committees within ECHA that evaluate restriction proposals under REACH. RAC assesses whether a proposed restriction appropriately addresses risks to human health and the environment. SEAC evaluates socio-economic impacts, alternatives availability, and proportionality. Both must issue opinions before the European Commission can adopt a restriction.

The Responsible Business Alliance (RBA) Code of Conduct is the leading industry standard for social, environmental, and ethical responsibility in global supply chains, primarily used in the electronics and technology sectors. It covers: labour standards (freely chosen employment, working hours, wages, humane treatment); health and safety; environmental management (emissions, water, waste, hazardous substances); ethics (anti-corruption, intellectual property, privacy); and management systems. Companies joining the RBA commit to implementing the Code across their operations and supply chain. The current version is RBA Code of Conduct v9.0 (2023).

A Reasonable Country of Origin Inquiry (RCOI) is the initial due diligence step required of SEC registrants under Dodd-Frank Section 1502. An RCOI is a good-faith inquiry into whether a company’s conflict minerals originated in the DRC or adjoining countries. The RCOI uses supplier declarations (typically CMRT data) to establish likely country of origin. If the RCOI reasonably determines that minerals did not originate from covered countries, or originated from scrap/recycled sources, a Conflict Minerals Report may not be required.

The universal PFAS restriction is a proposed amendment to REACH Annex XVII that would restrict the manufacture, placing on the market, and use of all per- and polyfluoroalkyl substances in the EU/EEA. Submitted in January 2023 by five national authorities (Denmark, Germany, Netherlands, Norway, Sweden), it is the broadest chemical restriction ever proposed under REACH. ECHA’s RAC adopted its final opinion in March 2026 confirming PFAS warrant a group-wide restriction. SEAC agreed its draft opinion in March 2026, with a 60-day public consultation closing May 2026. SEAC’s final opinion is expected by end of 2026, after which the European Commission will draft the restriction regulation.

The REACH Candidate List is a published list of Substances of Very High Concern (SVHCs) identified under REACH Article 59. Several PFAS have been added to the Candidate List, including PFOA, PFHxS, HFPO-DA (GenX), C9–14 PFCAs, and additional PFAS groups identified in 2019, 2020, and 2023. SVHC identification triggers communication and notification obligations for companies placing articles containing SVHCs above 0.1% w/w on the EU market.

The REACH Recast refers to the comprehensive revision of REACH Regulation (EC) No 1907/2006, announced under the EU Chemicals Strategy for Sustainability (CSS) and the European Green Deal. The recast is expected to introduce: formal PMT/vPvM substance criteria; a generic risk approach enabling faster restriction of high-hazard substance groups; polymer registration requirements; revised registration information requirements for low-tonnage substances; stronger enforcement provisions; and integration with the Digital Product Passport framework. A first proposal from the European Commission was anticipated by the end of 2025.

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is Regulation (EC) No 1907/2006 of the European Parliament and of the Council, dated 18 December 2006, establishing a comprehensive European Union system for managing chemical substances. REACH came into force on 1 June 2007 and has been amended multiple times. It applies to all chemical substances manufactured in or imported into the EU above 1 tonne per year, with obligations across the supply chain for manufacturers, importers, downstream users, and distributors. REACH established ECHA as its central regulatory body.

The REACH Restriction Roadmap is ECHA’s multi-annual planning tool that lists substances or substance groups for which restriction actions are planned or under preparation, including the proposed timeline. Published under ECHA’s Integrated Regulatory Strategy, the Roadmap gives industry advance warning of upcoming Annex XVII restrictions, typically 3–5 years before restrictions take effect. Groups currently on the roadmap include PFAS (per- and polyfluoroalkyl substances), microplastics, bisphenol A and analogues, and other substance families.

REACH-IT is ECHA’s secure web-based system for submitting formal REACH dossiers, notifications, and inquiries electronically. Through REACH-IT, registrants submit registration dossiers (prepared in IUCLID), applications for authorisation, PPORDs (product and process oriented research and development notifications), Article 7(2) notifications, SCIP dossiers, and C&L notifications. REACH-IT requires legal entity accounts and has role-based access for manufacturers, importers, Only Representatives, and third parties.

Five-year retention for DecaBDE and PIP (3:1) records (increased from three years by 2024 revision). Three-year retention for 2,4,6-TTBP. Records include business documents, exposure monitoring, downstream notifications, and exclusion documentation. Must be available to EPA upon request.

Under the TSCA Section 8(a)(7) PFAS Reporting Rule, manufacturers (including importers) must retain records supporting their PFAS data submissions. Records include raw data, calculations, estimates, supplier communications, analytical test results, and any documentation used to prepare reports. Records must be retained for at least five years from the date of submission and be made available to EPA upon request.

A tailored safe harbour warning for recreational marine vessel parts is a new warning format added by OEHHA’s December 2024 amendments (effective January 1, 2025), codified at Title 27 CCR §25607.51. This applies to exposures during the purchase, handling, or installation of parts for recreational marine vessels (boats and other pleasure crafts not used for commercial purposes). The required warning text is: ‘WARNING: Handling recreational marine vessel parts can expose you to chemicals such as phthalates and lead, which can cause cancer and reproductive harm. To minimize exposure, service the vessel outdoors or in a well-ventilated area, wear gloves, and wash your hands. For more information go to www.P65Warnings.ca.gov/marine-vessel-parts.’

Under Dodd-Frank Section 1502 and SEC Rule 13p-1, conflict minerals from recycled or scrap materials are exempt from the requirement to conduct supply chain due diligence beyond reasonable inquiry. ‘Recycled minerals’ are reclaimed end-user or post-consumer products, or scrap processed metals created during product manufacturing. If a company’s RCOI determines that all conflict minerals in its products come from recycled or scrap sources, it can state this in its Form SD without filing a Conflict Minerals Report.

Directive (EU) 2024/232 addresses the use of recycled PVC (polyvinyl chloride) containing lead and/or cadmium in EEE. Historically, recycled PVC may contain residual lead or cadmium from legacy stabilisers, presenting challenges for circular economy practices under RoHS. Directive (EU) 2024/232 allows continued use of recycled PVC containing lead or cadmium in specific EEE applications (primarily window and door profiles and structural applications in smart home/building automation EEE) under stricter conditions than the original exemptions, to support the circular economy while maintaining environmental protection. Specific quantity limits, material tracking, and supply chain transparency requirements apply.

DecaBDE in pre-existing plastics in the waste stream can be recycled under this exclusion, but facilities must implement regulated areas, signage, and PPE. Does not apply to new DecaBDE manufacturing.

Reformulation is the process of changing a product’s composition to eliminate or reduce listed chemicals below Proposition 65 safe harbour thresholds, eliminating the need for a warning. Reformulation is one of two primary compliance strategies under Proposition 65 (the other being implementing a compliant warning). Successful reformulation requires: identification of the listed chemical(s) in the product; identification of suitable chemical substitutes that do not trigger other Proposition 65 listing or other regulatory obligations; testing to confirm that the reformulated product does not contain the listed chemical above safe harbour levels; and supply chain implementation to ensure reformulated materials are used consistently.

Registration is the core REACH obligation under Articles 6–10: any EU manufacturer or importer of a substance (on its own, in a mixture, or for certain uses in articles) above 1 tonne per year must register the substance with ECHA before placing it on the EU market. Registration requires submission of a technical dossier (and a Chemical Safety Report for hazardous or PBT/vPvB substances above 10 t/year) via IUCLID and REACH-IT. Substances are registered on a per-substance, per-registrant basis within a joint submission framework (SIEF).

A registration dossier is the technical package submitted by a manufacturer or importer to ECHA as the basis for REACH substance registration. The dossier contains: a technical dossier with administrative data, physico-chemical properties, toxicological and ecotoxicological data, classification and labelling, guidance on safe use, and study summaries or robust study summaries; and (for substances above 10 t/year that are hazardous or PBT/vPvB) a Chemical Safety Report. Registration dossiers are prepared in IUCLID format.

A designated zone where DecaBDE or PIP (3:1) is manufactured/processed. Owners must restrict entry to authorized persons with PPE, post multilingual signage at every entry, and maintain records.

PFAS remediation refers to the treatment and cleanup of PFAS-contaminated soil, groundwater, surface water, and other environmental media. Unlike conventional contaminants, PFAS are extremely difficult and expensive to remediate due to their chemical stability. Common remediation technologies include granular activated carbon (GAC) adsorption, ion exchange, high-pressure membranes (reverse osmosis/nanofiltration), and emerging destruction technologies such as supercritical water oxidation and electrochemical treatment. Remediation can also involve soil excavation and containment or in-situ stabilization.

The 2024 revision (40 CFR § 751.401) excludes processing/distribution of articles for repair or maintenance where the PBT chemical has not been newly added. Applies to all five PBT chemicals.

Requester Product Number and Requester Product Name are two new fields added to the Product List tab of CMRT version 6.6 (released April 17, 2026). These fields allow the requesting company (typically a manufacturer or OEM) to pre-populate their own internal product identifiers directly within the template before sending it to suppliers. This enables suppliers to complete the CMRT with the requester’s product reference already embedded, facilitating more accurate matching of supplier declarations to specific products in the requester’s internal systems.

The R&D exemption, proposed in EPA’s November 2025 revision to TSCA 8(a)(7), would exempt PFAS manufactured in small quantities solely for research and development purposes from reporting obligations. This recognizes that R&D-scale PFAS production is typically exploratory and involves minimal quantities.

A restriction under REACH Title VIII (Articles 67–73) is a legally binding condition or prohibition on the manufacture, placing on the market, or use of a substance — on its own, in a mixture, or in an article — where an unacceptable risk to human health or the environment has been identified that requires EU-wide action. Restrictions are listed in Annex XVII. As of 19 June 2025, Annex XVII contains 77 entries. Restrictions may impose concentration limits, use prohibitions, labelling requirements, or emission standards.

A retail seller under Proposition 65 regulations is a business that sells consumer products directly to end-use consumers in California. Under Title 27 CCR §25600.2(c), a retail seller is generally responsible for ensuring that required Proposition 65 warnings are transmitted to customers. Retail sellers may comply by: (1) affixing a Proposition 65 warning to the product; (2) posting point-of-sale notices; (3) using shelf tags; or (4) by relying on a manufacturer’s warning system under certain conditions. For online retail, the warning must appear on the product page before purchase. Retailers may be held independently liable for Proposition 65 violations if they sell products that require warnings but lack them.

Risk assessment in conflict minerals due diligence refers to the systematic process of identifying and evaluating whether the supply chain is contributing to or at risk of contributing to armed conflict, human rights abuses, money laundering, or other OECD Annex II risks. Risk assessment is Step 2 of the OECD five-step framework. It involves evaluating smelter-level data (country of origin, RMAP status), supplier-level data (CMRT responses, response rates), and geographic-level data (CAHRA proximity) to prioritize risk mitigation efforts.

The Responsible Minerals Assurance Process (RMAP) is the third-party audit program operated by RMI to verify that smelters and refiners of tin, tantalum, tungsten, and gold have systems in place to ensure responsible sourcing from conflict-affected and high-risk areas. RMAP audits assess whether smelters can demonstrate that their mineral inputs do not finance armed groups. Smelters that pass an RMAP audit are classified as ‘conformant.’ On October 16, 2025, the European Commission formally recognized RMAP as equivalent to EU Conflict Minerals Regulation (EU) 2017/821 requirements via Implementing Decision (EU) 2025/2071.

The Responsible Minerals Initiative (RMI) is an initiative of the Responsible Business Alliance (RBA) that provides companies with tools, resources, and audit programs to support responsible mineral sourcing from conflict-affected and high-risk areas. RMI owns and maintains the CMRT, EMRT, and AMRT reporting templates, operates the Responsible Minerals Assurance Process (RMAP) audit program, and maintains the smelter conformant/active/eligible facility lists. RMI was formerly known as the Conflict Free Sourcing Initiative (CFSI).

RoHS 2 refers to Directive 2011/65/EU of the European Parliament and of the Council on the restriction of the use of certain hazardous substances in electrical and electronic equipment, adopted June 8, 2011 and effective from January 2, 2013. RoHS 2 recast and replaced RoHS 1, introducing: expanded product scope (open scope covering all EEE by July 2019); CE marking and Declaration of Conformity requirements; responsibilities for manufacturers, importers, distributors, and authorised representatives; technical documentation requirements; and a pathway for adding new restricted substances (Article 6). Four phthalates were added via Directive 2015/863/EU. Directive (EU) 2025/2456 (December 12, 2025) transferred scientific and technical tasks to ECHA.

RoHS 3 is the informal designation for Directive (EU) 2015/863, which amended Annex II of Directive 2011/65/EU (RoHS 2) to add four phthalate plasticisers to the list of restricted substances: DEHP, BBP, DBP, and DIBP. These substances were added following their identification as substances of very high concern (SVHC) under REACH and their subsequent restriction under Annex XVII of REACH. The four phthalates apply at a maximum concentration value of 0.1% (1000 ppm) per homogeneous material from July 22, 2019 for most EEE categories (July 22, 2021 for medical devices and monitoring/control instruments).

'RoHS 4' is an informal industry term referring to potential future amendments to Directive 2011/65/EU that may add new restricted substances or further revise the regulatory framework. No formal legislative proposal for ‘RoHS 4’ has been adopted as of April 2026. Substances under consideration for potential future restriction include: Tetrabromobisphenol A (TBBPA), a flame retardant, and Medium Chain Chlorinated Paraffins (MCCPs). These are under review as part of the EU Chemicals Strategy for Sustainability. The transfer of tasks to ECHA (Directive (EU) 2025/2456, December 2025) streamlines the pathway for future substance additions to Annex II.

The scope of EU RoHS Directive 2011/65/EU is defined in Article 2. It applies to EEE falling within the categories of Annex I, cables and spare parts for repair and reuse, and accessories. The open scope (since July 22, 2019) covers all EEE not explicitly excluded. Article 2(4) excludes specific items from RoHS scope, including: equipment for military and security purposes; space equipment; large-scale stationary industrial tools; large-scale fixed installations; means of transport for persons or goods (excluding electric two-wheel vehicles); non-road mobile machinery for professional use; active implantable medical devices; photovoltaic panels; equipment for research and development only.

A safe harbour level is the exposure threshold below which a Proposition 65 warning is not required. OEHHA establishes two types of safe harbour levels: the No Significant Risk Level (NSRL) for carcinogens — set at the exposure causing no more than one excess cancer case in 100,000 individuals over a 70-year lifetime; and the Maximum Allowable Dose Level (MADL) for reproductive toxicants — set at 1/1,000 of the level showing no observable reproductive effect. Safe harbour levels are optional — businesses may use their own risk assessments instead — but if a product’s exposure is below the safe harbour level, the business is exempt from the warning requirement for that chemical. As of April 2026, OEHHA has established specific NSRLs and MADLs for approximately 300 of the 900+ listed chemicals.

A safe harbour warning is a specific warning format defined in OEHHA’s Title 27 CCR regulations that, when used exactly as specified, provides a legal presumption that the warning meets the ‘clear and reasonable’ standard required by Proposition 65. Using a safe harbour warning eliminates the need to individually demonstrate that the warning method and content are adequate. OEHHA provides safe harbour warnings for: consumer products (long-form and new short-form with chemical name, effective January 1, 2025); food products; environmental exposures; occupational exposures; motor vehicle parts (new, effective January 1, 2025); recreational marine vessel parts (new, effective January 1, 2025); and other categories.

A Safe Use Determination (SUD) is a written statement issued by OEHHA, upon request from a business or trade group, that interprets and applies Proposition 65 regulations to specific facts submitted by the requestor. A SUD provides a formal OEHHA determination of whether a specific product, use, or exposure scenario complies with Proposition 65 or requires a warning. Unlike interpretive guidelines, a SUD can be relied upon as an affirmative defence in subsequent Proposition 65 enforcement actions — a business acting in good faith in accordance with an SUD is not subject to civil penalties for the conduct described in the SUD.

A Safety Data Sheet (SDS) is a standardised document providing information about a substance or mixture’s properties, hazards, safe handling, and emergency measures. Under REACH Article 31, SDS must be provided to professional recipients of classified substances and mixtures, substances that are PBT/vPvB, or Candidate List SVHCs. SDS must conform to the format in Regulation (EU) 2015/830 (replacing Regulation (EC) No 453/2010), covering 16 mandatory sections. SDS must be updated when new hazard information becomes available or when a substance is added to the Candidate List.

Primary vehicle for downstream notification under TSCA PBT for PIP (3:1) and DecaBDE. Companies must include EPA-mandated language. SDS transition window: February 2025 – May 2026.

The SASB (Sustainability Accounting Standards Board) Standards are sector-specific sustainability accounting standards developed to help companies disclose financially material ESG information to investors. SASB Standards cover 77 industry-specific sectors and provide standardised metrics for each. The ISSB incorporated the SASB Standards into IFRS S2 as industry-specific disclosure requirements. Following the merger of SASB into the IFRS Foundation in 2022, the ISSB now maintains and develops SASB Standards. SASB is closely aligned with financial materiality and investment decision-relevant metrics.

Saudi Arabia’s RoHS-equivalent regulation is managed by the Saudi Standards, Metrology and Quality Organization (SASO). Products placed on the Saudi market may be subject to SASO’s technical regulations restricting hazardous substances in EEE, broadly aligned with EU RoHS. Products covered by SASO’s mandatory product conformity programme (SALEEM programme) — which includes many EEE categories — must obtain SASO conformity certificates. SASO’s technical regulations for EEE substance restrictions align with the six original RoHS substances (Pb, Hg, Cd, Cr⁶⁺, PBBs, PBDEs) and applicable EU/IEC standards.

Science-based targets are GHG emission reduction targets aligned with the latest climate science, specifically what is needed to limit global warming to 1.5°C above pre-industrial levels, consistent with the Paris Agreement. The Science Based Targets initiative (SBTi) validates corporate targets against its criteria. Companies can set: near-term targets (covering 5–10 years, minimum 42% absolute Scope 1 and 2 reduction by 2030 from a base year); and long-term targets (net-zero by 2050 or earlier, with 90–95% absolute reduction). SBTi issued updates to the Corporate Net Zero Standard in 2025 and separately developed FLAG (Forests, Land, and Agriculture) targets for land-sector emissions.

The SCIP database (Substances of Concern In articles as such or in complex objects/Products) is maintained by ECHA under Article 9 of the EU Waste Framework Directive (2008/98/EC, as amended). EU-based suppliers of articles containing Candidate List SVHCs above 0.1% w/w must notify ECHA via the SCIP database before placing those articles on the EU market, effective from 5 January 2021. The SCIP notification must include: article identification, SVHC identity and concentration, and safe use information. SCIP data is publicly available to enable waste operators to identify SVHC-containing waste streams.

Scope 1 emissions are direct GHG emissions from sources owned or controlled by a company — including: stationary combustion (boilers, furnaces, turbines); mobile combustion (company vehicles, ships, aircraft); process emissions (chemical or biological reactions); and fugitive emissions (refrigerants, leaks from equipment). Scope 1 emissions must be disclosed under all major reporting frameworks: IFRS S2 (mandatory), ESRS E1 (mandatory), California SB 253 (mandatory for companies with >$1B revenue doing business in California). Emissions are measured and reported in tonnes of CO₂ equivalent (CO₂e) using GHG Protocol methodology.

Scope 2 emissions are indirect GHG emissions from the generation of purchased or acquired electricity, steam, heat, or cooling that is consumed by a company but produced outside its direct control. The GHG Protocol Scope 2 Guidance (2015) requires companies to report Scope 2 using two methods: Location-based (using average electricity grid emission factors); and Market-based (using contractual instruments such as Energy Attribute Certificates (EACs), PPAs, or supplier-specific emission rates). Both methods must be disclosed where there is a significant difference. The GHG Protocol’s draft update (public consultation 2025) proposes hourly matching requirements for market-based claims.

Scope 3 emissions are all indirect GHG emissions that occur in a company’s value chain, excluding Scope 1 and 2 emissions. The GHG Protocol Corporate Value Chain (Scope 3) Standard (2011, under revision) categorises Scope 3 into 15 categories: upstream (Categories 1–8: purchased goods and services, capital goods, fuel and energy activities, upstream transportation, waste, business travel, employee commuting, upstream leased assets) and downstream (Categories 9–15: downstream transportation, processing of sold products, use of sold products, end-of-life treatment, downstream leased assets, franchises, investments). Scope 3 is mandatory under IFRS S2, California SB 253, and ESRS E1.

SEAC is ECHA’s Socio-Economic Analysis Committee, which prepares opinions on the socio-economic aspects of proposed restrictions and authorisations under REACH. SEAC evaluates the costs and benefits of proposed regulatory actions, including impacts on industry, consumers, and society. SEAC opinions are based on the socio-economic analysis submitted in authorisation applications or restriction dossiers, supplemented by third-party comments during public consultations. SEAC and RAC opinions together feed into the European Commission’s final decision.

The U.S. Securities and Exchange Commission (SEC) is the federal regulatory body that administers and enforces the conflict minerals disclosure requirements under Dodd-Frank Section 1502 through Rule 13p-1 and Form SD. The SEC adopted the final Conflict Minerals Rule on August 22, 2012, with reporting beginning for the 2013 calendar year. Form SD filings are submitted to the SEC’s EDGAR system by May 31 annually. In 2025, SEC Commissioner Mark Uyeda publicly questioned the effectiveness and cost burden of the rule, signaling potential policy debate, though the rule remains in force as of April 2026.

The Sustainable Finance Disclosure Regulation (SFDR) (Regulation (EU) 2019/2088) requires financial market participants (fund managers, insurance-based investment products) and financial advisers to disclose how they integrate sustainability risks into their investment decisions and how their products impact sustainability. SFDR classifies financial products as: Article 6 (no sustainability objective, just risk disclosure); Article 8 (environmental or social promotion); Article 9 (sustainable investment objective). SFDR also requires disclosure of Principal Adverse Impacts (PAIs) on sustainability factors at entity and product level. The Commission proposed targeted amendments to SFDR in 2024 as part of broader sustainability simplification.

A short-form warning is an abbreviated Proposition 65 safe harbour warning format originally intended for small product packaging. OEHHA’s December 2024 amendments (finalized December 6, 2024, effective January 1, 2025) significantly updated the short-form warning requirements under Title 27 CCR §25603(d) and §25607.2. Key changes: (1) the short-form warning must now include the name of at least one listed chemical for each health risk endpoint (cancer and/or reproductive toxicity); (2) the warning can now be any size packaging (the previous small-package restriction has been removed); (3) the warning must use a 6-point font minimum and the Prop 65 warning symbol; (4) alternative signal words ‘CA WARNING’ or ‘CALIFORNIA WARNING’ are now permitted. A three-year transition period runs until January 1, 2028; products manufactured before that date with prior short-form warnings may continue to be sold.

A Substance Information Exchange Forum (SIEF) is the mandatory collaboration platform under REACH Article 29 for registrants of the same substance to share data and costs for joint registration. SIEFs are formed after pre-registration and bring together all manufacturers and importers of the same substance to: share existing data; agree on classification and labelling; prepare a joint technical dossier submitted by the lead registrant; and negotiate data compensation agreements. Joint submissions are mandatory under REACH except in limited circumstances.

Signs at every entry to regulated areas: chemical name, CAS number, EPA PBT identification, PPE requirements. Must be prominent, in multiple languages, easily readable. DecaBDE recycling area signage effective January 21, 2025.

A signal word is the bold, capitalised word that introduces a Proposition 65 warning. Under Title 27 CCR safe harbour warning regulations, the required signal word is ‘WARNING:’ The December 2024 amendments (effective January 1, 2025) added two alternative signal words that may also be used: ‘CA WARNING:’ and ‘CALIFORNIA WARNING:’ The addition of these alternatives allows businesses to indicate more clearly that the warning is specific to California law, which may help consumers and customers understand why a California-specific warning appears. The signal word must appear in all capital letters and bold print, and must be preceded by the Proposition 65 warning symbol.

A 60-Day Notice of Violation is the formal notice that a private enforcer must provide before filing a Proposition 65 enforcement action in court. Under Health & Safety Code §25249.7(d), the notice must: (1) be provided to the alleged violator, the California AG, and the applicable district or city attorney; (2) specify the alleged violation (what chemical, what product or exposure, what provision of law is violated); (3) include a Certificate of Merit; and (4) include factual information supporting the certificate of merit (provided to the AG). The 60-day period allows: government enforcers to initiate action (preempting the private suit); and the alleged violator to take corrective action, investigate the claim, and negotiate a resolution.

Proposition 65 applies only to businesses with 10 or more employees (Health & Safety Code §25249.11). Businesses with fewer than 10 employees are exempt from Proposition 65 warning requirements and the discharge prohibition. The number of employees is counted at the time of the alleged violation. For businesses near the 10-employee threshold, headcount includes full-time and part-time employees. Note: the small business exemption applies to the warning and discharge requirements but does not exempt small businesses from other California chemical regulations. Also, even exempt small businesses may face liability if their products are later resold by a covered business without compliant warnings.

Under TSCA, a small manufacturer is a company that meets the small business size standards defined by the Small Business Administration (SBA) for its NAICS code, typically based on employee count or annual revenue thresholds. Under TSCA 8(a)(7), small manufacturers reporting solely as PFAS article importers receive an extended reporting window: 12 months from the start of the submission period, versus 6 months for other manufacturers. The proposed revisions would potentially remove approximately 127,469 small businesses from reporting requirements through the imported article, byproduct, and de minimis exemptions.

A smelter or refiner is the facility that processes raw 3TG mineral ores into metal products. In conflict minerals supply chains, smelters and refiners are the ‘pinch point’ — the last stage where mineral origin can be verified before transformation makes individual source traceability impossible. The four mineral types have specific smelting processes: tin smelters process cassiterite ore, tantalum processors convert coltan into tantalum powder, tungsten smelters process wolframite/scheelite, and gold refiners process gold doré or scrap. RMAP audits are conducted at the smelter/refiner level.

The Social (S) dimension of ESG encompasses a company’s relationships with and impacts on its workforce, supply chain workers, customers, communities, and wider society. Under ESRS, social topics are covered across four standards: ESRS S1 (Own Workforce); ESRS S2 (Workers in the Value Chain); ESRS S3 (Affected Communities); and ESRS S4 (Consumers and End-Users). Social key performance indicators include: living wages, gender pay equity, lost-time injury rates, female leadership representation, modern slavery due diligence, supplier audit findings, and community investment. The CSDDD makes supply chain human rights due diligence legally mandatory for large companies.

A Socio-Economic Analysis (SEA) is a cost-benefit assessment required in REACH authorisation applications where the applicant argues that socio-economic benefits outweigh risks, or where adequate control cannot be demonstrated. The SEA must quantify the benefits of continued authorised use (economic and social value to applicants and downstream users) against the health and environmental costs of the risks. SEA methodology follows ECHA guidance and must include a scenario analysis of what would happen if authorisation is refused.

Lead-free soldering refers to the use of solder alloys that do not contain lead (Pb) above the RoHS Annex II maximum concentration value of 0.1% (1000 ppm). The transition from tin-lead (SnPb) solders to lead-free solders was one of the most significant manufacturing changes driven by RoHS 1 (2006). The most widely used lead-free solder alloys are SAC (tin-silver-copper) alloys, particularly SAC305 (96.5% Sn, 3% Ag, 0.5% Cu). Lead-free soldering requires higher process temperatures than SnPb soldering (melting point ~220°C for SAC305 vs. ~183°C for SnPb), which has implications for component heat tolerance and PCB design.

Stakeholder engagement is the ongoing process of identifying, mapping, prioritising, and meaningfully interacting with those affected by or with an interest in a company’s activities. Under ESRS 2 (General Disclosures), companies must disclose: their stakeholder engagement activities; how stakeholder input has informed the sustainability strategy and materiality assessment; and how they respond to stakeholder concerns. Under the CSDDD, companies must establish grievance mechanisms allowing workers, communities, and affected persons to raise concerns. GRI 2-29 and 2-30 require disclosures on stakeholder engagement approach.

The Standard Smelter List is the reference list embedded within each CMRT version that identifies smelters and refiners of 3TG minerals and their current RMAP audit status (conformant, active, or listed). It is maintained and updated by RMI with each CMRT release. The Standard Smelter List in CMRT 6.6 (released April 17, 2026) reflects the most current RMI-validated data. Suppliers completing CMRTs cross-reference their smelter entries against this list. Manufacturers use it to verify the RMAP status of identified smelters.

U.S. state-level PFAS laws are an increasingly complex patchwork of regulations that restrict, ban, or require disclosure of PFAS in various product categories. As of early 2026, over 15 states have enacted PFAS-specific legislation, with approaches ranging from product-specific bans to comprehensive all-product bans (Maine by 2030), reporting requirements (Minnesota by July 2026), labeling mandates (New Jersey from January 2028), and drinking water standards. Each state defines PFAS differently and uses different thresholds.

The Stockholm Convention on Persistent Organic Pollutants (POPs) is an international treaty that restricts or eliminates the production, use, import, and export of the world’s most dangerous chemicals. Several PFAS are listed: PFOS and its salts (Annex B, 2009), PFOA, its salts and PFOA-related compounds (Annex A, 2019), PFHxS, its salts and PFHxS-related compounds (Annex A, 2022), and long-chain perfluorocarboxylic acids C9–21 PFCAs, their salts and related compounds (Annex A, 2025, with a global ban from December 2026).

The Stop-the-Clock Directive (Directive (EU) 2025/794) is the EU directive that postponed by two years the application of CSRD reporting requirements for Wave 2 and Wave 3 companies. It entered into force on April 17, 2025. Wave 2 companies (large EU companies not qualifying as public interest entities, previously required to report for the 2025 financial year) are now required to report for the 2027 financial year at the earliest. Wave 3 (listed SMEs, non-EU large companies) were also delayed. Wave 1 companies (large public interest entities reporting from 2024 FY) were not affected. The directive also delayed the first phase of CSDDD requirements by one year.

Styrene is a synthetic chemical listed under Proposition 65 as a carcinogen (listed April 6, 2012). OEHHA has established a No Significant Risk Level (NSRL) for styrene of 27 micrograms per day. Styrene is used as a monomer in the production of polystyrene plastics, ABS plastic, rubber, and various resins. In the context of electronics and consumer products, styrene-containing plastics (polystyrene, ABS) are widely used for housings, packaging, and components. Food packaging using polystyrene may also trigger Proposition 65 concerns if styrene migrates into food above the NSRL.

The regulatory section containing all PBT provisions: § 751.401 (General), § 751.403 (Definitions), § 751.405 (DecaBDE), § 751.407 (PIP 3:1), § 751.409 (2,4,6-TTBP), § 751.411 (PCTP), § 751.413 (HCBD).

Under REACH Article 3(1), a substance is a chemical element and its compounds in the natural state or obtained by any manufacturing process, including any additive necessary to preserve its stability and any impurity deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition. Substances must be identified precisely for REACH purposes using agreed identifiers (molecular formula, SMILES, CAS number, EC number) and classified using Annex VI to the CLP Regulation.

Substance evaluation under REACH Article 44–48 is an in-depth assessment by a Member State Competent Authority (MSCA) to clarify whether a substance poses a risk to human health or the environment. Substances are selected for evaluation based on ECHA’s Community Rolling Action Plan (CoRAP). Following substance evaluation, the MSCA may request additional information from registrants or recommend follow-up regulatory action (restriction, authorisation, or harmonised classification).

Under REACH, a Substance of Very High Concern (SVHC) is a chemical meeting one or more criteria defined in Article 57: carcinogenic, mutagenic, or toxic to reproduction (CMR); persistent, bioaccumulative, and toxic (PBT); very persistent and very bioaccumulative (vPvB); or of equivalent concern. Several PFAS have been identified as SVHCs and added to the REACH Candidate List based on PBT/vPvB properties or equivalent concern. SVHC identification triggers supply chain communication, SCIP notification, and potential authorization requirements.

Substance restriction under RoHS refers to the prohibition of restricted hazardous substances in homogeneous materials above maximum concentration values (MCVs) per Annex II of Directive 2011/65/EU. Under Article 6, the Commission may amend Annex II to add new substances following a review and assessment of available evidence. Directive (EU) 2025/2456 (December 12, 2025) significantly changes the process: ECHA is now formally entrusted with preparing restriction dossiers; restriction proposals may be prepared by Member States or by ECHA on Commission request; and Annex II must be reviewed at least once every four years.

A supplier declaration (also called a material declaration or substance declaration) in the Proposition 65 context is a written statement from a component or material supplier confirming the chemical content of supplied materials relative to Proposition 65-listed substances. Unlike EU RoHS (which has standardised material declaration requirements under EN IEC 63000:2018), Proposition 65 has no standardised mandatory declaration format. However, supplier declarations are a critical component of a manufacturer’s Proposition 65 compliance programme, providing the primary evidence base for determining whether products contain listed chemicals at exposure-triggering concentrations.

A supplier declaration (also called a material declaration or substance declaration) is a written statement from a component or material supplier confirming the substance content of their supplied material or component relative to RoHS restricted substances. Under EN IEC 63000:2018, supplier declarations are the primary evidence mechanism for demonstrating RoHS compliance, particularly for substances in homogeneous materials that cannot be practically tested at the receiving manufacturer’s level. Declarations must specify: which substances are present; their concentration per homogeneous material; reference to the applicable standard; and the signatory’s name and date.

A written statement from a supplier confirming PBT chemical presence, absence, or concentration. No official TSCA format; operationally derived from 40 CFR Part 751 compliance needs. Should reference all five CAS numbers with applicable thresholds.

Supplier engagement in conflict minerals compliance refers to the proactive outreach and communication program by which companies collect CMRT data from their suppliers, address non-responses, and work with suppliers to improve smelter RMAP participation. Supplier engagement is both a data collection mechanism (CMRT request campaigns) and a risk mitigation tool (engaging suppliers whose smelters are non-conformant to encourage RMAP participation). Effective supplier engagement is a key element of OECD Step 3 (risk response) and Step 1 (management systems).

Supply chain data collection for PFAS refers to the systematic process of gathering PFAS presence, identity, concentration, and function data from upstream suppliers to satisfy regulatory reporting, restriction compliance, and product transparency requirements. This includes issuing PFAS-specific questionnaires, collecting material declarations, validating supplier responses against regulatory thresholds, and maintaining auditable records. Effective PFAS data collection covers all tiers of the supply chain, from raw material suppliers through contract manufacturers to finished product assemblers.

A supply chain policy for conflict minerals is a formal, publicly communicated statement of a company’s commitment to responsible mineral sourcing and its expectations of supply chain partners. It is required as Step 1 of the OECD five-step due diligence framework and is expected by the EU Conflict Minerals Regulation and Dodd-Frank. The policy should clearly state the company’s stance on conflict minerals, expectations for suppliers, and the consequences of non-compliance.

Supply chain transparency refers to the extent to which a company knows, discloses, and can demonstrate the origin, composition, social, and environmental conditions of its supply chain — from raw material extraction through all production tiers to final product delivery. Regulatory drivers for supply chain transparency include: CSDDD (human rights and environmental due diligence); CSRD/ESRS S2 (workers in the value chain); EU Deforestation Regulation (EUDR); EU Forced Labour Regulation; US Uyghur Forced Labor Prevention Act (UFLPA); and the EU Battery Regulation due diligence requirements.

Sustainability reporting assurance is the independent third-party verification that a company’s sustainability disclosures are free from material misstatement and prepared in accordance with the applicable reporting standards. Under the CSRD (EU) 2022/2464, mandatory limited assurance of sustainability statements is required from the first year of reporting; reasonable assurance (the higher standard) is expected to become required from 2028 onwards for EU reporters. The Omnibus I provisional agreement clarifies that limited assurance applies and sets maximum financial penalties for supervisory authorities at 3% of the company’s net worldwide turnover.

Sustainability-linked finance refers to financial instruments (loans, bonds, export credit) whose financial terms — typically the interest rate or coupon — are tied to the borrower’s performance against predefined sustainability KPIs and sustainability performance targets (SPTs). Unlike green bonds (where proceeds are restricted to specific green projects), sustainability-linked instruments impose no use-of-proceeds restrictions; instead, they incentivise overall sustainability performance improvement. Sustainability-Linked Loan Principles (SLLP) and Sustainability-Linked Bond Principles (SLBP) are published by LMA and ICMA respectively.

A Substance of Very High Concern (SVHC) is a substance meeting one or more criteria under REACH Article 57: CMR Category 1A or 1B; PBT or vPvB per Annex XIII; or other equivalent concern (e.g., endocrine disruptors, PMT/vPvM). SVHCs are identified by ECHA through the Annex XV dossier process and added to the Candidate List. As of February 4, 2026, the Candidate List contains 253 entries. Candidate List inclusion triggers Article 33, Article 7(2), and SCIP database obligations.

Taiwan RoHS is implemented through the Regulations for Restricted Use of Certain Hazardous Substances in Electrical and Electronic Equipment, aligned with CNS 15663 (Chinese National Standard). Administered by the Bureau of Standards, Metrology and Inspection (BSMI) and Ministry of Economic Affairs, it restricts the same six hazardous substances as EU RoHS 1 (Pb, Hg, Cd, Cr⁶⁺, PBBs, PBDEs) at equivalent concentration limits, in a broad range of EEE product categories. Taiwan RoHS requires a conformity mark on products and an accessible content declaration table on the product or its packaging, similar to China’s labeling approach.

The Toxic Chemical Substances Control Act (TCSCA), amended as the Toxic and Concerned Chemical Substances Control Act, is Taiwan’s national chemical management regulation, often referred to as Taiwan REACH. It governs the registration, evaluation, authorisation, and restriction of toxic and concerned chemical substances in Taiwan. Managed by the Taiwan Environmental Protection Administration (TEPA/EPA), TCSCA requires substance registration, SVHC-equivalent notifications, and imposes restrictions on listed substances. Taiwan maintains four classes of controlled substances, with Class 1 subject to prohibition and Class 4 requiring declaration.

Tantalum (Ta) is one of the four 3TG conflict minerals, primarily extracted from coltan ore (columbite-tantalite). Tantalum is used in capacitors found in smartphones, laptops, game consoles, and other electronics; in medical implants; and in aerospace applications. A significant portion of the world’s tantalum comes from the DRC and neighboring Rwanda and Burundi, making it a high-priority mineral for conflict minerals compliance. Tantalum refiners/processors are audited under RMAP for responsible sourcing practices.

The TCFD (Task Force on Climate-related Financial Disclosures) is the framework established in 2015 by the Financial Stability Board (FSB) for voluntary climate-related financial disclosure. The TCFD Recommendations (2017) organise disclosures under four pillars: Governance; Strategy (including scenario analysis); Risk Management; and Metrics and Targets. The TCFD framework was incorporated in full into IFRS S2 (ISSB, June 2023), making it the de facto global standard for climate-related financial disclosures. The FSB formally disbanded the TCFD in 2024, transferring monitoring to the IFRS Foundation, as ISSB has now taken over TCFD’s role.

Technical documentation under RoHS Directive 2011/65/EU is the body of evidence compiled by manufacturers to demonstrate product conformity with all applicable RoHS requirements. Under Article 8 and Annex VI, the technical documentation must include: a general description of the EEE; design and manufacturing drawings; list of harmonised standards applied; results of design calculations and inspections; test reports; a Declaration of Conformity; and, under EN IEC 63000:2018, supplier declarations, materials declarations, and risk assessment for restricted substances. Technical documentation must be kept for ten years from the date the product is placed on the market.

Tin (Sn) is one of the four 3TG conflict minerals, extracted from cassiterite ore. Tin is used primarily as a solder in electronics manufacturing (circuit boards, component assembly), in tin plating, and in alloys. Tin is the highest-volume 3TG mineral used in electronics. Significant sources of tin include the DRC, Indonesia, and Myanmar. The DRC is a notable conflict-risk source, particularly from eastern provinces. Tin smelters are audited under RMAP for responsible sourcing.

Tobacco smoke is identified as a source of Proposition 65-listed carcinogens and reproductive toxicants, including tobacco smoke (listed as a carcinogen October 1, 1988) and several specific tobacco smoke constituents (benzene, formaldehyde, vinyl chloride, cadmium, and others). Environmental tobacco smoke and ‘second-hand smoke’ are among the most common triggers for workplace, hotel, and building Proposition 65 exposure warnings. OEHHA has established specific safe harbour warnings for tobacco smoke-related exposures in the workplace and other environmental contexts.

In REACH, the tonnage band is the annual manufacture or import volume of a substance, expressed in tonnes, that determines the level of information required in the registration dossier. The four tonnage bands are: 1–10 t/year (basic data requirements, Annexes VI–VII); 10–100 t/year (extended data, Annex VIII); 100–1,000 t/year (further extended data, Annex IX); and >1,000 t/year (comprehensive data, Annex X). Higher tonnage bands require more toxicological and ecotoxicological testing and a Chemical Safety Report.

The third PBT criterion. A chemical is toxic when it causes adverse health effects: carcinogenicity, reproductive toxicity, developmental toxicity, endocrine disruption, neurotoxicity, or aquatic toxicity. All five TSCA PBT chemicals meet this criterion.

The Toxics Release Inventory (TRI) is a U.S. EPA program under the Emergency Planning and Community Right-to-Know Act (EPCRA) that requires certain facilities to report annual releases and transfers of toxic chemicals. PFAS were first added to the TRI in stages: the NDAA FY2020 added PFOA and PFOS; subsequent NDAA authorizations expanded the list. As of 2025, EPA tracks 205 PFAS under TRI. EPA is finalizing a rule (expected February 2026) to add additional individual PFAS and PFAS categories to TRI, along with criteria for automatic future additions.

Traceability in conflict minerals refers to the ability to identify and document the chain of custody of a mineral from its point of extraction (mine) through processing, smelting, and refinement to the point of use in a finished product. Complete traceability would allow a downstream manufacturer to verify that a specific batch of metal in its product came from a specific, identified, responsible mine. In practice, full traceability is rarely achievable for 3TG minerals due to mineral fungibility and supply chain complexity; smelter-level traceability is the practical standard.

A transition plan is a time-bound, company-specific strategy for achieving a significant transformation of a company’s business model and operations to align with a low-carbon economy, specifically the 1.5°C pathway of the Paris Agreement. Transition plans must include: current GHG emission levels and absolute reduction targets (Scope 1, 2, and 3); actions and investments to achieve targets; capital allocation plans; governance and risk management for climate-related risks; and interim milestones. Under IFRS S2, transition plan disclosure is a requirement. Under ESRS E1 (Climate Change), transition plan disclosures are required for CSRD-scoped companies. The Omnibus I provisional agreement specifies that CSRD transition plan reporting requirements remain unchanged.

The primary U.S. federal law governing chemical manufacture, processing, distribution, use, and disposal. Enacted 1976, amended by the Lautenberg Act 2016. Section 6(h) provides the expedited PBT pathway.

The statutory provision requiring expedited PBT action. Directs EPA to reduce exposure to the extent practicable without cost-benefit analysis. Created by the Lautenberg Act (2016). Legal authority for all five PBT chemical rules.

TSCA Section 8(a)(7) is a one-time, retrospective reporting requirement mandated by the NDAA FY2020 that requires any person who manufactured (including imported) PFAS or PFAS-containing articles in any year between 2011 and 2022 to report data to EPA. Reportable data includes PFAS identity, categories of use, volumes manufactured or imported, byproducts, environmental and health effects, worker exposure, and disposal methods. The final rule was published October 11, 2023. The submission period has been delayed multiple times; as of April 2026, EPA has moved the start date to January 31, 2027, or 60 days after the effective date of a forthcoming final revision rule, whichever is earlier.

EPA’s prioritized list of chemicals for evaluation, including potential PBT designations. The five PBT chemicals were selected from this list. Updated periodically; serves as an early indicator of future TSCA actions.

Tungsten (W) is one of the four 3TG conflict minerals, extracted primarily from wolframite and scheelite ores. Tungsten is used in electronics (vibration motors in mobile phones, hard drive components), cutting tools, light bulb filaments, military applications (ammunition), and jewelry. Significant sources include China (largest global producer), DRC, and Rwanda. Tungsten is one of the less-publicized 3TG minerals but remains subject to full conflict minerals due diligence requirements under both Dodd-Frank and EU Regulation (EU) 2017/821.

UK REACH is the retained version of EU REACH Regulation (EC) No 1907/2006, as it applied in Great Britain after Brexit under the European Union (Withdrawal) Act 2018. UK REACH is administered by HSE (Health and Safety Executive) as the UK’s REACH agency. UK REACH contains the same fundamental obligations as EU REACH (registration, SVHC communication, restrictions, authorisations), but operates independently of EU REACH. UK REACH has its own registration deadlines (extended transitional periods until 2026–2027), its own Candidate List and Annex XIV, and its own restriction processes.

UK RoHS refers to the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (SI 2012/3032) and its amendments, which implement RoHS requirements for Great Britain (England, Scotland, and Wales) following Brexit. UK RoHS is substantially equivalent to EU RoHS 2 (Directive 2011/65/EU), including the same ten restricted substances, MCVs, exemptions, CE marking equivalent (UKCA marking from January 2025 for most products), technical documentation, and DoC requirements. However, UK RoHS exemptions are updated separately from EU exemptions and may diverge over time. Northern Ireland is subject to EU RoHS under the Windsor Framework.

Ukraine has implemented RoHS-equivalent requirements through its Technical Regulation on Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment, adopted to align with EU RoHS as part of Ukraine’s EU Association Agreement obligations. The regulation restricts the same substances as EU RoHS 1 (Pb, Hg, Cd, Cr⁶⁺, PBBs, PBDEs) at equivalent concentration limits, with a product certification and conformity marking system (previously UkrSEPRO). Ukraine’s ongoing EU integration process under the Association Agreement is progressing towards further harmonisation with EU product regulations, including RoHS 2.

The UN Sustainable Development Goals (SDGs) are the 17 global goals adopted by all 193 UN Member States in 2015 as part of the 2030 Agenda for Sustainable Development. The SDGs address poverty, health, education, gender equality, clean energy, climate action, biodiversity, and justice. In ESG reporting, SDGs are used as an alignment framework to show how a company’s activities and ESG strategy contribute to global development goals. GRI Standards include SDG mapping. ESRS and IFRS S1/S2 do not mandate SDG alignment but many companies voluntarily map their material topics to relevant SDGs.

A Union importer under Regulation (EU) 2017/821 is any natural or legal person established in the EU who declares minerals or metals containing or consisting of tin, tantalum, tungsten, or gold for release for free circulation into the EU. Union importers above the volume thresholds specified in Annex I of the Regulation are subject to mandatory supply chain due diligence obligations. The regulation applies to importers of both raw minerals/ores and semi-processed or processed metals at specified Combined Nomenclature (CN) codes.

The universal PFAS restriction refers to the proposed EU-wide restriction under REACH Annex XVII that would ban or restrict the manufacture, placing on the market, and use of all per- and polyfluoroalkyl substances across all applications. Submitted by five national authorities (Denmark, Germany, Netherlands, Norway, Sweden) in January 2023, it is the broadest chemical restriction ever proposed under any regulatory framework globally. The proposal covers an estimated 10,000+ substances under the OECD definition and has identified 231 sectors where PFAS are used. ECHA’s RAC adopted its final opinion on March 2, 2026, confirming PFAS warrant group-wide restriction. SEAC agreed its draft opinion on March 11, 2026, with a 60-day public consultation closing May 25, 2026.

A value chain encompasses all activities, resources, people, organisations, and processes involved in creating and delivering a product or service — from raw material extraction through production, distribution, use, and end-of-life. In ESG reporting, value chain is a key concept: under ESRS 1, material impacts, risks, and opportunities must be assessed across the company’s upstream value chain (suppliers, raw materials), own operations, and downstream value chain (distributors, customers, end users). Value chain Scope 3 GHG emissions (Categories 1–15) represent the emissions associated with all value chain activities beyond the company’s direct control.

Vinyl acetate is a chemical used as a monomer in the production of polyvinyl acetate (PVA) adhesives, polyvinyl alcohol, and ethylene-vinyl acetate (EVA) copolymers — materials widely used in adhesives, paints, paper coatings, and foam for footwear and sports equipment. Vinyl acetate was listed as a Proposition 65 carcinogen effective January 3, 2025, under the State’s Qualified Experts mechanism following a Carcinogen Identification Committee determination. As of April 2026, OEHHA has not yet established a specific No Significant Risk Level (NSRL) for vinyl acetate; in the interim, businesses must use OEHHA’s quantitative risk assessment methodology to determine whether their specific exposures create a ‘significant risk’ requiring a warning.

Volume thresholds under Regulation (EU) 2017/821 are the minimum annual import volumes of 3TG minerals or metals below which Union importers are exempt from mandatory due diligence obligations. Thresholds are set in Annex I at a level that ensures at least 95% of total import volumes for each mineral and metal under its Combined Nomenclature (CN) code is covered. For example: tin ores and concentrates threshold is 6,000 kg/year; for gold in unwrought form the threshold is 100 kg/year. Thresholds vary by CN code and mineral type.

A vPvB (very Persistent, very Bioaccumulative) substance meets the more stringent persistence and bioaccumulation criteria in REACH Annex XIII: persistence (degradation half-life >60 days in marine water or >180 days in marine sediment) and bioaccumulation (BCF >5,000). vPvB substances qualify as SVHCs under REACH Article 57(e) and are prioritised for Candidate List inclusion and potential Annex XIV listing. Like PBT substances, no safe level (DNEL/PNEC) can be derived for vPvB substances.

A Proposition 65 warning is the required notice that a business must provide to individuals before knowingly exposing them to a chemical listed as causing cancer or reproductive harm, when exposure exceeds the applicable safe harbour level (NSRL or MADL). The warning must be ‘clear and reasonable’ as defined in Health & Safety Code §25249.6 and Title 27 CCR §25600 et seq. Proposition 65 warnings may be provided through: product labels; shelf tags or signs at point of sale; on-site signage; catalog or internet website warnings; or direct notification (for workplaces and rental housing). OEHHA’s safe harbour warning regulations provide specific content, format, and transmission requirements that create a presumption of compliance.

The Proposition 65 warning symbol is the pictogram required in Proposition 65 safe harbour warnings: a black exclamation point in a yellow equilateral triangle with a black outline. This symbol is mandated by Title 27 CCR §25603 and must be included in all consumer product long-form and short-form safe harbour warnings, as well as in the new motor vehicle parts and recreational marine vessel parts tailored warnings (effective January 1, 2025). The symbol must be displayed at a size no smaller than the signal word and must be placed conspicuously on the product, label, or packaging. Digital uses of the symbol (websites, e-commerce) must also comply with conspicuousness requirements.

The EU Waste Framework Directive (Directive 2008/98/EC, as amended by Directive (EU) 2018/851) intersects with REACH through the SCIP database obligation. Article 9 of the WFD requires EU-based suppliers of articles containing Candidate List SVHCs above 0.1% w/w to notify ECHA’s SCIP database before placing those articles on the EU market. SCIP data is made publicly available by ECHA to support safe waste management and material recovery of SVHC-containing waste streams.

Wastewater and biosolids are critical pathways for PFAS entering the environment. Conventional wastewater treatment plants (WWTPs) do not remove or destroy PFAS—they pass through treatment processes and are discharged in effluent or concentrated in biosolids (sewage sludge). When biosolids are applied to agricultural land as fertilizer, PFAS can contaminate soil and groundwater. EPA is developing regulatory approaches for PFAS in biosolids under the Clean Water Act and has completed draft risk assessments for PFOA and PFOS in biosolids.

The 2024 revision prohibits releasing DecaBDE to water during manufacturing, processing, and distribution. Addresses aquatic contamination from persistent DecaBDE in sediments. Applies independently of Clean Water Act.

Wave reporting refers to the phased implementation schedule of the EU CSRD (Directive (EU) 2022/2464), under which different categories of companies are required to begin CSRD sustainability reporting at different times. Following the Stop-the-Clock Directive (Directive (EU) 2025/794, in force April 17, 2025) and Omnibus I: Wave 1 (large public interest entities >500 employees): 2024 FY reporting (reports published 2025) — unchanged. Wave 2 (large EU companies not qualifying as PIEs): delayed from 2025 FY to 2027 FY at earliest. Wave 3 (listed SMEs): removed from mandatory CSRD scope under Omnibus I’s proposed revised thresholds (>1,000 employees / €450M turnover).

Extended compliance deadline for DecaBDE wire and cable insulation in nuclear power facilities. Requires export notification for DecaBDE cable shipped to foreign nuclear facilities.

Comprehensive worker protection for DecaBDE and PIP (3:1) facilities: regulated areas, restricted access, multilingual signage, NIOSH respiratory PPE, exposure monitoring, five-year records. Effective January 21, 2025 for most. Independent of OSHA.

A workplace warning is a Proposition 65 safe harbour warning provided to employees who may be exposed to listed chemicals in their work environment. Under Title 27 CCR §§25606–25606.7, employers must provide Proposition 65 warnings for workplace exposures to listed chemicals above safe harbour levels. Workplace warnings may be provided through: employee notification (written notice, collective bargaining agreement, or training); posting of signs in the exposure area; including warning information in safety data sheets (SDS); or labelling of containers or equipment. Workplace warnings are distinct from consumer product warnings.

X-ray fluorescence (XRF) is an analytical technique used for non-destructive screening of elemental content in materials. Under IEC 62321-3-1 (portable XRF) and IEC 62321-3-2 (laboratory XRF), XRF is the primary screening method for detecting lead (Pb), mercury (Hg), cadmium (Cd), total chromium (Cr — cannot distinguish hexavalent from trivalent), and total bromine (Br — cannot distinguish PBBs from PBDEs or other brominated compounds) in EEE components and materials. XRF is rapid, non-destructive, and cost-effective, making it the first-pass compliance screening tool across supply chains. It cannot detect phthalates (organic compounds) or hexavalent chromium specifically.

2,4,6-TTBP (CAS 732-26-3) is an antioxidant in fuel additives and oil/lubricant products. After January 6, 2026: distribution above 0.3% in containers under 35 gallons is prohibited; processing/distribution of oil/lubricant additives above 0.3% is prohibited. Distributors must keep 3-year records.

3TG is the collective abbreviation for the four minerals designated as conflict minerals under U.S. Dodd-Frank Section 1502 and EU Regulation (EU) 2017/821: Tin, Tantalum, Tungsten, and Gold. These four minerals and their ores (cassiterite for tin, coltan for tantalum, wolframite/scheelite for tungsten, gold doré for gold) are the scope of all conflict minerals reporting obligations under the CMRT, Form SD, and EU Regulation.

The CFR section codifying TSCA Section 6 chemical regulations. Subpart E contains all PBT provisions: § 751.401 (General), § 751.403 (Definitions), § 751.405 (DecaBDE), § 751.407 (PIP 3:1), § 751.409 (2,4,6-TTBP), § 751.411 (PCTP), § 751.413 (HCBD).