Get Ready for 'Design for Disassembly'

Probably one of the best efforts in the world for managing electronic waste is under way in the European Union.

The Waste Electrical and Electronic Equipment (WEEE) legislation covers all components, subassemblies, and consumables that are part of a product when it is discarded. The EU's definition of electrical and electronic equipment (EEE) includes all equipment that needs electric currents or electromagnetic fields to work properly. It also includes equipment for the generation, transfer, and measurement of currents and fields designed for use with a voltage rating of up to 1,000 volts AC and 1,500 volts DC.

The major categories of EEE are listed in Annex 1 of the legislation. They include 10 major types, such as large household appliances, IT telecom, and medical devices. Annex 2 is the indicative list of equipment falling into the categories of Annex 1, such as washing machines, mainframes, and cardiology equipment.

The objectives of the EU's overall environmental policy are to preserve, protect, and improve the quality of the environment. The policy is meant to protect human health and to ensure the prudent and natural use of natural resources. It is based on the principles of precaution and preventive action -- environmental damage should be rectified at the source, and the polluter should pay.

With the priority being sustainable development, significant changes in product development, production, consumption, and behavior patterns are required to reduce pollution and the wasteful consumption of natural resources. This legislation is also designed to address the differences in member states' policies, so it has set the directives and final authorities at the EU level.

The EU has also recognized that waste management is an integral aspect of product life cycle management, and the legislation strives to optimize reuse and recovery through product design. The idea is to make repair, upgrades, reuse, disassembly, and recycling essential considerations at the earliest conception and design stages of an R&D effort. Most manufacturers are already using acronyms like DFA (design for assembly), DFT (design for test), and DFM (design for manufacturability), but now we need to consider DFD (design for disassembly).

Two years ago, I was asked to conduct a study on lithium battery recycling for a particular product. I examined the legislation as it read back then. The recycling directions included a request to remove the embedded battery from the product before taking it back to the EU retailer, which would send the WEEE to the recycling center. Since the battery was encapsulated in a potting compound, I could not return the product as a whole unit. I had to identify a company that could deal with the potting compound to reclaim the lithium in the battery as a second reclamation effort. As a result, the final product eliminated the potting compound, and the battery enclosure was redesigned for easy access.

As we have seen with the European Union's Restriction of Hazardous Substances and Registration, Evaluation, Authorization and Restriction of Chemical substances regulations, companies must be able to anticipate the recycling and disassembly fees generated by their materials and designs. The EU's "polluter pays" policy ensures that producers will consider the after-sales costs of every product slated to be shipped to EU member states.