If you increase the cost to replace a debit card - is this a fee that triggers a 30 day disclosure?

with the new EMV cards and their costs this is a change we are needing to consider

Take a look at 12 CFR 1005.8. I think your situation falls under the subsequent disclosures requirements of 1005.8: If a bank is changing terms it must mail or deliver a written or electronic notice to the consumer 21 days before the effective date of any change that would result in increased fees for the consumer.