IPC – Association Connecting Electronics Industries® appreciates the opportunity to comment
on Canada’s proposed elimination of Resin acids and Rosin acids, hydrogenated, esters with
pentaerythritol (CAS# 64365-17-9); Rosin, hydrogenated (CAS# 65997-06-0); Resin acids and
Rosin acids, hydrogenated, esters with glycerol (CAS# 65997-13-9); Resin acids and Rosin
acids, hydrogenated, esters with triethylene glycol (CAS # 68648-53-3); and Resin acids and
Rosin acids, fumarated, barium salts (CAS# 124751-15-1) under the Chemicals Management
Program.

 IPC is concerned with all five aforementioned substances and therefore will refer to all
substances collectively as Rosin throughout the following comments.

IPC is gravely concerned with the Canadian Government’s recommendation to ban these five substances from any
products manufactured or sold in Canada. In addition to IPC’s one hundred and twenty-three
member companies manufacturing electronics in Canada, many of our members import a variety
of electronic products into Canada. This ban would impact all electronic products as well as
any product which includes electronics and would make it difficult for electronics
manufacturing to continue in Canada.


http://www.ipc.org/3.0_Industry/3.4_EHS/Comments-on-Rosin-2.pdf