Draft Indian WEEE (RoHS?) proposals
The Indian Government has published proposals for the disposal of WEEE (Waste Electrical and Electronic Equipment). The draft also includes what is referred to as the reduction in the use of hazardous substances. This could well be a reference to RoHS although further clarity is required.
The draft does not say if the 20 substances listed, with concentration limits are restricted or that manufacturers should avoid the use of them.
It is unclear whether the thresholds refer to the concentrations in the finished product, in homogeneous materials or something else (remember the debate around this subject leading up to the implementation of EU RoHS).
There are no exemptions associated with the draft but the scope proposed is similar to EU WEEE and includes EU categories 8 and 9, medical devices and monitoring and control instruments.
The list of 20 substances include some, such as TBBPA which are not thought to pose a risk while HBCDD is not listed even though it is EU REACH SVHC.
Those of you who follow my articles will have read about the hazards of unprotected,or backyard, recycling where heavy metals are extracted over open fires or by dipping in acid baths.
One of the aims of this legislation is that all Indian recyclers will need to register and be authorised ensuring that all Indian WEEE is recycled safely.
This would eliminate the need to restrict organohalogens such as PVC and TBBPA as these substances can be recycled safely by modern recycling processes.
Manufacturers and importers will need to provide written documentation with regard to compliance and include details in a product information booklet.
Such requirements would enter into force three years after the adoption of the legislation.