Electronics

Beveridge & Diamond, P.C. has worked extensively with clients in the electronics industry on existing and proposed environmental requirements affecting company operations, supply chains and products. Our current clients include major trade associations as well as original equipment manufacturers, semiconductor manufacturers and other electrical and electronic component and equipment manufacturers.

We have counseled clients in the industry on a wide range of strategic and compliance issues related to environmental, health and safety matters arising under U.S. federal and state law, as well as the laws of other countries. Our work includes advising clients on product design, market access, material restrictions (e.g., RoHS requirements), and expanding energy efficiency mandates. We also counsel clients on the full spectrum of chemical notification, registration and labeling requirements. We have helped clients develop successful product take-back and recycling programs in the U.S., Europe and Latin America. 

We have represented the U.S. electronics industry on international environmental product stewardship matters arising under the Basel Convention and related Organization for Economic Cooperation and Development (OECD) Council decisions governing the transboundary movement of wastes, including end-of-life electronic equipment. Some of our recent experience counseling the electronics industry includes:

Regulatory Tracking. The Firm supports the leading web-based regulatory tracking tool for the electronics industry - EIATRACK ( www.eiatrack.com ). EIATRACK identifies and tracks existing and proposed product-related environmental requirements impacting the design, marketing, and end-of-life management of electronic products in the U.S. and in key markets world-wide.

Chemical Bans and Restrictions. The Firm has advised companies on a wide range of RoHS and material ban legislation in the U.S., Europe and Latin America, including efforts to ban PFOS under various international agreements.

Product Take-Back Legislation. The Firm routinely tracks and advises a number of U.S. and foreign clients on product take-back and recycling initiatives in the U.S., Europe, Asia, and Latin America. This has included the preparation of detailed analysis and practical advice on existing national electronic take-back and recycling measures.

Chemical Notification and Regulation. Our work has included the preparation of detailed chemical import and export audit protocols, assessments of existing and planned initiatives aimed at developing new chemical inventory and notification schemes, and restrictions on the production or use of certain toxic chemicals and heavy metals.

U.S. Chemical Regulation. We have a broad and active Toxic Substances Control Act (TSCA) practice and advise clients on all aspects of U.S. chemical regulation. We have advised and represented clients in connection with chemical bans under U.S. federal and state regulatory programs. We routinely advise clients on compliance matters arising under Prop-65.

Electronic Scrap Recycling. The Firm has advised clients on all aspects of electronic equipment collection, transport and recycling. We have also defended clients in enforcement actions brought by EPA regarding the proper management of used electrical and electronic equipment.

Hazardous Materials Transport.  The Firm tracks and analyzes federal and state developments related to DOT hazardous materials transport and EPA's “universal waste rule,” which reduces the otherwise applicable regulatory requirements for handlers and transporters of certain ubiquitous hazardous wastes (e.g., CRTs, batteries, thermostats, and lamps) under RCRA and its state counterparts.   

E-Waste Imports and Exports. The Firm has advised clients on a wide range of issues related to the proposed import and export of used and end-of-life electronic equipment, components and consumables for recycling. This work has included advice on the requirements of RCRA and its state counterparts, the Basel Convention and related U.S. bilateral agreements.

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