Two environmental mandates that have a significant impact on the electronics industry advanced forward this week.
In China, the Ministry of Industry and Information Technology (MIIT) published the latest proposals on the so-called "China RoHS" rule. Similar to the EU's Restriction on Hazardous Substances, China RoHS regulates the use and disposal of certain hazardous materials in the manufacturing of electronics.
The proposals include further clarification on the definition of Electrical and Electronic Equipment (EEE) and are along the lines of RoHS in the European Union.
According to Gary Nevison, head of Legislation & Compliance at Premier Farnell/element14:
The product scope moves from Electronic Information Products (EIPs) to EEE similar to the EU, and as a result, many home appliances and electronic toys that fell out of scope of EIPs will be regulated under the new proposals.
The new proposals require that manufacturers and importers of electrical and electronic products provide information about the impact of a product on the environment and human health when the product is misused or disposed of in addition to the name and concentration of hazardous, the name of parts that contain hazardous substances, and whether a part or product can be recycled.
Under previous proposals, products listed in the Key Administrative Catalogue for the Pollution Control of EIPs, would need to be tested by one of the approved labs in China and obtain China RoHS Certification (CCC) accreditation.
Under the new China RoHS proposals, the Catalogue will be renamed as the Target Administrative Catalogue for the Pollution Control of Electrical and Electronic Products. Various government bodies will set a timeline to prohibit the use of certain hazardous chemicals for the products listed in the catalogue.
The proposals are open for consultation until July 10.
In the US, revisions to the 2008 Definition of Solid Waste (DSW) were discussed by industry association IPC and the Environmental Protection Agency (EPA). The EPA has proposed changes to the Resource Conservation and Recovery Act (RCRA) DSW rule. The IPC is encouraging provisions for secondary materials recycling be included in the upcoming revision.
According to the IPC, wastewater treatment sludge from electroplating is one of the largest sources in the United States of untapped metal-bearing secondary materials that can be recycled. Many of these materials are put into landfills because of EPA hazardous waste regulations.
More than 9.7 million pounds of copper were landfilled -- rather than recycled -- in 2010, according to the IPC. The 2011 proposed changes to the solid-waste rule would continue to inhibit the recycling of materials by imposing unnecessary burdens, the association adds.
IPC leaders are encouraging the EPA to include transfer-based exclusion and remanufacturing exclusions in the revision.
The government deciding a format of labels and what wordings qualify as being understandable and adequately explanatory of the facts. This can either be in the form of predefinining the wordings (which wont be easy as there are limitless possibility of disposals that can cause healthcare issues) or approving the wordings to be printed on the packaging.
Earlier wording in drafts of revisions of China RoHS connected this label specifically to outlining health consequences of improper handling of e-waste (caveat - or at least the translations I saw made this connection - I don't know if the language changed or not in the latest because I can't read Chinese), and India E-waste followed with language for this label that looked similar.
I don't think producers are qualified to write up something equivalent to a health warning label. Just trying to think of what you would put on that label escapes me. "Unsafe dismantling and handling of this product in lieu of proper disposal for purposes of precious metal extraction can lead to lung damage"? Most warning labels have a format. I think there is some assumption that "industry will come up with a label" similar to the assumption on the EUP (orange marking) that somehow industry would come up with a number of years for the EUP for each product - China ended up setting up guidelines that everyone uses.
"Any ideas on how industry can fulfil this new labeling requirement? Or is this going to be a problem? "
I think this is going to be a problem at first as the manufacturers wont be fully willing to disclose the actual facts completely. What will happen is that manufacturers will try to figure out what level of truth is acceptable to the masses and will not affect their sales. Disclosing beyond that cannot be expected unless strict audit is performed to ensure the compliance which itself will be a headache for the regulators.
There is a similar clause in India's E-Waste Handling rules. This has to do with board cooking for precious metal extraction and other unsafe e-waste handling (and has to do indirectly with dumping, redirection, or exporting of e-wastes). Any ideas on how industry can fulfil this new labeling requirement? Or is this going to be a problem?
@Ariella: well, I agree with the possibilities you have mentioned, at the end the issue will be still present in the future, definitely, until a worldwide recognized organism will be in charge of rules, controls and financial penalties in case of rules are not respected, isn't it?
I agree that there's still a lot of uncertainty regarding China RoHS. The clause that Ariella points to requires exporters to identify and discuss the hazardous substances, yet another part of the law requires products be sent to China-certified authorities for testing. Why take the word of an organization such as the EPA when you are going to test it anyway?
The new proposals require that manufacturers and importers of electrical and electronic products provide information about the impact of a product on the environment and human health when the product is misused or disposed of in addition to the name and concentration of hazardous, the name of parts that contain hazardous substances, and whether a part or product can be recycled.
Though that sounds progressive, I am sure that such notices can be hidden and obscured in very unclear language. Would there be regulations about the notice, like say, food labels that have to identify key nutrional facts in a certain size font, etc.?
EBN Dialogue enables and encourages you to participate in live chats with notable leaders and luminaries. Not only editors and journalists, but the entire EBN community is able to comment and ask questions. Listed below are upcoming and archived chats.
Archived Dialogues
Thailand Stages a Comeback Join EBN contributor Jennifer Baljko on Thursday August 23, 2012, at 11:00 a.m. EST for a live chat on how electronic manufacturers in Thailand have shored up their supply chain to reduce the impact of future natural disasters.
Euro-Crisis: What It Means for High-Tech Firms Join EBN Editor in Chief Bolaji Ojo and Contributing Editor Jennifer Baljko on Thursday, July 12, at 10:00 a.m. EDT for a Live Chat on high-tech and Europe's economic difficulties.
Microsoft Surface: Potential Winners & Losers What are the implications for the electronics industry supply chain of Microsoft Corp.'s decision to launch its own tablet PC? Join industry veteran and EE Times' systems and OEM expert Rick Merritt on Tuesday, July 3, at 12:00 pm EDT for a Live Chat on this subject.
Join EBN contributor Jennifer Baljko on Thursday August 23, 2012, at 11:00 a.m. EST for a live chat on how electronic manufacturers in Thailand have shored up their supply chain to reduce the impact of future natural disasters.
Peter Drucker famously said "Trying to predict the future is like trying to drive down a country road at night with no lights while looking out the back window." Yet in the razor's-edge world of electronics—with a lean supply chain and just-in-time demands—the need to know the future is vital.
You've heard the saying "the No. 1 supply chain risk is your people." That hasn't always been the case. But today's complex global supply chain requires a new type of multitalented employee. It's one who understands, finance, marketing, economics, is savvy with technology, graceful with relationships and can think analytically.
Where are these people? Are universities properly preparing the next generation supply chain professionals? How do train your existing workforce for these new, demanding positions?
Brian Fuller, editor-in-chief of EBN, will lead a 60-minute Avnet Velocity panel discussion that will ask and answer these and other questions swirling around today's supply-chain talent challenges.
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