A report was produced, at the back end of last year, by Hyder Consulting for the Department of Environment and Water Resources as part of the preliminary environmental and economic assessment of Australian RoHS policy.
The study considered three RoHS policy models identified by an Australian Government roundtable in 2005:
a) No government intervention
(No action to harmonise with the EU’s RoHS Directive)
b) Voluntary code of practice plus possible co-regulation
(For introduction in 2007 followed by a co-regulatory or regulatory scheme in 2011)
c) National legislation
Mandatory obligations under RoHS legislation within four years
Opinions were collated from companies currently affected by the EU RoHS Directive in Australia as well as businesses likely to witness an impact by the adoption of a similar local policy.
Just over half of the inputs were from companies described as large while the remainder were from SME’s.
The majority of respondents indicated that their product would be compliant for the Australian market. Key drivers for expanding EU RoHS in to Australia included corporate social responsibility, competitiveness, customer demand and a desire for a global standardisation of design and production. Longer term it was also felt that the cost of complying would be lower than non-compliance, whether it be mandatory or voluntary.
Around 74% of respondents believed that those companies that manufacture in Australia for export and supply into the EU would extend the EU compliance into the Australian market. A further 53% also believed that large scale importers of electrical and electronic equipment (EEE) into Australia would also extend EU compliance.
However, 62% felt that small scale importers would not extend EU compliance into the Australia market.
Over 30% of respondents felt that the government should introduce a RoHS policy in Australia. These also believed that it should involve mandatory obligations that are applied industry wide accompanied by monitoring, product, and substance audits.
In respect of timescales it was felt that 1 to 4 years would be appropriate although some felt it should be sooner rather than later so Australian companies remained competitive in global markets.
A view was expressed that longer compliance leadtimes could be considered for smaller companies such as micro-enterprises and SME’s that donot have the same resources or expertise as global manufacturers.
Strong views were expressed on the need to ensure consistency with the EU Directive including exemptions (ironically, currently under review in the EU) and generally not to exceed EU requirements.
Effective enforcement mechanisms were felt vital to ensure industry wide confidence in any scheme.
Recommendations for further work included:
1. Stakeholder consultations
2. Exposure scenarios around such subjects as emissions to landfill, consumption of mercury, cadmium and chromium etc
3. Further investigate cost benefit issues
4. Policy development and implementation issues
So, in summary, there appears to be a willingness to go down the RoHS route in Australia and, indeed, there may not be the same level of pain as witnessed in Europe as many companies have already moved towards compliance to ensure they remain competitive. Further stakeholder consultations will drive the process forward.
Directive Decoder
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