Original question as formulated in the survey: Do EICC member companies require full materials disclosure from their suppliers of all the chemicals used in production?

EICC self-score: Chemical Challenge Gap Analysis - Yellow (Small gap)

EICC justifies this score by referring to the VAP Protocol section C3.1. This section mentions that hazardous substances, including wastes, are properly categorised, labelled, handled, stored, transported and disposed using government-approved and/or licensed vendors as per local laws.

GoodElectronics and ICRT score: Chemical Challenge Gap Analysis - Red (Large gap)

What GoodElectronics and ICRT are driving at is the principle of Full Materials Disclosure (FMD). The whole point of FMD is that many hazardous chemicals are used in electronics production processes, but they are often not, or not yet, officially listed as hazardous chemicals. GoodElectronics and ICRT want to know whether EICC member companies are asking their suppliers for the full inventory of chemicals they use.

The VAP Protocol C3.1 does require that supplier factories keep an inventory of known hazards, but it does not give any guidance or definition of what this inventory must include. What is more, suppliers are not required to disclose this information to their clients (brands) much less to the public.

Regularly updated disclosure is essential. This approach has been developed in Silicon Valley in the US since the early 1980s and the US Toxics Release Inventory has required annual disclosure since the late 1980s.

Further reading

‘Meeting the Challenge’ on Transparency


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