European WEEE and RoHS Directives Update ¡¦July 2005

Within all EU member state countries, forthcoming legislation will control the manufacture, and disposal of electrical or electronic equipment sold within the community countries.

The following information is based primarily on the situation within the United Kingdom and it may be necessary to check the individual status for each EU member state. Use the following link to check the up to date status for each member state:

http://www.dti.gov.uk/sustainability/weee/WEEE_Transposition_Report_April05.pdf

Directive 2002/96/EC
Waste Electrical and Electronic Equipment (WEEE)

First step towards knowing whether or not your products are included in this proposed legislation is whether or not you are defined as a Producer (of electrical or electronic goods) under the following categories:

• Manufactures and sells his own brand
• Resells under his own brand
• Imports or exports branded goods

The directive sets criteria for the collection, treatment, recycling and recovery of waste electrical and electronic equipment. The responsibility will lie with the Producer, therefore any companies involved in sub-contracting assembly (EMS) will have no responsibility under this directive, and this will rest totally with their clients. EMS suppliers will of course be bound under the RoHS directive to conform to manufacturing directives as outlined later.

Products Included in the Directive

http://www.dti.gov.uk/sustainability

There are of course exemption under this directive, such as military electronics and again the above link should be used for a detailed listing.

1.	Large household appliances
2.	Small household appliances
3.	IT and telecommunications equipment
4.	Consumer equipment
5.	Lighting equipment
6.	Electrical and electronic tools (exception of large stationary industrial tools)
7.	Toys, leisure and sports equipment
8.	Medical devices (exception of all implanted and infected products)
9.	Monitoring and control instruments
10.	Automatic dispensers
	Categories 8 and 9 to be further defined and dates set

How will you be affected

Prepare variety of data on volumes and types of equipment you have placed in EU countries, and what has been recycled by you or on your behalf

Annual registration as a PRODUCER with Environmental Agency – once arrangements finalised – £1000’s annually

Ensure that your products, where possible, designed for reuse or recycling.

Pay your share of treatment and recycling costs for WEEE collected materials - both products produced prior to and after 13 August 2005.

Data to be made available of goods shipped to market January to December 2004

Make information available regarding reuse, refurbishment and treatment of your products.

All products on or after 13 August 2005 to be correctly labelled and dated, and packaging, instructions and warranties to carry correct recycling information and where to “Take-back” – Sections 10 and 11 of WEEE

***The way these requirements will operate in practice are not yet fully finalised – still under discussion***

“Facilitates the dismantling and recycling of waste electrical and electronic equipmentby restricting the use of hazardous substances used in their manufacture.”

Put on Market, basically means that the products have to be available to your customer on this date, conforming or RoHS Compliant with the contents of the directive.

Substance Limits for RoHS

Lead

Mercury

Hexavalent Chromium

Polybrominated biphenyls (PBB)

Polybrominated Diphenyl Ethers (PDBE)

And of 0.01% by weight in homogeneous materials for cadmium shall be tolerated.

“Homogeneous material means a unit cannot be mechanically disjointed in single materials.”

There is much debate currently over the wording and meaning of “Homogeneous material”, and it may be that a separate guidance notes will be issued with the legislation in order to clarify the maximum concentration levels.

Always remembering that these limits under the RoHS directive will apply to products “Put on Market” that is available to purchase on 1 July 2006. It does not mean that production processes must change on this date.

Some exemptions should be given to certain products or processes where no alternative technology currently exists, or for some other reasons. The current list of exemptions under discussion is as follows:

• Mercury (in some lighting applications)
• Lead in the glass of cathode ray tubes, electronic components and fluorescent tubes.
• Lead in certain steel, aluminium and copper alloys
• Lead in high melting temperature type solders
• Lead in solders for servers (Until 2010)
• Lead in solders for network infrastructure equipment
• Lead in electronic ceramic parts
• Cadmium plating
• Hexavalent chromium in absorption refrigerators
• Repair of equipment manufactured prior to 1 July 2006
• Military electronics
• Piezo devices

Future Reviews

As this type of directive is of an ongoing rolling nature some future reviews have already been identified:

• March 2005 – inclusion of categories 8 and 9 in WEEE – medical and monitoring equipment. – still waiting

• Evaluation of applications for:

  Deca BDE
  Mercury in straight fluorescent lamps for special purposes
  Lead in solders for servers etc. – 2010?
  Light bulbs – probably now included

It is widely expected that a total review of the directives will be scheduled sometime during 2008 on a European wide basis.

Similar legislation also exists in China although it is very difficult to get any hard information but it is expected that the list of exemption could be different from those proposed by the EU.

There are also environmental issues in terms of the use of lead in certain products in some states within the USA. These vary from state to state but should be verified for the following states:

California, Connecticut, Florida, New Jersey, South Carolina

None of the above directives within the EU are applicable to automotives, and in particular to automotive electronics. This is covered under a separate directive 2000/53/EC End of Life Vehicles, in which lead containing solders used in automotive electronics is exempted for the time being.