WEEE: No fun for manufacturers

Two new European environmental standards will have a dramatic effect on manufacturers of electronic devices for sale within the European Union (EU). One restricts the materials that may be used in the manufacture of products. The other requires manufacturers to assume responsibility for product disposal at end-of-life. These regulations go into effect soon, and meeting them could be difficult for US manufacturers.

The WEEE product lifecycle involves a host of steps that support reuse and recycling of electronic products, with the manufacturer footing the bill. Courtesy of TUV Rheinland North America.

As a result, much electronic equipment simply gets thrown away at the end of its life. Estimates published by the BBC (British Broadcasting Corp.) put the number of products ending up in landfills at more than 200 million per year. Other estimates put the amount of electronic waste at 4% of the 2 billion tons generated in Europe each year, with the amount growing swiftly. Europe has moved to stem this flood of waste with new regulations on the composition and disposal of electronic devices.

The European Union directive "Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment" (RoHS) affects designs by limiting choices in the fabrication of electronic equipment. The RoHS Directive bans from the EU market any new electronic equipment containing more than set percentages by weight of lead, cadmium, mercury, hexavalent chromium, and polybrominated biphenyl(PBB) and polybrominated diphenyl ether (PBDE) flame retardants.

Lead, for instance, cannot be more than 1000 parts per million (ppm), while cadmium is restricted to 100 ppm. As a result, soldering, batteries, packaging, and other common components of electronic products will be drastically affected. The restriction takes effect July 1, 2006, and products or their components that do not comply will need to be redesigned in order to stay on the market.

The Waste Electrical and Electronic Equipment (WEEE) Directive is more imminent, scheduled to take effect in August 2005. The WEEE directive seeks to minimize the impact of electronic equipment on the environment both during its product lifetime and when it becomes waste by making the manufacturer responsible for both disposal and recycling.

The directive requires that manufacturers of equipment for sale in the EU must fund recycling and disposal efforts for their equipment at the end of its life, either by establishing their own programs or by participating in approved central programs. The end user is not to be charged for any of these programs, and the manufacturer must provide a way for the user to dispose of old electronics freely.

Another element of the WEEE directive targets design. Equipment manufactured for sale in the EU must be designed to be recycled. This means that products must be able to be dismantled so individual elements can be separated and handled appropriately. Design engineers must therefore keep disassembly in mind along with assembly, and manufacturers must guide recycling efforts by marking products and supplying documentation that provides the disassembly and disposal instructions. This documentation covers products down to the component level, so component suppliers will need to provide manufacturers with the appropriate data on the composition and handling of their devices, as well.

Along with the requirements for marking and documentation come targets for the recovery and recycling of materials in the product. Depending on the type of equipment, manufacturers must recover 70% to 80% by weight of the materials used in the products, with component, material, and substance reuse and recycling accounting for 50% to 75% by weight. To prove these targets have been met, companies will need to maintain records of their product's composition as well as the success of downstream recovery and recycling efforts.

Not all electronic devices are subject to these new directives. The WEEE, for instance, defines 10 categories of equipment ranging from consumer appliances to computers and information technology (IT) systems that must comply. Nevertheless, the regulations can affect manufacturers who do not appear to fall into one of the categories: Although large industrial systems for fixed-location operation are exempt, the control panels within such systems are covered. In effect, then, virtually every manufacturer of products with electronic content will need to establish design practices and compliance programs to address the RoHS and WEEE directives.

With the first deadlines for these new standards becoming effective in 2005, this need for new design approaches and documentation is leaving many companies scrambling to establish the appropriate programs. That can be a challenge without guidance. The regulations have been available for inspection since 2003, says Geoffrey Bock, an engineer at the industrial machinery division of TUV Rheinland of North America, but initially there were no standards for compliance. Those standards are still in development through organizations such as the IEEE, the IEC, and ASTM, he notes. As a result, many companies have fallen behind in preparing for compliance.

Companies have two choices for compliance, according to Bock. One is for the company to develop its own processes and self-declare compliance. The other is to work with third parties to handle the recycling efforts. Either way, the cost of compliance must be borne by the manufacturer as the directives forbid charging end users for recovery and recycling.

Evading the compliance issue is not an option. The directives provide for a fine up to EUR 50,000 for regulatory offenses such as marketing noncompliant equipment, shirking or failing to report on recovery efforts, and failing to register with a competent authority before placing products on the market.

Third-party programs are being established, although information about them is hard to come by. Industry organizations such as the UK-based WEEE Recycling Network (www.weeenetwork.com) are arising to help smaller companies find suppliers and recyclers to help.

Larger organizations that are taking the self-declaration route are consulting with compliance consultants such as TUV Rheinland (www.tuv.com) and Underwriters Laboratories (www.ul.com) to define the testing and monitoring programs they will need as well as to find RoHS-compliant suppliers.

With the deadlines so close, compliance test engineers should consider getting acquainted with these directives soon to help guide their company's efforts. The directives can be found online at the Journal of the European Union as directives 2002/95/EC and 2002/96/EC (europa.eu.int/eur-lex/en).

Design Chain Associates (www.designchainassociates.com) maintains a list of links to company lead-free program descriptions. In addition, an online seminar regarding WEEE compliance is available from TUV Rheinland (www.us.tuv.com/training_and_education/weee-seminar.html).