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Thursday, October 06, 2005

WEEE and RoHS

buyusa.gov briefly explains what WEEE and RoHS are, and why suppliers need to be concerned about them.

From August 2005, companies selling a broad range of electrical goods in Europe will need to conform to WEEE (Waste Electrical and Electronic Equipment Directive) and as of July 2006, those same companies will also need to conform to RoHS (Restriction of Use of certain Hazardous Substances Directive).

The European Commission has a more detailed explanation:

Directives 2002/95/EC on the restriction of the use of certain hazardous substances in electrical and electronic equipment and 2002/96/EC on waste electrical and electronic equipment are designed to tackle the fast increasing waste stream of electrical and electronic equipment and complements European Union measures on landfill and incineration of waste. Increased recycling of electrical and electronic equipment will limit the total quantity of waste going to final disposal. Producers will be responsible for taking back and recycling electrical and electronic equipment. This will provide incentives to design electrical and electronic equipment in an environmentally more efficient way, which takes waste management aspects fully into account. Consumers will be able to return their equipment free of charge. In order to prevent the generation of hazardous waste, Directive 2002/95/EC requires the substitution of various heavy metals (lead, mecury, cadmium, and hexavalent chromium) and brominated flame retardants (polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE)) in new electrical and electronic equipment put on the market from 1 July 2006.

Here's what Hewlett Packard has to say about WEEE:

Governments, customers and the public are increasingly interested in the proper disposal of used electronics. The European Union (EU) has developed the WEEE (Waste Electrical and Electronic Equipment) Directive to ensure that systems for collection, treatment and recycling of electronic waste will be in place throughout the European Union. While the WEEE Directive applies to most of HP’s products, it does not apply to parts, assemblies or consumables such as inkjet or LaserJet cartridges.

Throughout the European Union, national legislation is being developed to implement this Directive. Some countries in Europe have national WEEE-type legislation in place for several years, others are currently implementing the Directive and the rest will follow. HP expects that all WEEE legislation in Europe will be agreed by the end of 2006....

Product recycling is nothing new to HP and HP has participated in the development of the WEEE Directive at all stages of the legislative process both at EU and member state level. HP is now contributing to the implementation process in each member state where the company has a presence. HP will comply with the provisions of the WEEE Directive and national implementing legislation....

HP has recycled computer and printer hardware since 1987. HP's Planet Partners recycling service provides an easy way to recycle any brand of computer equipment and is available in 36 countries.


And here's what they say about RoHS:

HP is committed to compliance with all applicable laws and regulations, including the European Union Restriction of Hazardous Substances (RoHS) Directive. HP’s goal is to exceed compliance obligations by meeting the requirements of the RoHS Directive on a worldwide basis. Our company-wide RoHS Team, which includes representatives from all affected HP businesses and organizational functions, leads our global transition efforts. After completing extensive compliance planning and development work in 2003, the RoHS Team continued to work with suppliers in 2004 to guarantee a smooth global transition.

In 2004, we shipped our first HP products containing RoHS-compliant components. To speed our overall transition efforts, we focused on converting families of component parts as opposed to single products or platforms. We will continue to ship numerous products with a majority of compliant components while complete product lines are being transitioned. Our first fully RoHS-compliant products, the HP PhotoSmart R717, HP PhotoSmart M417 and HP PhotoSmart M22 digital cameras, will ship in early 2005....

As originally written, the EU RoHS Directive did not clearly define how to measure acceptable levels of restricted materials. Hexavalent chromium (Cr-VI), a RoHS-restricted compound (0.1% by weight allowed) that is commonly used as a protective coating for metals, presents one example of the implications.
HP took a conservative approach and assumed that use of this compound in coatings and platings on electronic parts would be subject to RoHS. However, many suppliers assumed that the acceptable level would be measured instead as a percentage of the weight of the coated component, allowing the use of restricted materials in thin coatings. These differing views created confusion, and consequently many suppliers delayed making changes to comply with RoHS. In 2004, legislators clarified that RoHS-restricted materials would be evaluated at the material level (e.g. coatings and platings).

A related challenge is that legislation is not harmonized across industries. For example, since the auto industry is the largest user of steel, many steel suppliers are working towards compliance with the EU End of Life Vehicle (ELV) Directive that requires Cr-VI elimination in auto manufacturing as of July 1, 2007 – one year after the RoHS compliance date. The electronics industry buys a small fraction of the total coated steel produced and therefore has little leverage with suppliers to drive an earlier transition. In an attempt to harmonize legislation across industries, HP worked with others in the industry to request a one-year exemption from the restriction of Cr-VI for electronics manufacturers. HP is working with the industry to find practical alternatives to Cr-VI coatings by sharing test results and establishing common specifications.

Goal for 2005

Eliminate lead, mercury, cadmium and hexavalent chromium in 50% of electronic products sold worldwide, as defined by the EU’s RoHS Directive (PBB and PBDE are not used in HP products).

Goal for 2006

Eliminate lead, mercury, cadmium and hexavalent chromium in 100% of electronic products sold worldwide, as defined by the EU’s RoHS Directive.


Here is what Cisco says:

Legislative and environmental factors combined with the competitive drive to implement the latest technology present many companies with the challenge of managing technology surpluses. Cisco offers customers the Takeback and Recycle program to properly dispose of surplus products and products that have reached their end of life.

Equipment that is returned to Cisco through this program is disposed of in an environmentally safe manner using processes that comply with the WEEE (EU Directive on Waste Electrical and Electronic Equipment to be compliant by August 13, 2005) regulations, all EPA guidelines, and U.S. environmental laws at all levels of government. All Cisco branded products are accepted under the program, and on an "as requested" basis, Cisco works with customers to dispose of competitor or other IT products....

Cisco Systems is collaborating with industry peers and suppliers to comply with the European Union Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment ("RoHS") Directive, taking effect July 1, 2006. The RoHS directive prohibits sale of electronic equipment containing certain hazardous substances such as; lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls ("PBB") and polybrominated diphenylethers ("PBDE"), in the European Union. Cisco has a program in place to ensure that Cisco's products satisfy the RoHS Directive with respect to the various categories of electronic products. Cisco is committed to fully comply with the RoHS Directive on or before July 1, 2006....


pb-free.info has identified an interesting exception:

The RoHS Directive does not contain its own list of equipment that must comply with its requirements. Instead, it takes its scope from annex 1 of the associated WEEE Directive. RoHS does, however, maintain its own a list of exemptions within its annex. However, there are a few anomalies to this basic assumption. For example, military applications are absent from the scope of both Directives. In this instance, article 2.3 of WEEE states that equipment connected with national security or purely military purposes is excluded from WEEE. No such reference is made in the RoHS Directive, but the Commission considers that RoHS is broadly reflected in WEEE, and as such this exemption applies to both Directives.

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