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An Updated Primer on WEEE & RoHS, Part 1

This blog discusses the Waste Electrical & Electronic Equipment (WEEE) and Reduction of Hazardous Substances (RoHS) directives and how they affect the design, manufacture, marketing, and sales of products sold in the European Community member states and North America.

These directives govern the registration, collection, disposal, and recycling of electrical and electronic products produced within and outside the countries concerned. The European Parliament is in the process of final review for the most recent amendments to the directives, and each individual member state is working to identify governing bodies that will be responsible for the practical aspects required for full compliance. The Environmental Protection Agency (EPA) is the governing body for the United States, and electronic waste is covered under Title 40 Part 261 (Identification and Listing of Hazardous Waste).

In this blog I will discuss all the various elements of these environmental regulations and name all the players manufacturers must be aware of to assure compliance. The regulations are many and the enforcers similarly numerous, but your company needs to be aware of all these participants to avoid getting caught in a legal mess. As noted in the headline, this is an updated primer on the various parties involved. The details would be too intense for those already familiar with the regulations and the implications for their businesses, but for anyone that is just getting started, this may just be what the doctor ordered.

First, I'll identify all of the departments and government agencies you need to know about in Europe — plus all of the acronyms. In part two of the report to be posted next week, we'll discuss details of the laws and how they impact the electronics market. Please chime in with comments and suggestions.

  • The Department of Trade and Industry (DTI) leads the EU negotiations on European Directives, all of RoHS implementation, and on most aspects of UK implementation of WEEE. The Environment Agency (SEPA in Scotland and EHS in Northern Island) are the enforcement agencies for WEEE. Responsibility for enforcement of the RoHS directive has yet to be allocated by the DTI.
  • Department for Environment Food and Rural Affairs UK (DEFRA)
  • leads on certain aspects of domestic implementation, including drawing up guidance on how WEEE must be treated, waste permitting, and assessing producers’ compliance with the collection, recycling, and recovery targets. The Environment Agency (SEPA in Scotland, EHS in Northern Island) enforce these aspects.

  • The EC member states
  • are reporting progress towards implementation and enforcement of the WEEE and RoHS directives. Because of the organizational, resource, legal, and implementation challenges, the effective details for registration, collection, and enforcement vary considerably. The “Perchards Report” is monitoring and reporting individual state progress. The DTI commissioned this to provide a series of short factual reports on existing WEEE-related measures and the types of transposition plans that were developing in other member states. The last report was filed in November 2005.

9 comments on “An Updated Primer on WEEE & RoHS, Part 1

  1. stochastic excursion
    May 12, 2012

    A lot of good facts here.  What is the level of industry involvement in developing these standards?  

    I know industrial standards bodies are sometimes dominated by major players in the industry who skew the rules to their advantage.  Are there indications of that giong on in this area or is it more or less a level playing field?

  2. dalexander
    May 13, 2012

    Stochastic, Good choice of words. Yes, it is a level playing field. Everyone has to meet the same requirements as in the CE marking requisites. With all the environmental legislation being introduced and maintained, the enforcement becomes a critical issue. With the responsibility to anticipate and fund all the recycling cost being shifted to the producer or agent of the product, the EU has made a brilliant move in reducing their own cost burden, and imagine the benefits derived from every qualifying product having at a minimum 55% of the component material as classified, “recyclable”. How this plays into the counterfeit electronic parts supply chain invasion, will be worth watching in itself. If you can reuse a microprocessor, is that considered, “recycled” material? Should there be a marking on recycled components like we have for recycled paper? This raises a lot of sticky wicket questions…What do you think?

  3. Taimoor Zubar
    May 13, 2012

    Should there be a marking on recycled components like we have for recycled paper?”

    @Douglas: That's an interesting point. I think many electronic components can be fairly easily recycled and should be. This would certainly save the resources being used to build new components. However, I think the process of recycling electronic components will be much different than the one for paper. There needs to be standards in place which can control the recycling process.

  4. stochastic excursion
    May 14, 2012

    The practice of recovering raw materials such as tantalum from electronic waste makes a lot of sense.  Microprocessors are different because they are almost like the brains of systems that incorporate them.  Mission-critical systems like ATM's, voting machines, and defense electronics should stick to sources that are verifiable from fabrication to test to assembly.  

    In the same way you wouldn't use recycled paper for a publication meant to impress a client.  Recycled materials have importance in the supply chain it seems as more of a supplement to existing sources.

  5. dalexander
    May 14, 2012

    Stochastic, In suggesting recycled parts find there way back into the supply chain with some kind of marking ID, I was suggesting that there may be a licit path for reclaimed parts that might be segregated from new parts sold on critical use products. If your child's toy had a 1 year MTBF (Reliability) label on it, would you buy it for a two-year old at a cheaper price than the same toy with a 10 year MTBF? The problem I was hinting at is still the counterfeiting potential of 1 year MTBF being marked as 10 year. So, tying it back into WEEE, the question becomes, can a recycled component or higher level product be identified as recycled in such a manner that it not only does not end up in a land fill, but in fact would find its way back into the market place as a new, USED or refurbished product with a known and stated lower Reliability quotient? My two- year old is not going to play with the same toys 10 years fom now anyway. I'm just putting a new spin on the used product market by suggesting a new loop being deliberately added to the supply chain, without turning it into a knot that counterfeiters could use to tangle up the licit, new product supply line.

  6. dalexander
    May 14, 2012

    Rich, I agree 110% about the disincentive nature of individuals having to pay to turn in their old terminals and other electronics. The EU WEEE requirement states that he manufacturer or agent shoulders the recycling costs upfront so individual consumers don't have to carry the cost of recycling. In addition, in the EU, the stores where the product was initially purchased, take the returned “waste” back without hesitation. Now, I suspect, the retailer adds something to their mark-up, and the manufacturer recoups their burdened cost by adding to the wholesale price some or all of the recycle costs.

  7. stochastic excursion
    May 14, 2012

    A lot of electronic parts now have identification burned onto on-board ROM.  Like key for cars recently manufactured having a unique code that unlocks the door, parts could have a traceability id burned in on board, or maybe on a micro-QR code. 

    Counterfeiters could of course burn in duplicate codes from authentic parts they take out of the supply chain.  With a manufacturer providing traceability for each device, this could be tricky to pull off.

  8. dalexander
    May 14, 2012

    Rich,

    I agree. The optimum, interim solution is to buy from franchised distributors or sources that have well documented processes in place so every part is traceable back to the source. Rules Based RFID is the best implementation for supply chain tracking that is widely deployed now, but for semiconductors, Hardware Intrinsic Security may be the most cost effective in the long run and DNA marking for all materials and components will most likely capture the countermeasures market as the cost for aunthentication come down. This article discusses Waste management via WEEE and I think at some point, we will not be able to address the beginning of the supply chain without discussing the end of the supply chain. For now, just ask your distributor to guarantee reimbursements against all losses for passing on counterfeit parts. Make sure you cover cost of rework and replacement, and not just the cost of the component itself.

  9. Mr. Roques
    May 15, 2012

    Will it, at the end, read: “Send everything to a poor country that prefers a few dollars over the possible effect of those devices on its land”? I think those strategies should take that into a account and have an integral solution that looks for the best solution, for everyone, not just their country or region.

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