Directive Decoder

Two new studies have been started by the European Commission regarding the RoHS Directive. One is considering the case for ALL existing exemptions plus some new requests, the other is looking at adding more substance restrictions to RoHS beyond the existing 6. Both studies will have major implications on the legality of existing designs which rely on current exemptions, which may be withdrawn or substances which may be banned.

ERA attended a Member State RoHS workshop organised by BERR (formerly the UK DTI) on 26 October 2007 to discuss options for improving the RoHS exemptions process. Applicants have experienced long periods of uncertainty with no indications of progress and the Commission has found it difficult to reach decisions because of the technical complexity of many of the requests. Steve Andrews of BERR will present the conclusions from the workshop at the next TAC meeting in November.

The Commission has recently awarded two study contracts to the Öko Institut; the review of all existing exemptions in the RoHS Directive Annex plus seven new requests and a study into the possibility for adding more substances to the current RoHS 6. The latter study forms part of the current review of the RoHS Directive that will eventually be amended. These studies will have profound implications to all sectors of the electronics industry including those that are currently excluded because the scope of RoHS could be changed to include many new product types.
It is now important for manufacturers to act swiftly to counter unacceptable changes. Once the Commission’s proposals are presented to the European Parliament and Council of Ministers, it will be much more difficult to make changes - so now is the time to act.

* In the Western world, phones made to last ten years typically are discarded after 18 months

* 105 million phones are thrown out in Europe every year. In Britain alone, about 15 million mobile phones are replaced each year

* There are nearly 50,000 network base stations in the UK

* The mobile industry in Britain accounts for about 0.7 per cent of CO2 emissions

* Each mobile subscriber is responsible for about 55 kg (120lb) of CO2 emissions a year

Interesting snippet from an excellent Envirowise “Cleaner Design” seminar last week:

 80% of the cost of a product is set at the design stage
 93% of production materials are never used in the final product
 80% of products are discarded after a single use

Design decisions will affect the manufacture, use and disposal phases of a product

Directive Decoder

US companies that donot have a legal presence in the European Union donot have any direct obligations under REACH, regardless of whether or not they sell products into the EU.
However, REACH may have an impact on supply. The costs associated with registration or potential restrictions may lead EU manufacturers to phase out certain substances. Therefore US companies may witness supply difficulties for some products and raw materials.
It is also likely that products, where purchased from the EU, will become more expensive as REACH is implemented.
Any US company with a presence in the EU may well be affected by the REACH requirement that importers, manufacturers, producers and downstream users comply with various procedures including, in some cases, registration of substances.

Directive Decoder

REACH will have far reaching implications for the entire supply chain both within the European Union and beyond.
An interesting question is will China produce its own version of REACH as it did with RoHS and the pending WEEE regulations? I guess the answer may be found in whether or not the significant number of small and medium chemical plants will be ready for REACH like legislation in the foreseeable future?
There is a potential risk to trade as EU downstream users may prefer to purchase from local sources rather than face the burden of registering an imported chemical or facing a potential price increase

Directive Decoder

Tests in the US concluded that lead-free solders were no better, or worse, than traditional lead based solder, just different, and overall provide no benefit to the environment, especially if lead is adequately controlled.

Not enough to allow for an exemption but this would have been thought provoking when the restriction of lead in RoHS was first considered.

Since use of lead-free solders became widespread there have been few problems reported although many manufacturers expressed concerns over long term reliability.

However, the Microsoft Xbox has clearly suffered a large number of failures which, according to published articles, may well be caused by lead-free soldering to either a BGA (ball grid array) package or a CSP (chip scale package).

Norwegian company TOMRA are rolling out their Automated Recycling Centres (ARCs) around the world.

According to TOMRA, their machines are able to recognise and sort different materials, such as bottles and cans, and efficiently condense them in size.

The state-of-the art ARC is based on cutting-edge material recognition technology. Objects made of plastics, metals, glass and other types of packaging are recognised with almost 100% accuracy as they are inserted into the user station. After the objects have been identified, they are sorted and crushed into separate storage bins.

The number of companies who have registered as Producers in line with the requirements of the WEEE Directive across Europe is not exactly encouraging.

Not surprisingly, Germany lead the way with 17% of the estimated companies registered, followed by the UK at 16% with France and Italy around 8%.

On the other side of the coin, Recycling International Magazine claims that 500 containers of electronic equipment waste are sent to Nigeria every single month with around 45% of them from the EU.

Directive Decoder

I make no apologies for repeatedly talking about REACH……it really is coming!

I can hear the cries of “chemicals, nothing to do with us” all over the place, but that would be wrong.

While it is not yet clear how REACH will impact distributors like Farnell, the wider picture is taking shape.

According to the CEO of German company TechniData, “practically every single industrial enterprise that is based in the EU, or that imports into the EU, will be affected by REACH”.

Well, here is my 50th blog. I hope that you have enjoyed my ramblings over the last year or so.

There is so much going on and, as Ernst & Young reported in blog number 49,
regulatory and compliance risk will be a major challenge for business in 2008.

If you look at what we have covered in this column throughout the year it highlights the diversity of directives.

The National Weights and Measures Laboratory (NWML) has reported on its RoHS enforcement activities between January 2006 and September 2007.

They set out with a goal to deliver a supportive, modern body that helped industry to meet the objectives of the RoHS Directive.

Their aim was to assist business through education, promotion and direct engagement with the Producers of electrical and electronic equipment and other interested bodies.