Just when you thought you were beginning to understand Europe’s environmental regulations, the European Union turns the tables and will change them again. In the process, these requirements will become much more complicated, more costly, and—for product designers—more challenging.
Adding to this growing complexity is the emergence of environmental restrictions that target the electronics industry from China, Korea, and India (Fig. 1). Also, California’s RoHS-like laws covering the chemical content of electronic products, electronic waste, and energy efficiency are expected to impact the industry inside and outside the state.
The EU’s Restrictions on Hazardous Substances (RoHS) originally limited the use of six hazardous substances in electronic products. Another EU directive, Waste from Electrical and Electronic Equipment (WEEE), focuses on recycling e-waste.
RoHS requires manufacturers to demonstrate that their products don’t contain more than the maximum permitted levels of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominated diphenyl ethers. RoHS has already come at a big cost to the industry, even to companies that have had formal environmental programs in place for years (Fig. 2).
A study conducted for the Consumer Electronics Association by Technology Forecasters Inc. estimates that the RoHS directive cost the global electronics industry more than $32 billion for initial compliance and about $3 billion annually to maintain compliance. The study also found that companies spent on average about $2.6 million to achieve initial RoHS compliance and another $482,000 for annual maintenance.
But according to the European Commission (EC), which oversees RoHS and WEEE, more than four years after these directives went into effect, only about a third of electronic waste is reported to be treated in line with these laws. The other two-thirds is going to landfill and potentially to substandard treatment sites in or outside the EU.
THE PCB CONTROVERSY
Meanwhile, the EC was considering adding substances to the RoHS list. One of these was tetrabromobisphenol A (TBBPA), a reactive flame retardant used in most printed-circuit-board (PCB) laminates. TBBPA was one of the more controversial additions to the draft list of the European Commission’s Environmental Directive-General.
The IPC, a global trade association that comprises 2700 members, has been anything but supportive of adding TBBPA to RoHS. The group says that many PCB manufacturers and end users of circuit boards would not be able to afford the more costly halogenfree laminates.
The group also pointed out that some of the electrical and dielectric properties of halogen-free materials are different compared to those based on TBBPA, requiring the redesign of many PCBs. The IPC won its case when the EC recently announced that it does not intend to add TBBPA as an additional substance to be monitored or restricted under RoHS.
“TBBPA was found to be safe for humans and the environment by a comprehensive risk assessment conducted by the European Union and therefore is not expected to be restricted under the EU’s Restriction, Evaluation, and Authorization of Chemicals (REACH) regulation,” says Lee Wilmot, director of EHS at TTM Technologies Inc. and chair of the IPC EHS Steering Committee. Several groups are involved in revising RoHS, now known as RoHS2. U.K.-based ERA Technology was contracted to look at the viability of adding categories, such as medical equipment and monitoring and control instruments, to the scope of RoHS, mainly because they represent different markets than consumer electronic products.
Also, the EC assigned the German-based Oko Institute to consider adding new restricted substances within the scope of the directive. Oko was further asked to conduct a separate study considering the validity of all current exemptions to RoHS.
At last count, a list of 46 potential restricted substances was reduced to eight under RoHS2. But in a letter to its member companies in May 2008, IPC called the institute’s draft report on adding substance restrictions “biased” with “flawed methodologies.”
MORE CHANGES
Other proposed changes by the EC’s Directorate General Environment to both RoHS and WEEE directives showed up in a new round of proposals published in December, aimed at clarifying the scope and definitions in the directives. Details of the proposed changes can be found on the EC Web site at ec.europa.eu/environment/waste/weee/index_en.htm.
One change covers new procedures for exemptions, including introducing additional socio-economic criteria for granting exemptions and a requirement for applicants to evaluate substitutes before submitting requests. Another calls for adding medical devices and control and monitoring instruments to the scope of RoHS. There’s also language for establishing a clear mechanism for identifying and, “if necessary,” restricting the use of additional hazardous substances.
The EC says it recognizes that revisions to the RoHS directive covering medical devices and control and monitoring instruments may add manufacturing costs, particularly for products produced in smaller numbers. However, the commission also said that rolling out exemptions of these products over a period of time would allow the proposed exemptions to occur in normal product development cycles.
One of the big changes under consideration for WEEE is to harmonize the registration and reporting obligations for producers, along with harmonizing their financing across the EU. (Some member states already make producers fully financially responsible for WEEE.) The EC also wants to clarify what products are excluded from the scope of the directive.
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