Supply Chain Reaction

The EC (European Commission) last week released its proposed changes to ROHS (Restriction of Hazardous Substances) and WEEE (Waste in Electrical and Electronic Equipment), aiming to improve and simplify the environmental regulations.

Specific to recycling, the proposed revised WEEE directive sets a new binding target for the collection of electrical and electronic equipment. The current collection target of 4 kg per person per year does not properly reflect the situation in individual EU Member States, the EC believes, explaining that some Member States where the consumption of electrical and electronic equipment is widespread would have more ambitious targets under the proposed new directive while others with smaller markets will have less ambitious targets.

Specifically, the EC has proposed setting mandatory collection targets equal to 65% of the average weight of electrical and electronic equipment placed on the market over the two previous years in each Member State. The recycling and recovery targets of such equipment now include the re-use of whole appliances, and weight-base targets will increase by 5%. It is also proposed to set targets for the recovery of medical devices.

Meanwhile, the proposed revised ROHS directive would cover medical devices and monitoring and control instruments, which had been excluded from ROHS' reach. There inclusion in proposed and final changes was and is expected. 

Also, while no new banned ROHS substances have been named, a list of "priority" substances posing particular environmental concerns when used in electrical and electronic equipment will be assessed in line with the EU REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) regulation with a view of a possible ban in the future.

That last point was a concern for some industry groups, including the IPC, which in mid-October was fired up about possible TBBPA (Tetrabromobisphenol) ROHS inclusion.

Although found to be safe for humans and the environment by a EU Risk Assessment, TBBPA, a reactive component for producing flame-retardant epoxy systems and a component in most PCB (printed-circuit-board) laminates, had been on the table as a possible priority substance.

The IPC this week sighed with relief in respect to the proposed ROHS revisions, saying "there is finally good news on the environmental regulation front" and applauding the lack of additional banned substances.

Why? Well, these directives, as many won't admit, aren't always based on hard, scientific tests and results. Far from being based on whims, there was lack of adequate testing done as to long-term impact of removing the six targeted materials (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominated-diphenyl ether) from electronics design when ROHS was first pushed upon the electronics supply chain in 2006. And, for an industry driven by fact and figure loving engineers, that can be hard to swallow, not to mention to design around.

IPC from day one has been actively advocating that any new ROHS regulations be based on scientifically valid evidence. Following the release of a draft report on the revision of ROHS, IPC filed comments and in June and hosted a workshop in Brussels to address industry concerns with the proposed expansion of ROHS substance restrictions.

But don't go popping any time champagne corks just yet. The ink on these changes hasn't even be laid to paper, let alone dried.

“This is the first step in a lengthy legislative procedure that could see the proposals change before adoption,” Fern Abrams, IPC director of government relations and environmental policy, cautioned. “Amendments could be inserted during the next stages in the legislative process before the directive is finalized. IPC continues to be cautious and will be diligent to ensure that any proposed changes continue to be based on science.”

For the details on the possible ROHS changes, click here; and for a summary of the EC impact assessment of the possible ROHS changes, click here.

For the details on the possible WEEE changes, click here; and for a summary of the EC impact assessment of the possible WEEE changes, click here.

And voice your opinions below. What do you think of the possible changes to the two directives?