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WEEE, RoHS, and a Trail of Breadcrumbs
April 3, 2006 |Estimated reading time: 3 minutes
By Michelle Boisvert, Managing Editor
BOSTON — You can't go very far in the electronics manufacturing industry without hearing discussion about the European Union's (EU) Restrictions of the use of certain Hazardous Substances in Electronic Equipment (RoHS) and the Waste Electrical and Electronic Equipment (WEEE) regulations. Manufacturers share growing concerns about the long-term reliability of lead-free solders and what lies beyond the implementation deadlines. Each directive has its own technical and manufacturing issues — WEEE with component marking questions, and RoHS with phasing out tin/lead and manufacturing in a mixed-alloy environment, for example. There are many other concerns that those on the line don't often deal with, such as the paperwork and logistics associated with each specific directive. The Department of Trade and Industry (DTI) has begun speaking with stakeholders (producers, retailers, treatment and recycling industries, reuse and refurbishment organizations, and local authorities) to cover concerns and needs of small and large companies with regard to the WEEE Directive. None of the involved parties expected to reopen the conclusions from the review on December 14, 2005; however, the group was "looking for evidence to show whether the implementation proposals will deliver the objectives and obligations set by the Directive in an effective and efficient way," states DTI information. The review concluded that U.K. implementation of the WEEE Directive should feature approved compliance schemes for retailers that establish networks of Designated Collection Facilities (DCFs); obligatory registration for producers that can be direct or established through an approved compliance scheme; a system for calculating producers' obligations under the Directive; and a "quasi-market mechanism" for allocating WEEE from DCFs to producer schemes. The review also included a code of practice for collection of WEEE; a network of authorized treatment facilities; protocols to enable producers to demonstrate achievement of recycling targets cost effectively; and a voluntary approach for producers to show the cost of handling historical WEEE. Although the DTI does not plan to make any changes to the implementation of the Directive, comments are being accepted via e-mail (WEEE@dti.gsi.gov.uk) until April 21, 2006. The DTI will release formal consultation on draft regulations in Spring 2006.
This is great news to all involved companies, as there are still many questions regarding how this directive will fare, but we're not out of the woods yet. At a March 28, 2006, meeting in Boston, Mass., representatives from The Mabbett Group, an international organization specializing in WEEE/RoHS compliance and implementation for electronics companies, met to help sort through the paperwork trail that will be a necessity for WEEE and RoHS compliance for all within the electronics supply chain. "Trying to draw a firm line of what's covered and what is not is complicated," said Stephen Greene, senior product stewardship, associate and senior project manager, Mabbett & Associates, Inc. If companies haven't done so already, they now must keep more precise records, documentation, and processes, including conformance certificates, contracts, and agreements, as well as third-party reviews. Unfortunately, when it comes to the signing on the dotted line, not many companies are willing to take that step. "No one is signing anything at the material declaration suppliers level," said a representative from one OEM in attendance. "Everyone is doing due diligence, but no one will sign off." Greene also emphasized that compliance to these environmental regulations doesn't start on the assembly line; it must be built into the first level of product design.
While there are still several questions in the U.S. surrounding the ins and outs of WEEE and RoHS implementation, it seems that we're not alone. With the RoHS deadline just three months away, WEEE (which initially seemed less daunting to the industry) is still creating shadows of doubt. The DTI is ironing out the nitty-gritty details now, and communicating with the industry. However, it has been noted that complete agreement from all parties isn't expected. In the meantime, U.S. companies can use the resources out there, seek legal counsel, begin a documentation process, and begin dropping the paperwork "breadcrumbs" to track due diligence.