Directive Decoder

With everything else going on in the UK over the weekend it is worth noting that the Waste Electrical and Electronic Equipment Directive (WEEE) came into force on July 1st.

To be honest WEEE is a pretty complicated directive. Unlike RoHS, this is categorised as an Article 175 directive meaning that the interpretation, and implementation, may well differ across EU Member States.

I listened to a guest on a BBC Radio 5 current affairs programme on Saturday morning really struggling to get the aims of the directive across to the listener.

The EU WEEE (Waste Electrical & Electronic Equipment) Directive requires 10 categories of electrical and electronic equipment to be collected, treated, recycled and disposed of when it reaches end-of-life. The directive sets targets for the percentages of materials that must be recovered and includes a list of parts that have to be removed and then recycled separately. The Directive also includes a requirement that manufacturers design equipment so that it can be easily recycled although this has not yet been translated into national legislation in any EU State.

Recycling is a cost that can be significant and is paid for by the producer (usually the manufacturer or importer). In effect it is a sales cost, as it must be financed when the product is sold. The cost of recycling can be influenced by the design of the equipment although whether the manufacturer can realise these benefits depends on whether they collect and recycle their own equipment at end of life (in which case they can) or if it is collected and recycled by compliance schemes that collect a wide range of products from many producers (where the benefits are more limited).

The REACH regulations were adopted in December 2006. REACH stands for “Registration, Evaluation, Authorisation (and restriction) of CHemicals”. This is a complex piece of legislation that will affect manufacturers and importers of chemicals, preparations (such as adhesives, paints, etc.) and “articles”, which include all types of electrical components, sub-assemblies and equipment. There are no exemptions for such as transport, aerospace, etc.

These regulations have been adopted because of the many thousands of high volume chemicals used in the European Union. Today there is no risk data available on 21% of them, inadequate data on 65% and only 3% are fully tested. This means that it is almost impossible to choose a “safe” substance due to a lack of data. REACH aims to ensure that all substances are fully tested.

Norway has served notice that it intends to prohibit, with a few exemptions, 18 substances from consumer goods in Norway. Called the Prohibition on Certain Hazardous Substances in Consumer Products this could well be referred to as “PoHS” due to the passing resemblance to RoHS.

The legislation will only apply to Norway but already there appear to be limited choices for companies exporting to Europe. Either develop PoHS as a standard, as RoHS proved that manufacturers do not want to produce unnecessary variants of a product, or simply don’t ship to Norway.

The Energy-Using Products Directive establishes a framework for the setting of eco-design requirements in energy-using products. It aims to improve the environmental performance of products throughout their life cycle, by systematic integration of environmental considerations at an early stage in the product design. The clear objective is to cut energy use.

The Directive was finalised in July 2005 with detailed “implementing measures” to follow after studies, led by the European Commission, have been completed. Reporting is expected later in 2007 / 2008.

While RoHS legislation started life in Brussels it continues to spread around the world in its various forms.

Now Australia has performed an impact assessment for local adoption of RoHS. A survey of industry was commissioned via a website.

To date the impact assessment has not been made available publicly, nor is there a policy decision by the government.

Around 160,000 tonnes of consumer batteries, 190,000 tonnes of industrial batteries and 800,000 tonnes of vehicle batteries are sold in Europe every year.

The most recent figures indicate Belgium, Sweden, Austria, Germany, Holland and France as having the most efficient systems in place to collect all types of used portable batteries.

The European Union has agreed the text of a law that will make recycling of batteries obligatory from 2008.