An Updated Primer on WEEE & RoHS, Part 2

The European Parliament, in its Resolution of 14 November 1996 (7), asked the European Commission to present proposals for directives on a number of priority waste streams, including electrical and electronic waste, and to base such proposals on the principle of producer responsibility. The European Parliament, in the same resolution, requests the Council and the Commission to put forward proposals for cutting the volume of waste.

These directives and the regulations that resulted have continued since then to dominate discussions on the use and disposal of hazardous chemicals in Europe and major parts of the world. (See: An Updated Primer on WEEE & RoHS, Part 1.)

Council Directive 75/442/EEC of 15 July 1975 on waste (8) provides that specific rules for particular instances or supplementing those of Directive 75/442/ EEC on the management of particular categories of waste may be laid down by means of individual directives.

However, the objective of improving the management of WEEE could not be achieved effectively by member states acting individually. In particular, different national applications of the producer responsibility principle could lead to substantial disparities in the financial burden on economic operators. Having different national policies on the management of WEEE hampers the effectiveness of recycling policies. For that reason the essential criteria was laid down at the EC Community level.

Member states could “customize their own processes and procedures for implementation,” but the overall mandates of the directives had to be met. For example, basic principles with regard to the financing of WEEE management had to be set at Community level, and financing schemes had to contribute to high collection rates as well as to the implementation of the principle of producer responsibility.

Member states were to ensure that inspection and monitoring infrastructure that enabled the proper implementation of this directive was verifiable, having regard to Recommendation 2001/331/EC of the European Parliament and the Council of 4 April 2001, which provided for minimum criteria for environmental inspections in the member states.

The European Commission set the following early milestone targets for member states.

  • August 13, 2005:
  • Create collection facilities to collect household WEEE

  • January 2006:
  • Start of producer registration

  • June 2006:
  • Producer responsibility for financing commences alongside retailer take-back

  • July 2006:
  • RoHS substance ban commences

  • December 31, 2006:
  • WEEE collection and recycling targets to be achieved at the rate of separate collection of at least four kilograms on average per inhabitant per year of WEEE from private households.

The following eight criteria should be kept in mind when preparing a product for sale in a European Community covered by the RoHS and WEEE directives:

  1. RoHS restrictions
  2. on the use of hazardous materials including chemicals used in the fabrication of potting compounds, printed circuit boards (use TBBPA), soldering pastes (no Pb), or electronic components.

  3. A design
  4. that considers the amount and type of material that can be recycled at the lowest cost to the producer.

  5. A plan
  6. that includes the supply and retail chain logistics for implementing and financing the collection, recycle, and disposal processes.

  7. A design
  8. that allows for sufficient surface area to locate the mandated recycle label along with the producer's brand name.

  9. A documentation package
  10. detailing all of the materials used in the fabrication of the product and what items can be removed and recycled separately from the fully assembled product.

  11. A list
  12. of key member state agency contacts for each product compliance registration center that will be required to register and market the product into the target region in the timeliest manner.

  13. A product price structure
  14. that considers the cost of collection and recycling. This cost could be determined by agreement with the agencies or partnerships in a multi-party compliance scheme designed to relieve the individual producer of onsite responsibilities. It should be noted that the producer, without exception, has ownership for the effectiveness of the compliance scheme.

  15. A method for auditing
  16. all collections and recycle activities along with a reporting structure to verify compliance at the end of every year.

If the product meets all of the compliance directives as stipulated in WEEE, EPA, and RoHS documentation, the materials used in the product will not be prohibited by any of the existing directives and will have at least 55 percent of the total weight of all materials employed classified as recyclable. Collection, recycle, and disposal cost will be held to a minimum and registration with individual member states will be greatly expedited because of the forethought demonstrated during the product development cycle.

3 comments on “An Updated Primer on WEEE & RoHS, Part 2

  1. Barbara Jorgensen
    May 22, 2012

    This is all great stuff, but there are several points contained in here worth “underlining:” a plan of action and a price spec for the collection and disposal of obsolete devices. There has been a lot of discussion and alerts about counterfiets this week, and I'm not sure the industry really understands that most of this stuff comes from old boards and rejects. Making sure the stuff gets destroyed would cut off a big source of supply and protect OEMs as they are accountable for their products in the first place

  2. dalexander
    May 23, 2012

    Barbara, If a company had an auditable feedback system where there was a record of all of the goods they produced by model number and date of recycle activity, then the goal could look like a reverse book-to-bill ratio. In other words, for the year 2000, we produced 50,0000 dispoasable widgets of model number XXX, and our recycle number for the year 2000 of XXX was 40,0000, then the “P” (produced) to “R” (recycled) ratio is 5:4. This means XXX which was designed to last maybe 6 months maximum before throw-away were either still in unopened packaging, or hit the land fill and bypassed the collection for recycle process. The higher the R:P, the better the company is managing their recycle program. Now, having said that, I know there are dozens of issues with this “too simple” proposal, but it may be a concept worth exploring. Don't just put green labels on products, but state your R:P ratio and maybe consumers could drive the process with their purchasing power vote.

  3. Barbara Jorgensen
    May 23, 2012

    Excellent idea! I agree, it has to be easy for companies to implement, read, and analyze. Nothing is ever as simple as it seems, but I think any process that can kill two birds with one stone (1. establish compliance and 2. ensure disposal/cut off counterfeit supplies) fits the bill. The trouble is all these compliance audits are developed in silos and there are never cross-functional checkpoints where two parties can see they are really trying to accomplish the same thing. It doesn't even have to be evident to the end user that disposing of this stuff is even connected to anti-counterfeiting efforts. All they need to know is that it gets done. And doesn't cost them a whole lot more $$$

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