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WEEE Registration Logistics
December 31, 1969 |Estimated reading time: 4 minutes
By Katherine Hickey and Ronald Lasky
WEEE should have been adopted in the EU by August 2005; however, the UK, France, Italy, Poland, Estonia, Finland, Greece, and Malta have yet to enforce the legislation. Are they laggards or is WEEE not going to happen? Nay to both thoughts. These delays are due to the inordinate amount of government work that must be performed within the countries to get ready for WEEE. An entire panoply of infrastructure is required to make WEEE work in each country. The governments, with the support of industry, must lead this infrastructure. The UK is being honest in that they are not ready for WEEE implementation and will not be ready for a while. At first, the UK moved the August 13, 2005, date required for registration of WEEE products to January 1, 2006; and most recently to July 1, 2006. The other 20 or so EU countries likely are not being forthright on their lack of preparedness.
One of the frustrations with WEEE, by the manufacturers of EEE products, is that all products must be registered separately in each of the 30 EU countries. This frustration is compounded by the difficulty of finding the addresses in which to send WEEE registrations. An appendix to The Protocol for RoHS and WEEE Compliance, available at http://www.smta.org/store/book_detail.cfm?BOOK_ID=208 has met this need.
In a nutshell, what does WEEE require?
- Registration of a manufacturer’s product(s) with each of the 30 EU countries.
- Registration requires a market projection of how many units will be sold.
- A documented “take-back” scheme with your distributors in each country.
- Designation of an approved facility to recycle your products.
- It appears that the products can cross boundaries to be recycled. For example, a product sold in Germany may be recycled in Poland.
- Some countries will have a “Clearing House” you can hire to recycle your products. The UK has been the leading example of this approach.
- Certain recycling targets have been set: e.g. 75% of products recycled and 65% of the material in each product recycled. Achievement of these targets should be tracked.
- Producers must label their products as “put on the market” post the original August implementation date. Labeling conventions are outlined in the Directive texts.
- “Due diligence” is important in all of these processes. Those who are trying hard to obey the Directives and make mistakes likely will be dealt with leniently. Those who willfully disobey the Directives will be almost certainly dealt with more severely.
- Keep good records.
Some may view the delay in WEEE implementation as a possible indication that RoHS will also be delayed. Forget it. WEEE is delayed because it requires significant government work. RoHS requires little government work - you do all of the work. In theory, the government should be monitoring this, but we expect these activities will be light at first and typically each country’s bureau of weights and measures will handle this. (Again, the UK is taking the lead here.) Government infrastructure will also be needed for this task in each of the countries, but even if it is not there, products must be ready for document checks and spot chemical analyses. Therefore, you will need to be fully RoHS-compliant.
How does one prepare? We recommend a “Self Declaration” indicating compliance with the six RoHS-prohibited materials: mercury, lead, hexavalent chromium, BDEs, PBDEs at <0.1%, and cadmium at <0.01%. The self declaration should consist of a documented chemical assay of the solder paste used, indicating that it complies with the RoHS specifications; a bill of material (BOM) for the product with documentation that all components, connectors, PWBs, etc. comply with RoHS; a documentation of the assembly process; and a “tear down” analysis on several assembled units to demonstrate compliance.
IPC 1752, a declaration spreadsheet, has been developed to help in this self-declaration process. The “tear down” analysis is the least clear task. Unfortunately, there is no single technique to provide a definitive analysis indicating that a product complies with RoHS. In a sense, accomplishing this task beyond all doubt would be difficult, as all solder joints, leads, connections, and materials would need to be analyzed. Because there would be thousands of points that would require analysis, only a statistical sampling is practical. For the sites sampled, a minimum of three analysis techniques are required. For mercury, lead, and cadmium, a technique such as atomic absorption spectrophotometry could be used. For hexavalent chromium, ion chromatography should work; and infrared spectrometry would be a candidate tool for BDE and PBDE. However, measuring the concentrations to <0.1% or <0.01% requires excising material from the product that is being analyzed. Most analysts will try to avoid this approach due to its difficulty. However, we feel it is required for convincing results. It is interesting that as China executes its own RoHS program, they have established 18 laboratories they “recommend” for RoHS analysis of products coming into the country.
As the RoHS implementation date of July 1, 2006, approaches, it is important that your WEEE and RoHS plans are in place. If you want to gauge how you are doing compared to others, you may want to use the free Lead-free Readiness Assessment Tool, available at www.pb-free.com.
KATHERINE M. M. HICKEY, MEM, NeoVention, LLC, may be contacted at (603) 513-1916; e-mail: kathy@neovention.com; RONALD C. LASKY, Ph.D., PE, senior technologist at Indium Corp., and visiting professor at Dartmouth College, may be contacted at (508) 930-2242; e-mail: rlasky@indium.com.