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Lead-Free WEEE and RoHS Issues to Consider
December 31, 1969 |Estimated reading time: 3 minutes
There are many unresolved issues associated with the WEEE and RoHs Directives. Companies throughout the EEE supply chain must understand their obligations under these Directives and develop a strategic action plan for compliance to ensure long-term market competitiveness and business success in the EU and the global economy.
By Thomas M. Cronin and Arthur N. Mabbett
Many in the electronics industry are starting to grasp the business implications associated with the European Union’s (EU) Waste Electronics and Electrical Equipment (WEEE) and Restrictions on Hazardous Substances (RoHS) Directives, as well as the effort required to prepare for the deadlines. Although the Directives specifically target producers and distributors of electronics products, they also impact manufacturers throughout the supply chain. Companies that cannot provide compliant parts and services risk losing market shares.
Companies must determine whether their products fall within the scope of the Directive’s. WEEE covers waste electronics and electrical equipment falling into one of ten categories. RoHS covers the same product categories as WEEE, but medical devices and monitoring and control equipment currently are excluded from the scope of RoHS.
RoHS is based on EC Treaty article 95, which creates a “single market Directive” that aims to harmonize EU legislation. It requires a common regulatory approach, thereby preventing the adoption of different restriction levels by different countries and different product standards.
In contrast, WEEE requires that each of the 25 EU member countries transpose the Directive into law individually, but not necessarily adopt a harmonized approach of how it is applied. Therefore, actual obligations and implementation strategies for producers may vary for each member country. While many industry organizations have advocated a harmonized approach to WEEE transposition, there are inconsistencies in how it is interpreted and applied at the EU member state level.
The deadline for EU countries to transpose WEEE into law was August 13, 2004, yet only a handful of countries have officially done this. Most, however, have drafted implementation legislation. Such inconsistencies throughout the EU, combined with a lack of clarity in critical areas, jeopardize the ability to prepare for the August 13, 2005, deadline.
Producer financial obligations are perhaps the most confusing and complicated aspect of WEEE. Under WEEE, producers must provide financial guarantees to cover the costs of collection, treatment and recovery allocated to them. They also must ensure that they can fulfill their obligations in the event of insolvency. Such guarantees may take the form of blocked bank accounts or recycling insurance. Some unresolved questions include:
- Market share - WEEE allocation may take various forms based on market share, depending on how the Directive is transposed by the member country.
- Individual responsibilities - Financial obligations can be assumed individually by producers or through compliance schemes. Individual compliance means that producers are responsible for their own products, and can benefit from design modifications.
- Consumer vs. Business - WEEE distinguishes between household users (consumers) and non-household users (businesses). Under proposed regulations, producers must finance the costs of collection, treatment and recovery of WEEE at no charge to consumers. They also are responsible for end-of-life management costs of equipment purchased prior to August 13, 2005.
There are product and material exemptions under both Directives. However, these exemptions are subject to regular review; it is widely believed that most, if not all, exemptions eventually will be removed. In the case of the RoHS Directive, it likely will become increasingly difficult for companies to find suppliers of tin/lead parts as the global supply chain transitions to lead-free.
Thomas M. Cronin, director of environmental, health and safety group, Mabbett and Associates, may be contacted at cronin@mabbett.com; Arthur N. Mabbett, president, Mabbett and Associates, may be contacted at amabbett@mabbett.com. Mabbett and Associates may be reached at (781) 275-6050.